Align PDS Attestation Module Update

In July 2025, the North American Electric Reliability Corporation (NERC) updated the functionality of the Periodic Data Submittals (PDS) and Attestation modules in Align. The Attestation module experienced a complete overhaul with this update and the PDS module had several changes to allow for compatibility with the Attestation module.

The most important thing to note is that all attestations approved prior to the July update were removed from Align. If your Facility had an active attestation previously, you will need to submit a new attestation when you receive the PDS request. Texas RE will be sending FAC-003-5 PDS requests to all entities for the third quarter. Additionally, PDS requests for PRC-023 will be sent out to all entities in March 2026. Attestations in response to PTC-023 requests can be submitted at that time.

An approved active attestation provides entities an opportunity to opt out of the required Periodic Data Submissions for certain Standards while their attestation has an active status on an annual basis. NERC has designated attestations as, “a method for a registered entity to state a Standard or Requirement is not applicable for Periodic Data Submittals or Self-Certifications.” If your Facility does not meet the criteria for a specific Standard requested from the PDS and you have responded that your Facility is not applicable to the Standard, the Primary Compliance Contact (PCC) is encouraged to submit an attestation request directly from the PDS module. The attestation request is not to be submitted to attest to “no vegetation outages” during the quarter.

An entity needs to submit only one attestation per NERC Compliance Registration (NCR) for all functions needed for the attestation. For example:

• If NCR00000 has both Transmission Owner (TO) and Generator Owner/Operator (GO) functions as part of their registration and neither function meets the criteria for FAC-003-5, the attestation request would include both the TO and GO in the request
• If NCR55555 has both TO and GO functions as part of their registration, the TO function is applicable to Standard FAC-003-5 but the GO function does not meet the criteria for FAC-003-5; the attestation request would include only the GO in the request

Additionally, this new module lets entities update their attestation requests if the circumstances of the original attestation request change. New attestation requests will no longer be necessary to update an active attestation.

Please remember that an attestation request needs to include a detailed justification of how a Standard does not apply to a Facility.

Once an attestation is received by Texas RE, the request will be reviewed and either approved or disapproved. If the attestation is approved, the request is accepted for one year. The attestation will be submitted annually to the entity for renewal. Failure by an entity to complete the renewal by the appropriate date will result in that attestation expiring.

Further information on attestations is available through the links below. Please reach out to Texas RE with any questions.

Attestation User Guide
Registered Entity Attestation Training | Recording