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FERC Issues NOPR Proposing Revisions to Annual and Quarterly Financial Forms

By Ben Duwve & Sahara Shrestha on July 1, 2026
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On June 18, 2026, FERC issued a Notice of Proposed Rulemaking (NOPR) seeking industry comments on proposed revisions to various FERC annual and quarterly financial reporting forms. The NOPR proposes revisions to FERC Form Nos. 1 (Annual Report of Major Electric Utilities, Licensees, and Others), 1-F (Annual Report for Nonmajor Public Utilities and Licensees), 2 (Annual Report for Major Natural Gas Companies), 2-A (Annual Report for Non-Major Natural Gas Companies), 3-Q (electric) (Quarterly Financial Report of Electric Utilities and Licensees), 3-Q (gas) (Quarterly Financial Report of Natural Gas Companies), 6 (Annual Report of Oil Pipeline Companies), 6-Q (Quarterly Report of Oil Pipeline Companies), and 60 (Annual Report of Centralized Service Companies) (collectively, Financial Forms). In the NOPR, FERC seeks to update general filing instructions, delete various schedules in FERC Form Nos. 3-Q and 6-Q, and exempt oil pipelines with annual jurisdictional operating revenues below $500,000 from filing FERC Form No. 6-Q.

As background, FERC requires jurisdictional public utilities, licensees, centralized service companies, and natural gas and oil pipeline companies to submit a variety of annual and quarterly reports based on an entity’s industry affiliation. FERC explains that the information collected in the Financial Forms assists FERC in the administration of its jurisdictional responsibilities and is used by FERC staff, state regulatory agencies, customers, investors, financial analysts, and others in the review of the financial condition of regulated companies. FERC further explains that the information filed in the Financial Forms represents, in most cases, the only source of financial data presented in a format and detail suitable for FERC to exercise its duties and responsibilities under the Federal Power Act, Natural Gas Act, Interstate Commerce Act, and Public Utility Holding Company Act of 2005.

The NOPR’s proposed revisions fall into several categories:
• FERC proposes to remove outdated regulatory provisions containing obsolete deadlines across Parts 141, 260, 357, and 369 of its regulations, and to make minor conforming and punctuation corrections.
• FERC proposes to revise and standardize the general filing instructions across the Financial Forms, including by removing the requirement for jurisdictional entities to file their Annual Reports to Stockholders, explaining that these reports are publicly available and that eliminating the requirement will reduce unnecessary reporting burden.
• FERC proposes to revise certain schedule instructions across the Financial Forms to address discrepancies identified through the transition to eXtensible Business Reporting Language (XBRL), FERC’s electronic filing system for the Financial Forms, in order to better reflect the intent of the reporting requirements.
• FERC proposes to delete certain schedules from the Quarterly Financial Forms. Specifically, deleting 17 of 24 schedules from FERC Form No. 3-Q (electric), 3 of 19 schedules from FERC Form No. 3-Q (gas), and 3 of 11 schedules from FERC Form No. 6-Q, which FERC explains will result in an estimated 70%, 15%, and 27% reduction in reporting burden, respectively.
• FERC proposes to revise the instructions for Certified Public Accountant (CPA) Certification Statements filed with FERC Form Nos. 1 and 1-F to remove the prescriptive pro forma language requirement and to require submission through FERC’s eForms portal, rather than by eFiling or mail.
• FERC proposes to clarify that only oil pipeline companies with annual jurisdictional operating revenues of $500,000 or more are required to file FERC Form No. 6-Q, thereby exempting smaller oil pipeline companies from the quarterly reporting requirement.

Initial Comments on the NOPR are due July 24, 2026. Reply Comments are due on September 22, 2026. The NOPR, issued in Docket No. RM26-12-000, is available here.

Photo of Ben Duwve Ben Duwve

Ben is an associate in the firm’s Energy practice. He received his J.D. from the George Washington University Law School, where he served as senior production editor of The Federal Communications Journal.

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Photo of Sahara Shrestha Sahara Shrestha

Sahara represents clients in the hydropower, natural gas, and electric utility sector before the Federal Energy Regulatory Commission (FERC) and the D.C. Circuit. She advises hydropower clients on all aspects of FERC licensing and compliance under the Federal Power Act, as well as…

Sahara represents clients in the hydropower, natural gas, and electric utility sector before the Federal Energy Regulatory Commission (FERC) and the D.C. Circuit. She advises hydropower clients on all aspects of FERC licensing and compliance under the Federal Power Act, as well as issues arising under other federal statutes, including the Clean Water Act, National Environmental Policy Act, National Historic Preservation Act, and Endangered Species Act. Sahara also advises natural gas clients in certificate proceedings and compliance matters, and advises electric utility clients on transmission, interconnection, and market design issues.

Read more about Sahara ShresthaEmail
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  • Posted in:
    Administrative and Regulatory, Energy and Utilities
  • Blog:
    Washington Energy Report
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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