Grid Transformation - BCSI in the Cloud

The 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP IP) emphasizes the significance of understanding the risks associated with the grid transformation risk element as the energy sector evolves and adopts new technologies. While there are multiple North American Electric Reliability Corporation (NERC) Standards associated with the grid transformation risk element in the 2026 CMEP IP, the two Standards applicable to Bulk Electric System (BES) Cyber System Information (BCSI) in the cloud are CIP-011-3, R1 and CIP-004-6, R6. Outlined below are some items of interest.

CIP-011-3, R1: As new grid transformation technologies are adopted, often new security risks are introduced. These risks frequently require additional security controls to mitigate the new security risks. Responsible Entities should consider assessing their internal controls, access controls, and methods to identify, protect, and securely handle BCSI when adopting new or emerging technologies.

CIP-004-6, R6: Effective access management is vital to information protection as new grid transformation technologies are adopted. Effective access management ensures only authorized individuals can access sensitive information such as BCSI. Responsible Entities should understand the interdependent relationship between CIP-004-6 and CIP-011-3.

Some best practices and controls that Responsible Entities should consider are:

• Periodically reassessing policies and procedures surrounding CIP-011-3 (information protection), and the employees who have access to BCSI
• Periodically reviewing policies and procedures surrounding CIP-004-7, R6 (access management for BCSI)

For more information on the grid security risk element, Texas RE encourages Responsible Entities to refer to the 2026 CMEP IP.