Spring Compliance Update

by Natara Feller

You may be surprised to learn that, for the most part, the states have not delayed or suspended upcoming April compliance deadlines.  FERC on the other hand has extended the EQR deadline to June 1.  Below is a list of upcoming deadlines across FERC, EIA, various states and RTOs.  This list is not all-encompassing, and your Company may have regulatory compliance obligations beyond those listed below. Note that most states have suspended the requirement for paper filings and are only accepting electronic filings at this time.


  • 2020 Q1 EQRDue June 1 (any sales made on an RTO’s real-time or day-ahead market to balance power are required to be reported to FERC in the EQR.) Extended to June 1
  • Form 561Annual Interlock report due May 1
  • Form 552 – report of Natural Gas Transactions due May 1


  • Form 861, Annual Electric Power Industry Report due April 30 
  • Form 910 –  Monthly Natural Gas Marketers Survey due April 30
  • Form 861 – Monthly Electric Power Report due April 30




  • ISO-NE Annual Officer Certification Form due April 30
  • ISO-NE Information Disclosure Form due April 30 


  • MISO Annual Officer Certification Form due April 30


  • NYISO Annual Financial Certification was due March 30 (or 90 days after end of fiscal year)
  • NYISO Annual Officer Certification Forms due April 30
  • NYISO Annual Affiliate Certification due April 19


  • PJM Annual Officer Certification Form due April 30 (or last business day of April)
  • PJM Affiliate Disclosure Form due April 30
  • PJM Sector Selection due April 30



  • Historic ESCO Price Data Filing for Q1 April 30

Illinois Commerce Commission

  • ARES Annual Supplier Recertification due (Electric) April 30
  • Diversity Report due April 15


Ohio Public Utilities Commission

  • Renewable Portfolio Standards Filing due April 15
  • Quarterly Market Report due April 30 


Pennsylvania Public Utilities Commission

  • Annual Report due April 30
  • Quarterly Report due April 30 
  • Load Serving Entity Compliance Report due April 30 
  • Retail Choice Activity Report due April 30
  • Annual Revenue Report due April 30

In addition, the NYPSC Secretary granted a further extension of the implementation date of the Dec 12 Order by another 90 days.  Specifically, an extension is granted until August 10, 2020 for ESCOs to comply with the new rules concerning the product limitations for new enrollments and renewals (Ordering Clauses 1 & 2) and implementation of the changes to Section 2 & 5 of the UBP  (Ordering Clause 5).  The deadline to submit the enhanced eligibility application has been extended to September 9, 2020.


Natara G. Feller, Esq. | Managing Partner | Feller Law Group, PLLC