FERC's New Financial Forms NOPR: What Filers Should Know About the Proposed Changes

On June 18, 2026, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) in Docket RM26-12-000 proposing revisions to its annual and quarterly financial forms. While many of the changes are administrative in nature, the proposal would make several meaningful changes to FERC's financial reporting requirements for regulated entities.

The proposal affects FERC Forms 1, 1-F, 2, 2-A, 3-Q, 6, 6-Q, and 60. Form 714 is not impacted. Overall, the proposal focuses on modernizing filing requirements, removing outdated reporting obligations, improving consistency across forms, and reducing certain quarterly reporting requirements.

Although many of the proposed revisions appear straightforward, they would require accounting organizations and software providers to update reporting processes, software, controls, and documentation if the rule is finalized.

What Are the Key Proposed Changes?

Among the most significant proposals are reductions to quarterly reporting requirements:

• Removal of 17 of 24 schedules from Form 3-Q (electric)

• Removal of 3 of 19 schedules from Form 3-Q (gas)

• Removal of 3 of 11 schedules from Form 6-Q (oil)

The proposal also includes:

• Eliminating Annual Reports to Stockholders filing requirements

• Modernizing filing instructions

• Clarifying oil pipeline quarterly filing exemptions

• Updating CPA certification requirements

• Correcting numerous schedule-level instruction discrepancies

• Aligning forms more closely with current XBRL filing processes

While many of these revisions are intended to simplify the reporting process, organizations should also consider the operational implications of implementing the changes and how they may affect existing reporting workflows.

What is Changing - the Details You Need to Know

1. Quarterly Reporting Requirements Would Be Significantly Reduced

The most visible proposal affects quarterly financial reporting.

The most impacted form is FERC Form 3-Q (electric). FERC proposes retaining only seven core financial schedules:

• Schedule 108 - Important Changes During the Quarter

• Schedule 110 - Comparative Balance Sheet

• Schedule 114 - Statement of Income

• Schedule 118 - Statement of Retained Earnings

• Schedule 120 - Statement of Cash Flows

• Schedule 122 - Notes to Financial Statements

• Schedule 122a - Statement of Accumulated Comprehensive Income/Hedging Activities

For FERC Form 3-Q (gas), FERC proposes removing:

• Schedule 200 - Summary of Utility Plant and Accumulated Provisions for Depreciation, Amortization, and Depletion 

• Schedule 210 - Gas Plant in Service and Accumulated Provision for Depreciation by Function 

• Schedule 339 - Depreciation, Depletion and Amortization of Gas Plant (Accounts 403, 403.1, 404.1, 404.2, 404.3, 405) 

Finally, for FERC Form 6-Q (oil), FERC proposes removing:

• Schedule 300 - Operating Revenue

• Schedule 302 - Operating Expense Accounts

• Schedule 600a - Statistics of Operations – Operated by Others

FERC explains that much of the information proposed for removal is either already collected through annual filings or provides limited regulatory value on a quarterly basis.

From an implementation perspective, these changes would reduce the number of quarterly schedules that many organizations prepare. At the same time, they would require updates to reporting software, taxonomies, validation rules, rendering logic, internal procedures, and testing before implementation.

There is also a broader accounting consideration. Many organizations perform key financial processes monthly or quarterly because recurring execution helps reinforce procedures, maintain institutional knowledge, and identify issues earlier in the reporting cycle. Similar to monthly account reconciliations, preparing financial schedules on a recurring basis can strengthen reporting discipline by allowing questions or inconsistencies to be addressed before year-end. Whether the proposed schedule reductions preserve that balance is one of the questions stakeholders may wish to consider during the comment process.

2. CPA Certification Requirements Would Be Modernized

FERC proposes removing the prescribed CPA attestation language currently required for Forms 1 and 1-F. Instead, independent accountants would be permitted to use professional judgment while continuing to certify compliance with FERC reporting requirements and the Uniform System of Accounts. In addition:

• CPA certifications would be submitted through the eForms portal (eCollection.ferc.gov)

• eFiling and mailed submissions would no longer be required for certification statements

These changes would align the certification process more closely with FERC's broader electronic filing framework for Forms 2 and 2-A and would simplify the submission process.

3. Annual Reports to Stockholders Would No Longer Be Required

FERC proposes eliminating the requirement to submit Annual Reports to Stockholders with Forms 1, 1-F, 2, and 6.

The Commission notes that these reports are generally already publicly available and no longer provide sufficient regulatory value to justify the additional filing requirement.

4. Oil Pipeline Filing Exemption Would Be Clarified

The proposal clarifies that oil pipeline companies with less than $500,000 in annual jurisdictional operating revenues would not be required to file Form 6-Q if they are not otherwise required to file annual Form 6.

This clarification primarily resolves ambiguity within the current filing requirements rather than creating a new reporting obligation.

5. Numerous Schedule-Level Instruction Updates

The proposal also includes a wide range of technical revisions, including:

• Correcting form instructions

• Fixing column references

• Clarifying year-to-date reporting requirements

• Replacing "written off" columns with "credits"

• Updating petroleum commodity codes

• Revising substation classification language

• Removing obsolete footnote references

• Updating filing terminology to match modern XBRL processes

While individually modest, these revisions may still require updates to software, documentation, testing, and internal procedures.

What Does This Mean for Filing Season?

If finalized, the proposal would require organizations to update both technology and internal reporting processes before implementation.

Areas organizations may need to evaluate include:

• Taxonomy updates

• Reporting software changes

• Internal procedures and documentation

• Validation and testing

• User training

• Internal controls

Although the proposal is intended to reduce certain reporting requirements over the long term, implementation will still require careful planning to ensure reporting processes remain accurate and well controlled.

The irony is that a burden-reduction rule can temporarily increase workload while organizations prepare for the new requirements.

Potential Audit and Compliance Impacts

Even though this proposal reduces reporting requirements, regulated companies should expect auditors and compliance teams to focus on implementation controls.

Questions auditors may ask include:

• Were removed schedules properly discontinued?

• Were all newly revised instructions applied correctly?

• Were year-to-date reporting clarifications implemented consistently?

• Were CPA certification processes updated?

• Were taxonomy updates properly validated?

• Were internal controls updated to reflect the new reporting structure?

Organizations should also consider retaining historical reporting capabilities for trend analysis and support during regulatory reviews, even if certain schedules are no longer filed quarterly.

Questions to Ask Your FERC Software Vendor

The proposal provides a good opportunity for organizations to discuss implementation plans with their software providers. Consider asking questions such as:

• How quickly will software updates be available if the proposal is finalized?

• How will taxonomy and validation changes be communicated to users?

• How will historical filings be preserved if schedules are removed?

• How will software handle both historical and future reporting requirements during the transition?

Should Companies Submit Comments?

Absolutely.

Many of the proposed revisions appear administrative or noncontroversial, but several changes, particularly those affecting quarterly reporting, may have broader implications for financial reporting processes, regulatory transparency, benchmarking, and implementation.

Every organization uses these forms differently. Some may view the proposed changes as a meaningful reduction in reporting burden, while others may rely on recurring quarterly reporting as part of their overall financial reporting and control environment.

FERC has specifically requested feedback on many of these proposals, making this an important opportunity for utilities, pipelines, consultants, auditors, and software providers to share practical implementation perspectives before a final rule is issued. Comments are due 60 days after publication in the Federal Register, with reply comments due 30 days later.

Bottom Line

This NOPR represents an important modernization effort for FERC's financial reporting framework. While many of the proposed revisions simplify or update existing requirements, organizations will still need to carefully evaluate the work required to implement the changes if they are finalized. 

For accounting and regulatory reporting teams, now is the time to understand the proposal, evaluate how it may affect existing processes, and determine whether there are aspects of the proposal they would like FERC to consider before issuing a final rule.

For software providers, the proposal will require careful planning to ensure taxonomies, validations, reporting workflows, and historical reporting capabilities continue to support customers throughout the transition.

The organizations that begin evaluating these changes now will be best positioned when FERC establishes its final implementation timeline. To review the NOPR docket in its entirety, please visit M-1 | RM26-12-000 | FERC.