The EQR Final Rule Is Here: What Order No. 917 Means for Market Participants and ISOs
- Apr 1
- 3 min read
Updated: Apr 3
After nearly three years of stakeholder engagement and technical conferences, the Federal Energy Regulatory Commission (FERC) has released the long-awaited Electric Quarterly Report (EQR) Final Rule, Order No. 917. Issued on March 19, 2026, the rule represents the most significant overhaul of EQR reporting in over 20 years.
Why FERC Acted Now
The EQR has long served as a critical tool for FERC to monitor wholesale power markets and ensure that rates, terms, and conditions are on file as required under Sections 205 and 220 of the Federal Power Act. However, the existing reporting framework has increasingly shown its age.
In the Final Rule, FERC explains that data inconsistencies, technical limitations, and market growth of RTO/ISO required a more complex structure that the old system was not equipped to handle. Order No. 917 is FERC’s solution.
The Shift to XBRL-CSV: A Foundational Change
One of the most significant changes in the Final Rule is FERC’s decision to move EQR submissions to an XBRL-CSV-based reporting system, replacing the current XML format.
This move is intended to make data easier to search, aggregate, interoperate, and analyze.
This will also require sellers to start coordinating with IT teams and FERC software vendors like Systrends to map internal data to the new FERC Taxonomy, once released.
Extended Filing Deadlines: A Practical Win
In response to widespread industry feedback, FERC adopted an extended EQR filing timeline by moving from 30 days after the quarter to four months after the quarter.
For many market participants, especially those operating in ISO/RTO markets, this change is significant. It allows more time for resettlement data, resulting in fewer refilings. FERC expects to see a significant drop in the need for subsequent refilings.
Refiling Policy and Look-Back Period
There were also a few changes made to the refiling policy, material edits, and look-back period.
Sellers are still required to refile EQRs when they discover material errors or omissions, but FERC chose not to set a strict rule for what counts as “material.” Instead, materiality depends on the specific situation and should be judged based on the overall significance of the issue, not just the dollar value.
Sellers are expected to use reasonable judgment, considering issues pertaining to how the error affects rates or prices, how many quarters are impacted, and the seller’s size and transaction volume.
The final rule states that the refile period default will remain at 12 quarters (three years), but FERC clarified that it retains authority and could require refilings beyond 12 quarters in exceptional circumstances. Which would be for rare circumstances.
A new notes field will be required for all refilings which can be used to explain why the correction is being made and how the error occurred.
New Reporting Obligations for ISOs and RTOs
Sellers may think that the ISO obligation to provide EQR transaction data is not new, or that it only pertains to the ISO/RTOs. But this change has direct and meaningful implications for sellers in that market.
Under the Final Rule, ISO-provided transaction data becomes the authoritative reference point for organized-market transactions in EQRs.
For sellers, this means:
Less ambiguity about what should be reported
Greater consistency across market participants
Reduced risk that a seller’s EQR diverges from regulator-expected data
What Market Participants Should Be Doing Now
Implementation will take time. While the rule is effective on May 26, 2026, meaningful changes like the transition to XBRL-CSV and ISO/RTO transaction data reports will likely roll out over the following 12 to 24 months. FERC still needs to prepare technical sessions, portal developments, and testing. This provides the opportunity for market participants to prepare thoughtfully rather than reactively.
Practical next steps include:
Engaging with EQR experts like Systrends about XBRL-CSV readiness
Reviewing internal data sources and controls for EQR fields
Monitoring for FERC staff guidance, draft taxonomies, and technical conference announcements
For ISOs/RTOs, beginning internal coordination around transaction data reporting responsibilities
Companies that start early will be better positioned to reduce compliance risk, avoid unnecessary refilings, and take advantage of the efficiencies this new rule is intended to deliver.
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