ORBIS Compliance

United States DOE Opens Implementation Consultation on Bulk-Power-System Equipment and Supply-Chain Security

Published /Effective /United States of America

On September 9, 2026, the U.S. Department of Energy published a Request for Information in Docket DOE-HQ-2026-1123 to inform implementation of Executive Order 14421 on securing the U.S. bulk-power system.

DOE requests evidence on the scope of covered equipment and transactions, Covered Foreign Entities, foreign-produced equipment, supply-chain practices, software and firmware provenance, digital and maintenance services, remote access, existing equipment and mitigation, licensing and vendor prequalification, domestic manufacturing, secure replacement capacity, Federal procurement and economic, reliability, safety and small-entity effects.

Technical questions address country-of-manufacture evidence, hardware and software bills of materials, code signing, secure updates, multifactor authentication, least privilege, logging, vulnerability history, testing, certification and audit evidence. Responses are due October 9, 2026, and DOE will hold a webinar on September 16.

The RFI is voluntary and does not itself propose or adopt a rule, prohibition, license requirement or compliance standard.

Impact

Impact assessment: Medium.

Key reasons: the RFI will shape DOE's implementation of an Executive Order that authorizes review, restriction and mitigation of certain bulk-power-system equipment transactions, including equipment, components, software, services and remote-access capabilities linked to Covered Foreign Entities.

Who is affected?

Utilities, owners and operators, equipment manufacturers, software and service providers, foreign suppliers, cybersecurity teams, procurement functions and Federal contractors.

Conclusion:

no new obligation applies through the RFI itself, but stakeholders should evaluate the detailed questions and consider submitting evidence by October 9, 2026.

Regulatory Authority

Office of Cybersecurity, Energy Security, and Emergency Response, U.S. Department of Energy (DOE)

Regulatory Impact

Impact TypeStatus
Top Priority
Type Certificate
Spectrum Bands
Import Changes (HS Codes)
Standard Changes
Product Changes
Label Changes

United States of America Quick Facts

Regulatory AgencyFederal Communications Commission (FCC)
Certification TypeMandatory for most telecom equipment
License ValidityValid indefinitely as long as compliance is maintained
Application LanguageEnglish
Legal License HolderLocal representative may be required for some cases
In-country Testing RequirementMay be required for certain telecom equipment

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