What Is the FERC XBRL Mandate?

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Wednesday, September 30. 2020

What Is the FERC XBRL Mandate?

In 2019, the Federal Energy Regulatory Commission (FERC) revised its electronic filing format to incorporate structured data in the eXtensible Business Reporting Language (XBRL) format. As has been the case with other federal regulators, the move to adopt XBRL is being undertaken to modernize the reporting environment and increase efficiency in submitting and consuming data. Broad support across the industry also helped drive the action.

FERC’s XBRL requirement will require filers to submit to quarterly and annual reports of public utilities, electric utilities, natural gas companies, oil pipeline companies, and centralized service companies in XBRL. To that end, FERC, in conjunction with XBRL US, has developed a new reporting taxonomy specifically designed to encompass the information required in energy reporting. This draft taxonomy has been available for public review and after a recent conference has now been finalized.

What’s in the FERC Taxonomy?

The taxonomy can be viewed in Yeti here. For filers familiar with the US GAAP or IFRS taxonomies, you may notice that the FERC taxonomy is organized by form rather than by financial presentations related to particular topics. Thus far, the forms included are:

Form 1

Form 1
Form 1F
Form 3-Q Electric

Form 2

Form 2
Form 2A
Form 3-Q Gas

Form 6

Form 6
Form 6Q

Form 60
Form 714

The FERC Taxonomy features elements related to the sections and fields of these forms. These elements will be used to “tag” the data you supply as part of your filing, allowing the data to become “machine-readable”. XBRL permits software applications to extract data for analysis and comparison very quickly and with little human overhead and oversight. This allows for much faster data analysis, as well as easier and more robust verification of the data’s accuracy and completeness.

How Does the Mandate Change Filing Requirements?

The informational requirements for FERC forms remain unchanged. However, using the FERC taxonomy, filers will now need to tag their data in XBRL before submitting their forms to FERC. This is similar to what registrants must do with SEC financial filings, only, again, the FERC taxonomy is structured around the forms, rather than financial presentations.

FERC reporting will be completed through a new eForms portal that will continue to write filings into FERC’s eLibrary.

What’s the Cost to Me as a Filer?

As with other transitions to a new filing format and technology, there will be some burden to the filer. FERC estimates the following out-of-pocket expenses for filers:

Forms Nos. 1, 1-F, 3-Q electric, 2, 2-A, 3-Q natural gas, 6, and 6-Q: $4,912 per filing
Form No. 60: $982 per filing
Form No. 714: $737 per filing

These expenses may involve purchasing XBRL software and/or the services of a filing agent. FERC also estimates an additional yearly burden of 33.4 internal work hours.

When Does the XBRL Mandate Go Into Effect?

FERC adopted the XBRL mandate in 2019. On July 17, 2020, the taxonomy became finalized. The followingis a general guideline for compliance, beginning with the quarterly forms for the third quarter of 2021:

Date:	Form/Filers:
November 29, 2021	FERC Form No. 3-Q (electric) for Major Electric Utilities, Licensees, and Others FERC Form No. 3-Q (natural gas) for Major Natural Gas Companies
December 9, 2021	FERC Form No. 3-Q (electric) for Non-major Public Utilities and Licensees FERC Form No. 3-Q (natural gas) for Non-major Natural Gas Companies FERC Form No. 6-Q for Oil Pipeline Companies
April 18, 2022	2021 FERC Form Nos. 1 and 1-F 2021 FERC Form Nos. 2 and 2-A 2021 FERC Form No. 6
May 1, 2022	2021 FERC Form No. 60*
June 1, 2022	2021 FERC Form No. 714

* Note that because May 1, 2022 falls on a weekend, filers will be allowed to submit their filings by May 2, 2022.

What’s Next?

FERC encourages users to explore the taxonomy in Yeti or through the sample files located on FERC’s website to familiarize themselves with the taxonomy’s structure.

A Solution for FERC XBRL

In addition to continuing to provide quality and timely software solutions for SEC filers, Novaworks will support the FERC Taxonomy and the FERC XBRL filing process in an upcoming separate product line. These XBRL products are projected to be priced within FERC’s estimates of filing burden and will provide a streamlined, easy-to-use online interface to create FERC XBRL filings. Please check back here at the Novaworks web blog for more information in the coming months!