NERC Preparing to Identify Computational Load Sites: What Computational Load Owners and Operators Need to Do Now
NERC and Regional Entities are preparing to initiate the registration process for Computational Load Owners (CLOs) and Computational Load Operators (CLOPs) in early 2027. Computational Load Owners and Operators should begin preparing now.
The North American Electric Reliability Corporation (NERC) has taken another important step toward implementing its new registration requirements for computational loads. On October 30, 2026, NERC posted a proposed Section 1600 Data Request for Computational Load Site information, initiating a 14-day industry comment period ending November 12, 2026.
This data request is intended to help NERC and its Regional Entities identify operational and planned Computational Load Sites across the Bulk Power System footprint and expedite the registration process for Computational Load Owners and Computational Load Operators.
How Will NERC Identify Computational Load Sites?
One important aspect of this upcoming process is how NERC and the Regional Entities intend to identify the computational load facilities that may fall under the new registration requirements.
The anticipated process will involve the following steps:
1. NERC will issue a data request to Transmission Owners (TOs) and Distribution Providers (DPs).
NERC will reach out to Transmission Owners and Distribution Providers to identify Computational Load Sites connected to their respective transmission and distribution systems. The TOs and DPs will be requested to submit their data using a secure data collection system.
2. Computational Load Site information will be collected.
The proposed Section 1600 Data Request is intended to obtain key information about operational and planned Computational Load Sites, including:
Contact information
Facility location
Facility size
Operational and development status
In-service date or expected in-service date
This information will help NERC and the Regional Entities establish an inventory of Computational Load Sites and identify the entities potentially subject to the new registration requirements.
3. NERC and Regional Entities will contact Computational Load Owners and Operators.
Once Computational Load Sites have been identified, NERC and its Regional Entities will begin reaching out directly to the applicable Computational Load Owners and Computational Load Operators to initiate the registration process.
4. Registration activities are expected to begin in early 2027.
Following FERC approval of NERC's proposed revisions to the NERC Rules of Procedure registry criteria, NERC and the Regional Entities intend to move forward with registering the applicable Computational Load Owners and Computational Load Operators.
What Should Computational Load Owners and Operators Be Doing Now?
Although the formal registration process is not expected to begin until early 2027, computational load owners and operators should not wait until they receive an inquiry from NERC or their Regional Entity.
There are several practical steps organizations should begin taking now:
1. Identify potentially applicable Computational Load Sites.
Develop an inventory of existing and planned computational load facilities, including data centers and other facilities that may meet the applicable computational load definitions and registration thresholds.
2. Understand ownership and operational responsibilities.
Determine which legal entities own, maintain, and operate each Computational Load Site. Ownership and operational responsibilities may reside with separate organizations, meaning that multiple entities could have registration obligations associated with the same facility.
3. Gather facility and contact information.
Begin compiling the information likely to be requested during the registration process, including facility addresses, ownership and operating entities, facility size, operational status, site-level characteristics, and appropriate regulatory and compliance contacts.
4. Evaluate NERC registration applicability.
Review the NERC Board's recently approved Computational Load standards (CLO-001-1, CLO-002-1, and CLO-003-1), along with the proposed revisions to the NERC Rules of Procedure registry criteria. Organizations should understand how the new requirements apply to their facilities and determine which entities may need to register as Computational Load Owners and/or Computational Load Operators.
5. Establish a registration and compliance readiness plan.
Organizations should begin identifying internal stakeholders, assigning responsibilities, and establishing processes to respond to NERC and Regional Entity inquiries. This is particularly important for organizations with multiple computational load facilities, complex ownership structures, or third-party operators.
Important Upcoming Milestone: November 12, 2026
NERC is currently accepting comments on its proposed Section 1600 Data Request for Computational Load Sites.
Publication date: October 30, 2026
Comment period: 14 days
Comment deadline: November 12, 2026
Submission email: ERO.Registration@nerc.net
The proposed data request is available here:
Final Thoughts
NERC's proposed data collection marks a significant transition from developing the new Computational Load standards to implementing the registration requirements across the industry.
For computational load owners and operators, the key takeaway is simple: Do not wait for NERC or your Regional Entity to contact you before preparing for registration.
NERC and the Regional Entities are preparing to identify Computational Load Sites through their interconnected Transmission Owners and Distribution Providers. Once these facilities are identified, direct outreach to Computational Load Owners and Operators is expected to follow, with registration activities anticipated to begin in early 2027.
Organizations that start identifying their facilities, clarifying ownership and operating responsibilities, and gathering the necessary information now will be in a much better position to navigate the upcoming registration process and prepare for their new NERC compliance obligations.
The time to prepare is now.
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