The following article was written by Nazra Gladu, from Manitoba Hydro.
The mission of the North American Electric Reliability Corporation (NERC) is to assure effective and efficient reduction of risks to the reliability and security of the North American bulk power grid. In today’s rapidly evolving energy landscape, NERC compliance is more critical than ever. As the North American power grid incorporates more inverter-based resources[1] and manages risks from extreme weather events, compliance standards must evolve to uphold system reliability and resilience. NERC Reliability Standards are not mere regulatory checkboxes, they are essential safeguards that protect the integrity of the bulk power system and ensure the stability of the broader energy market in a complex, fast-paced environment.
A NERC requirement is a clearly defined, enforceable obligation set forth in a reliability standard.[2] It mandates specific actions or outcomes that registered entities like utilities, transmission operators, or other participants in the bulk power system must fulfill to ensure the reliable and secure operation of the electric grid.
The term “requirement” in the context of NERC compliance is more than just a rule to follow — it is a cornerstone of operational integrity and grid reliability.
R.E.Q.U.I.R.E.M.E.N.T.
Requirement is more than a word, it is a powerful framework that captures the essential components of a strong compliance culture. Each letter in R.E.Q.U.I.R.E.M.E.N.T. represents a critical element, from Regulations and Ethics to Monitoring and Transparency that together form the foundation of a resilient and accountable energy system.
Let us take a closer look at each of these letters:
R – Regulations
Regulations form the backbone of any compliance program, setting the legal and operational boundaries within which organizations must operate.
In the energy sector and beyond, understanding and adhering to local, national, and international regulations is essential to maintaining trust, avoiding penalties, and ensuring system reliability.
Whether it is data protection laws like Canada’s Personal Information Protection and Electronic Documents Act[3], healthcare mandates like Canada’s Health Act[4], or financial oversight frameworks such as Canada’s Bill 198[5], each regulation carries specific obligations that must be met.
For entities governed by NERC, this includes a wide array of reliability standards designed to safeguard the bulk power system. Staying current with evolving regulations helps organizations proactively anticipate risks, adapt to change, and maintain a competitive edge in a highly regulated environment.
E – Ethics
Ethical behaviour is the foundation of effective compliance and goes beyond simply following rules. Ethics are about doing the right thing, even when no one is watching.
When organizations prioritize integrity in their business practices, they naturally align with regulatory expectations and foster a culture of accountability.
Ethics serves as the moral compass that guides decision-making, helping teams navigate complex situations with transparency and fairness. Moreover, there is a direct link between a company’s core values and its ability to maintain regulatory adherence. For example, at Manitoba Hydro, our foundational values are reflected in our organization’s C.A.R.E. principles:
- Collaborate – Working together to achieve shared goals.
- Align – Ensuring our actions and decisions support our mission and values.
- Reimagine – Embracing innovation and continuous improvement.
- Empower – Enabling individuals and teams to take ownership and lead with confidence.
When ethics are embedded in the corporate culture, compliance becomes a natural extension of everyday operations rather than a burdensome obligation.
Q – Quality Assurance
Quality assurance is a critical pillar of compliance, ensuring that both processes and products consistently meet established standards. By embedding quality assurance into daily operations, organizations can detect and correct issues early, reducing the risk of non-compliance and enhancing overall reliability.
Quality assurance supports compliance through structured documentation, repeatable procedures, and continuous improvement practices. This consistency not only satisfies regulatory expectations but also builds trust with employees, our customers, interested parties, our board, and the public by demonstrating a commitment to excellence and accountability.
U – Understanding
A deep understanding of compliance frameworks is essential for building a strong and sustainable compliance program.
Knowing the rules and requirements is only the beginning. Organizations must also grasp the broader implications of those rules on operations, risk management, and strategic decision-making for compliance to become a shared responsibility throughout the enterprise.
I – Inspection
Regular inspections including external NERC Reliability Standards audits conducted by the Midwest Reliability Organization (MRO) and internal assessments, are essential for verifying compliance with NERC reliability standards and maintaining operational integrity. These reviews serve as a structured mechanism to assess whether policies and procedures are being followed as intended.
More importantly, inspections help uncover gaps, inefficiencies, or potential risks that might otherwise go unnoticed. By identifying these issues early, organizations can take corrective action before they escalate. Inspections reinforce accountability and demonstrate that compliance is a practice embedded in an organization’s culture.
R – Risk management
Effective compliance begins with the ability to identify, assess, and mitigate risks before they become violations. Risk management in a compliance context involves proactively scanning for vulnerabilities, whether operational, technical, or procedural that could lead to non-compliance.
By using tools such as risk assessments, control matrices, and compliance dashboards, organizations can prioritize threats and implement safeguards accordingly.
This proactive approach reduces the likelihood of regulatory breaches and strengthens overall resilience.
E – Education
Education is the fuel that powers a culture of compliance. Ongoing training ensures that employees know how to apply requirements in real-world scenarios.
By regularly updating staff on compliance policies, procedures, and regulatory changes, organizations empower their teams to make informed, responsible decisions. This continuous learning approach fosters a shared sense of accountability and reinforces the idea that compliance is everyone’s responsibility, not just the job of a dedicated department.
M – Monitoring
Monitoring is the ongoing pulse check of a compliance program, ensuring that policies are not only in place but actively followed. Through continuous oversight, whether via automated systems, manual reviews, or real-time alerts, organizations can detect deviations from compliance standards early and respond quickly.
Monitoring provides the data needed to evaluate the effectiveness of controls, identify trends, and make informed adjustments. It also reinforces accountability by demonstrating that compliance is not a one-time effort, but a sustained commitment to operational integrity and regulatory alignment.
E – Enforcement
Enforcement is the mechanism that ensures policies are not just written but followed. When violations occur, organizations can respond with appropriate corrective actions, whether that means re-training staff, revising procedures, or applying disciplinary measures.
Consistent enforcement reinforces the seriousness of compliance expectations and helps deter future non-compliance. It also demonstrates that the organization is committed to upholding standards and maintaining accountability. Without enforcement, even the most well-designed compliance program risks becoming ineffective.
N – Notification
Notification is a critical component of compliance that ensures transparency and timely communication when issues arise. Whether it is reporting a potential violation, disclosing a data breach, or informing regulators of operational changes, prompt and accurate notification helps maintain trust and demonstrate accountability. It also enables faster response and resolution, minimizing potential impacts.
Establishing clear notification protocols such as who needs to be informed, how, and when ensures that no critical information falls through the cracks. In a well-functioning compliance program, notification is not just reactive, it is a proactive tool for maintaining integrity and regulatory alignment.
T – Transparency
Transparency is the thread that weaves trust into every aspect of a compliance program. By openly documenting policies, decisions, and actions, organizations demonstrate their commitment to accountability and ethical conduct.
Transparency not only satisfies regulatory expectations but also builds confidence among employees, our customers, interested parties, and the public. It ensures that compliance efforts are visible, traceable, and verifiable, making it easier to identify issues, share best practices, and continuously improve. In a transparent organization, compliance is not hidden in the background – it is a visible, integral part of the culture.
The R.E.Q.U.I.R.E.M.E.N.T. framework highlights the multi-faceted nature of compliance. Each element, from Regulations and Ethics to Transparency, plays a vital role in building a culture of accountability and operational excellence.
Together, they form a comprehensive approach that not only ensures adherence to NERC standards but also strengthens organizational resilience. Compliance is no longer just a legal obligation, it is a strategic advantage that protects your infrastructure, enhances trust, and positions an organization for long-term success. Now is the time for organizations to evaluate, reinforce, and evolve their compliance programs – because reliability isn’t optional, it’s essential.
[1] Inverter-Based Resources (IBRs) are types of power generation technologies that produce electricity in direct current (DC) and use power electronic inverters to convert it into alternating current (AC), which is compatible with the electric grid. Examples include wind turbines, fuel cells, solar photovoltaic (PV) systems.
[2] https://www.nerc.com/pa/Stand/Pages/ReliabilityStandards.aspx
[3] The Personal Information Protection and Electronic Documents Act (PIPEDA): https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/
[4] Canada Health Act: https://www.canada.ca/en/health-canada/services/health-care-system/canada-health-care-system-medicare/canada-health-act.html
[5] Canada’s Bill 198 Similar to U.S.’s Sarbanes Oxley Act: https://www.asyma.com/blog/canadas-bill-198-similar-to-u.s.s-sarbanes-oxley-act
About the Author
Nazra Gladu, P.Eng., is a Reliability Compliance Program Engineer at Manitoba Hydro, the province’s largest and only integrated electricity and natural gas utility. With over 17 years of experience, she leads the development and oversight of corporate compliance programs, regulatory engagement, internal audit strategies, and regulatory audits to ensure alignment with evolving reliability standards.
Nazra holds a B.Sc. in Electrical Engineering from the University of Manitoba and has held diverse roles in system operations, project management, and engineering. She actively contributes to several industry and professional committees, including Electricity Canada’s Electric Regulatory Advisory Committee, Engineers Geoscientists Manitoba’s Equity, Diversity, and Inclusion Committee, Manitoba Hydro’s Engineer-in-Training Recruitment Panel, and Manitoba Hydro Professional Engineers Association Volunteer Services Committee. She is also a past member of the Midwest Reliability Organization’s Compliance Monitoring and Enforcement Program Advisory Council.
Nazra is a published author and active contributor to the compliance community, with a strong passion for mentorship, equity in engineering, and community engagement. Outside of work, she enjoys creating stained glass art, cheering at her son’s soccer games, and supporting Winnipeg’s vibrant local pro wrestling scene.
DISCLAIMER
MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject matter experts from MRO’s organizational groups have authored some of the articles in this publication, and the opinion and views expressed in these articles are those of the author(s) and do not necessarily represent the opinions and views of MRO.