FERC’s Office of Enforcement and Regulatory Accounting (Enforcement) has released its annual report on enforcement actions during fiscal year 2025, which ran from October 1, 2024 to September 30, 2025. The report provides a comprehensive overview of Enforcement’s activities across the electric, natural gas, and oil pipeline industries.
Enforcement remains focused on matters involving (1) fraud and market manipulation, (2) serious violations of Reliability Standards, (3) anticompetitive conduct, (4) threats to energy infrastructure, and (5) conduct that threatens the transparency of FERC-regulated markets.
Division of Investigations
The Division of Investigations (DOI) conducts investigations into potential violations of the statutes, regulations, rules, orders, tariffs, certificates, and licenses administered by FERC. Of the 24 new investigations opened by DOI staff in FY 25, 11 involved potential market manipulation, 17 involved potential tariff violations, and six involved potential misrepresentations.
Other investigations involved potential North American Electric Reliability Corporation (NERC) Reliability Standard violations and potential violations of the Commission’s Market Behavior Rule on Unit Operation. DOI resolved 11 investigations through settlement, which resulted in $22.84 million in civil penalties and $13.73 million in disgorgement. Since 2007, Enforcement has negotiated settlements totaling $899.8 million in civil penalties and approximately $664.17 million in disgorgement.
DOI closed 17 investigations with no action, all of which stemmed from referrals from a market monitor. The majority of those investigations reviewed whether companies violated an ISO/RTO tariff, the Commission’s Anti-Manipulation Rule, or the Commission’s Market-Behavior Rules.
Self-Reports
Enforcement stated that it continues to encourage the submission of self-reports and views them as a reflection of a company’s commitment to compliance. In FY 25, Enforcement received 153 new self-reports from a variety of market participants, including public utilities, natural gas companies, generators, and ISOs/RTOs. It closed 163 self-reports in FY 25, 31 of which were carried over from previous fiscal years, and 21 remained pending as of the end of FY 25.
While many of the self-reports closed in FY 25 involved tariff violations, the report’s illustrative examples of self-reports that were closed with no action shows that Enforcement also received self-reports involving violations of the standards of conduct, the capacity release rules, and the Interstate Commerce Act as well as failures to timely submit regulatory filings.
Enforcement Hotline
DOI staff fielded 304 calls and inquiries through its Enforcement Hotline. The Enforcement Hotline is available for people to inform Enforcement staff of potential violations of statutes, FERC rules, orders, regulations, and tariff provisions. 297 of the calls and inquiries received in FY 25 were promptly resolved, either after Enforcement staff provided advice, the caller stopped communicating with Enforcement, or because the matter was already pending before the Commission, which precludes Enforcement staff from discussing it due to ex parte rules. FERC also noted a significant portion of calls to the hotline were about matters outside of the Commission’s jurisdiction.
Joint Reliability Review
Enforcement, with staff from the Office of Electric Reliability, Office of General Counsel, NERC, and regional entities, conducted a joint review of the performance of the natural gas and electric industries during extreme cold weather events accompanying Winter Storms Blair, Cora, Demi, and Enzo in January 2025.
Enforcement staff observed in the report that the electric and natural gas industries responded better to cold weather events than they had in previous extreme cold weather events, but work remains to improve communication between the industries during extreme cold weather events.
Division of Audits and Accounting
The Division of Audits and Accounting (DAA) uses risk-based criteria to identify companies in FERC-regulated industries to audit for compliance with Commission rules and regulations. Companies selected for audit are not necessarily suspected of wrongdoing, but rather just meet the aforementioned criteria.
In FY 25, DAA completed 10 audits of public utility, natural gas, and oil companies. These audits resulted in 63 findings of noncompliance and 260 recommendations for corrective action. In the process, the audits secured approximately $80 million in refunds and other recoveries.
The audits undertaken in FY 25 showcase Enforcement’s concerns about noncompliance with tariffs and conduct that undermines the proper function of wholesale markets. Audits assessed a range of subjects:
- Compliance with Commission-approved fuel-adjustment clauses and formula rate or tariff recovery mechanisms used to recover fuel and purchased-power costs from wholesale customers through billing determinants
- Adherence to the approved terms, rates, and conditions of a transmission formula rate and a wholesale distribution formula rate
- Compliance with conditions established in FERC orders authorizing the acquisition of jurisdiction assets, accounting regulations, and financial reporting regulations associated with acquisitions
- Compliance with ISO/RTO tariffs and the submission of generation outage tickets and operational status to various reporting systems
- Compliance with FERC gas tariff, reporting requirements of FERC Form No. 2, and accounting requirements
- Compliance with FERC oil tariffs, the reporting requirements of FERC Form No. 6, and accounting requirements
In addition to these audits, DAA participated in 447 proceedings at the Commission covering various accounting matters, including electric, oil, and gas rate proceedings, pipeline certificate proceedings, and mergers of public utilities under Section 203 of the Federal Power Act.
Division of Analytics and Surveillance
The Division of Analytics and Surveillance (DAS) actively evaluates FERC-regulated markets to detect potential manipulation, anticompetitive behavior, and other anomalous activities. It implements surveillance tools and algorithmic screens to continuously monitor and analyze market participant behavior, economic incentives, operations, and price formation in both the natural gas and electric markets.
One of DAS’s primary tools to detect potential market manipulation and anti-competitive behavior are screens that evaluate potential suspicious activities in jurisdictional markets. In FY 25, natural gas surveillance screens produced 1,780 surveillance reviews, which resulted in 24 natural gas surveillance inquiries being opened and one referral to DOI for investigation. Electric surveillance screens produced 1,920 surveillance reviews, which resulted in 36 electric surveillance inquiries and 10 referrals to DOI for investigation.
Expectations for the Future
Enforcement continued using its investigative power and extensive technical expertise to vigorously enforce its rules and regulations. We expect that Enforcement will continue to initiate and pursue investigations across all industries and aggressively pursue enforcement matters in Fiscal Year 2026. We also expect that market monitor referrals will continue to be a solid source of new investigations.
Consistent with prior annual reports, the FY 25 Annual Enforcement Report emphasizes the importance of companies establishing and maintaining effective compliance programs that foster a culture of compliance that begins at the executive level and permeates throughout the organization.
Effective compliance programs should be tailored to a company’s specific size, region, organizational structure, operations, and business activities. Companies should be proactive and ensure that their staff and management receive adequate and appropriate training and resources that enable them to detect potential issues in a timely manner and remain apprised of the latest compliance trends and issues.
While an effective compliance program will often prevent noncompliance with FERC rules, regulations, and orders, the compliance program should also be capable of and equipped to timely and effectively correct any noncompliance.