FERC Order No. 919: CIP Reliability Standards for Virtualization Technologies

The Federal Energy Regulatory Commission (FERC) issued Order No. 919 on March 24, 2026, approving 11 modified Critical Infrastructure Protection (CIP) Reliability Standards submitted by the North American Electric Reliability Corporation (NERC). These modifications are designed to accommodate virtualization and other emerging technologies within the U.S. electric grid infrastructure while maintaining robust cybersecurity protections. As part of the order, FERC also approved four new definitions and 18 modified definitions to be incorporated into NERC's Glossary of Terms Used in Reliability Standards, ensuring that the language governing grid reliability keeps pace with technological evolution. A central concern addressed in the order is a proposed self-implementing exception phrase — 'per system capability' — that appears across multiple provisions of the modified standards. FERC found this phrase insufficiently defined and directed NERC to develop a clear, enforceable set of criteria for when a responsible entity may invoke this exception, ensuring adequate oversight, consistency in application, and requirements for alternative mitigation measures. The order reflects FERC's broader effort to modernize grid reliability standards to support secure adoption of cloud-based and virtualized environments by electric utilities, while preserving the integrity of critical infrastructure protection frameworks.

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