Nearly three years after proposing reforms, the Federal Energy Regulatory Commission (FERC) has largely adopted its proposed revisions to Electric Quarterly Report (EQR) requirements.
The proposed rule, issued on Oct. 19, 2023, and described in detail here, sought to simplify the EQR filing process and make it less burdensome for filers.
On March 19, 2026, FERC largely adopted its Notice of Proposed Rulemaking, save for a few changes, some of which are significant. Read on for more information on the revisions FERC adopted as part of Order No. 917 and the implications for sellers who submit EQRs.
Key Takeaways of FERC’s Final Rule
While FERC’s final rule is detailed, and a granular review is advisable, among the most important aspects of which EQR filers should be aware are:
1. FERC will require sellers to submit all reports through a new and different electronic system that is not yet developed (XBRL-CSV).[i] The current system permits sellers to submit data in multiple ways, often through vendor-developed software solutions, but does not use the XBRL-CVS format. EQR filers will have to coordinate with their software vendors as the new system is developed. FERC found that issuing the final rule before developing the necessary details, would be “the most efficient and effective approach” and that “the technical implementation details can be resolved by [FERC] staff and the industry.”[ii]
Following its issuance of the final rule, FERC will post draft documents, including draft taxonomies (i.e., files containing relevant business terminology, their meanings, their data types, relationships among terms, and the rules or formulas they must follow) and other related guidance.[iii] Staff will then convene one or more technical conferences and ultimately post proposed taxonomies and guidance upon which interested parties may comment.[iv] FERC anticipates issuing a further order on the posted staff proposal.[v]
2. FERC extended the reporting deadline to submit EQRs to four months after close of period to give time for RTO/ISO data to be finalized.[vi]
This new schedule, shown below, will only be implemented after the change to the new XBRL-CSV system is fully implemented.[vii]
| Quarter | Reporting Period | Current Deadline | New Deadline |
|---|---|---|---|
| First | Jan. 1-March 31 | April 30 | July 31 |
| Second | April 1-June 31 | July 31 | Oct. 31 |
| Third | July 1-Sept. 31 | Oct. 31 | Jan. 31 |
| Fourth | Oct. 1-Dec. 31 | Jan. 31 | April 30 |
3. FERC declined to extend the current 12-quarter refiling period (for corrections to previously-submitted data) to 20 quarters and emphasized that only material changes should be fixed.[viii]
Accordingly, the requirement will remain that a seller must only re-file 12 quarters’ (three years’) worth of data, or as far back as the error occurred, if earlier. FERC also emphasized, repeatedly, that only “material” changes need to be corrected.[ix] FERC further elaborated on what materiality means but declined to establish a bright line rule.[x]
4. FERC will require RTOs/ISOs to provide sellers’ transaction data correctly formatted in the newXBRL-CSV standard.[xi]
FERC found that “[t]his requirement will help Sellers to prepare and submit Transaction data in the EQR and will reduce the amount of manual data manipulation prior to submission.”[xii] Sellers will still be responsible for compiling data as part of their reports and will be responsible for ensuring data accuracy.[xiii]
5. FERC determined that only “significant changes” to taxonomies or the data dictionary will be filed for public comment.[xiv]
FERC explained that “minor or non-material” future changes to taxonomies or the data dictionary will be posted to FERC’s EQR website.[xv] Posted non-material changes will not take effect until at least 60 days after posting.[xvi]
In addition to these significant changes, the final rule modifies, deletes and adds a number of data fields.
Implementation Timeline
FERC’s final rule will become effective 60 days after its posting in the Federal Register. That said, the status quo filing mechanics will remain the same until the technical implementation described above can be accomplished. Implementation will involve technical conferences where FERC staff, software vendors and industry representatives will be able to coordinate on details, and ultimately another FERC filing. This process could take several months, if not years, to fully implement.
McGuireWoods’ Federal Energy Regulatory Commission team will continue to monitor these issues and is available to assist with any FERC compliance questions. For more information, contact the authors or a member of the federal energy regulatory team.
[i] Filing Process and Data Collection for the Electric Quarterly Report, Order No. 917, 194 FERC ¶ 61,195 at P 35 (2026) (“Order No. 917”).
[ii] Order No. 917, 194 FERC ¶ 61,195 at P 36.
[iii] Order No. 917, 194 FERC ¶ 61,195 at P 35.
[iv] Order No. 917, 194 FERC ¶ 61,195 at PP 35-36.
[v] Order No. 917, 194 FERC ¶ 61,195 at P 36.
[vi] Order No. 917, 194 FERC ¶ 61,195 at P 64.
[vii] Order No. 917, 194 FERC ¶ 61,195 at P 64.
[viii] Order No. 917, 194 FERC ¶ 61,195 at P 115.
[ix] Order No. 917, 194 FERC ¶ 61,195 at P 109.
[x] Order No. 917, 194 FERC ¶ 61,195 at PP 112-114.
[xi] Order No. 917, 194 FERC ¶ 61,195 at PP 85-87.
[xii] Order No. 917, 194 FERC ¶ 61,195 at P 86.
[xiii] Order No. 917, 194 FERC ¶ 61,195 at P 86.
[xiv] Order No. 917, 194 FERC ¶ 61,195 at P 55.
[xv] Order No. 917, 194 FERC ¶ 61,195 at P 56.
[xvi] Order No. 917, 194 FERC ¶ 61,195 at P 56.