A Coordinated Electric System Interconnection Review—the utility’s deep-dive on technical and cost impacts of your project.

Challenge: Frequent false tripping using conventional electromechanical relays
Solution: SEL-487E integration with multi-terminal differential protection and dynamic inrush restraint
Result: 90% reduction in false trips, saving over $250,000 in downtime

Inverter-Based Resource (IBR) Registration Initiative: What Category 2 Generator Owners and Operators Need to Know

IBR Registration Initiative for Category 2 Generator Owners and Operators
Calendar icon. D

january 30, 2026 | Blog

Introduction

The rapid growth of inverter-based resources (IBRs) including solar PV, wind, battery energy storage systems (BESS), and hybrid facilities has fundamentally changed how the Bulk Power System (BPS) operates. While these resources bring flexibility and decarbonization benefits, they also introduce new reliability risks if not properly modeled, operated, and governed.

To address these challenges, the North American Electric Reliability Corporation (NERC) launched the IBR Registration Initiative, a multi-year effort to bring previously unregistered BPS-connected IBR owners and operators under the NERC compliance framework. As of May 2025, the initiative has entered its third and final phase: registration with a firm compliance effective date of May 15, 2026 for newly registered Category 2 entities 


This article explains:

  • What Category 2 Generator Owner (GO) and Generator Operator (GOP) registration means
  • Who must register and why
  • Key timelines, documentation, and risks
  • How Keentel Engineering supports IBR owners through registration and ongoing NERC compliance

Understanding Category 2 GO and GOP Registration

What Is Category 2?

NERC revised its Rules of Procedure (ROP) to formally define Category 1 and Category 2 Generator Owners and Operators. Category 2 primarily captures IBR facilities that were historically outside the NERC compliance registry but now meet revised Bulk Electric System (BES) and aggregation criteria 


In practical terms, Category 2 typically includes:

  • Solar, wind, BESS, and hybrid facilities
  • Aggregated resources ≥ 20 MVA
  • Facilities interconnected at ≥ 60 kV
  • Assets connected to the BPS, even if individually smaller

If a facility aggregates with others to exceed the threshold at a common point of connection, all participating facilities become Category 2 assets, triggering registration obligations 


Why This Registration Matters

Many IBR owners are encountering NERC registration for the first time. This is not a paperwork exercise it is a fundamental shift in regulatory exposure.


Once registered, Category 2 GO/GOPs become subject to:

  • Mandatory NERC Reliability Standards
  • Audit readiness expectations
  • Model validation, protection, and performance requirements
  • Event reporting, disturbance analysis, and coordination obligations


Failing to engage early increases the risk of:

  • Incomplete or incorrect registration
  • Delayed approvals
  • Compliance gaps at the May 2026 enforceability date

NERC and the Regional Entities have been clear: timely cooperation is mandatory, not optional 


Registration Timeline and Key Milestones

According to NERC, Category 2 registrations are being processed in batches between August 2025 and April 2026, with a universal effective registration date of May 15, 2026 


Key takeaway:

Even though compliance enforcement begins in May 2026, registration activities are happening now, and Regional Entities are operating on different schedules.

Keentel strongly recommends initiating internal readiness at least 9–12 months before the effective date.


Required Documentation for Category 2 Registration

Entities must submit detailed technical and contractual information through CORES or a Regional Entity secure portal, including 

:

  • Completed GO/GOP Asset Verification Form
  • Interconnection Agreement (and amendments)
  • Operating and third-party O&M agreements
  • Electrical one-line diagrams (from resource to POI)
  • Inverter or turbine nameplate data

This documentation is not just administrative—it becomes the foundation for:

  • BES applicability determination
  • Compliance scope
  • Future audits and enforcement actions

Confidentiality and Data Protection

Some asset owners hesitate to share technical data without an NDA. NERC explicitly states that NDAs are not required. Instead, all submitted data is protected under ROP Section 1500 (Confidential Information), which legally binds Regional Entities to safeguard sensitive information 


Multi-Regional Entities and Phased Projects

Facilities in Multiple Regional Entities

If your organization owns or operates Category 2 facilities across multiple Regional Entity footprints:

  • You must comply with each Regional Entity’s timeline
  • Registrations may not be synchronized
  • Separate approval letters may be issued

Phased Commercial Operation

Projects coming online in phases must register early, even if initial phases only meet Category 2 thresholds and later phases may elevate the facility to Category 1 status 


Life After Registration: What Changes?

Once registered, Category 2 entities must prepare for:

  • Applicable NERC Reliability Standards (per the quarterly compliance dates matrix)
  • Future transition to GADS reporting (effective May 15, 2026)
  • CMEP oversight and possible inclusion in the Coordinated Oversight Program
  • Cyber and physical security participation via E-ISAC membership (a free benefit of registration) 

How Keentel Engineering Supports Category 2 IBR Owners

Keentel Engineering specializes in bridging the gap between registration and real-world compliance. Our services include:

Registration & Applicability Support

  • Category 2 GO/GOP determination
  • BES and aggregation analysis
  • Registration strategy across multiple Regional Entities

Technical Documentation & Engineering

  • One-line diagram development and validation
  • Inverter and BESS nameplate verification
  • Interconnection and operating agreement reviews

NERC Compliance Readiness

Long-Term Compliance Support

  • Ongoing advisory services
  • Model validation updates
  • Event response and disturbance analysis support

Expanded FAQ – Practical Answers for Asset Owners

  • Do I still need to submit documentation if I believe my asset does not meet Category 2 criteria?

    Yes. Self-determinations do not replace Regional Entity evaluations. All requested documentation must be submitted before a formal decision is issued 


  • What if I don’t yet know who my GOP will be?

    Register as both GO and GOP. The registration can be revised later once a formal GOP is designated 


  • When do GADS requirements begin?

    GADS reporting is not required until May 15, 2026, but early confirmation submissions are recommended 


  • Can Category 2 entities join the Coordinated Oversight Program?

    Yes, provided the organization operates in two or more Regional Entities. Any changes will be formally processed after the registration effective date 

  • What is E-ISAC and why does it matter?

    E-ISAC provides threat intelligence for cyber and physical security risks and is a free benefit of NERC registration, offering significant operational value to new registrants 



Final Thoughts

The IBR Registration Initiative is not just a regulatory formality—it represents a structural shift in how inverter-based resources are governed within the North American grid. For Category 2 Generator Owners and Operators, early action, strong engineering support, and compliance-focused planning are essential.

Keentel Engineering stands ready to guide IBR owners through every phase—from registration to full NERC compliance—so there are no surprises when May 2026 arrives.



Man in a blazer and open shirt, looking at the camera, against a blurred background.

About the Author:

Sonny Patel P.E. EC

IEEE Senior Member

In 1995, Sandip (Sonny) R. Patel earned his Electrical Engineering degree from the University of Illinois, specializing in Electrical Engineering . But degrees don’t build legacies—action does. For three decades, he’s been shaping the future of engineering, not just as a licensed Professional Engineer across multiple states (Florida, California, New York, West Virginia, and Minnesota), but as a doer. A builder. A leader. Not just an engineer. A Licensed Electrical Contractor in Florida with an Unlimited EC license. Not just an executive. The founder and CEO of KEENTEL LLC—where expertise meets execution. Three decades. Multiple states. Endless impact.

Four workers in safety vests and helmets stand with arms crossed near wind turbines.

Let's Discuss Your Project

Let's book a call to discuss your electrical engineering project that we can help you with.

Man in a blazer and open shirt, looking at the camera, against a blurred background.

About the Author:

Sonny Patel P.E. EC

IEEE Senior Member

In 1995, Sandip (Sonny) R. Patel earned his Electrical Engineering degree from the University of Illinois, specializing in Electrical Engineering . But degrees don’t build legacies—action does. For three decades, he’s been shaping the future of engineering, not just as a licensed Professional Engineer across multiple states (Florida, California, New York, West Virginia, and Minnesota), but as a doer. A builder. A leader. Not just an engineer. A Licensed Electrical Contractor in Florida with an Unlimited EC license. Not just an executive. The founder and CEO of KEENTEL LLC—where expertise meets execution. Three decades. Multiple states. Endless impact.

Leave a Comment

Related Posts

IBR Registration Initiative for Category 2 Generator Owners and Operators
By SANDIP R PATEL January 31, 2026
Understand NERC PRC-029-1 ride-through requirements for IBRs, key compliance dates through 2026, applicability to BES and non-BES assets, and what Generator Owners must do now.
Understanding Category 2 IBR Registration and Compliance white paper cover by Keentel Engineering fe
By SANDIP R PATEL January 31, 2026
Complete guide to Category 2 IBR registration and compliance, including NERC requirements, FERC Order 901, CMEP enforcement, applicable standards, and preparation steps.
Map of 2025-2026 Winter Reliability Risks for the power grid with Keentel Engineering logo.
By SANDIP R PATEL January 29, 2026
The 2025–2026 Winter Reliability Assessment highlights rising winter demand, resource mix shifts, and NERC compliance changes, impacting grid reliability and engineering.
Lifecycle management of T&D switchgear using condition monitoring data, showing engineers analyzing
By SANDIP R PATEL January 24, 2026
Learn how utilities use condition monitoring data to manage T&D switchgear lifecycles, reduce failure risk, extend asset life, and enable condition-based maintenance.
Frequency response characteristics of voltage measurement systems illustrated with substation and wa
By SANDIP R PATEL January 21, 2026
Explore frequency response characteristics of voltage measurement systems used in power substations and grid analysis by Keentel Engineering.
Keentel Engineering white paper cover on reevaluating IEEE and IEC substation standards for increase
By SANDIP R PATEL January 21, 2026
Professional white paper cover by Keentel Engineering on reevaluating IEEE and IEC substation standards, featuring an electrical substation under fault conditions.
Learn how PJM D-Curve reactive capability testing is performed for wind farms and inverter-based res
By SANDIP R PATEL January 15, 2026
Learn how PJM D-Curve reactive capability testing is performed for wind farms and inverter-based resources, including testing requirements, measurement basis, and eDART submission support.
Energy sector integration showing power grids, wind turbines, solar energy, and multi-energy system
By SANDIP R PATEL January 1, 2026
Explore how energy sector integration reshapes modern power grids, improving decarbonization, resilience, and system planning based on CIGRE TB 973 insights.
Diagram illustrating real-code EMT modeling for HVDC, FACTS, and inverter-based resources in power s
By SANDIP R PATEL January 1, 2026
Learn how IEEE/CIGRE real-code EMT modeling improves HVDC, FACTS, and inverter-based resource studies with higher fidelity, compliance accuracy, and tool-independent simulation.