US FERC Form 556 Qualifying Facility Self-Certification Guide (August 2026)

Key Takeaways

• Facilities with a net power production capacity of 1 MW or less are exempt from FERC Form No. 556 filing (August 2026).
• The Federal Energy Regulatory Commission (FERC) has 90 days to review applications for Commission certification (August 2026).
• Protests to self-certifications must be filed within 30 days of the filing date (August 2026).
• Electric utilities are not required to purchase power from facilities 500 kW or more until 90 days after notification (August 2026).

Understanding FERC Form No. 556 for Qualifying Facility Status

The Federal Energy Regulatory Commission (FERC) establishes procedures for small power production facilities to obtain Qualifying Facility (QF) status. These regulations, found under 18 CFR § 292.203 and § 292.207, outline how facilities self-certify or apply for Commission certification. Obtaining QF status is often a prerequisite for securing power purchase agreements with utilities under the Public Utility Regulatory Policies Act of 1978 (PURPA).

Filing Requirements and the 1 MW Exemption

Most facilities seeking QF status must file a notice of self-certification with the Commission. However, a significant exemption exists: any facility with a net power production capacity of 1 MW or less is exempt from these filing requirements (August 2026). This means smaller solar installations may automatically qualify without needing to submit FERC Form No. 556.

Facilities exceeding 1 MW must submit FERC Form No. 556 electronically. This filing is typically required before a facility begins operations. Interconnecting utilities often require proof of FERC Form No. 556 filing or exemption status to execute PURPA power purchase agreements.

Self-Certification vs. Commission Certification

Owners or operators can choose between two paths to QF status:

1. Self-certification: This involves filing a notice of self-certification with FERC.
2. Commission certification: An owner or operator may file an application for Commission certification. This application must include a properly completed FERC Form No. 556, as specified in § 131.80 of this chapter.

The Commission has a specific timeline for reviewing certification applications. Within 90 days of the later of the filing date or any supplement, amendment, or change to the application, the Commission will either inform you of deficiencies, issue an order granting or denying the application, or toll the time for issuance of an order (August 2026). If the Commission does not act within 90 days of the latest filing, the application is deemed granted (August 2026).

Protest and Response Windows

The FERC process includes specific windows for protests and responses. Any protest to a self-certification or self-recertification must be filed within 30 days from the date the self-certification or self-recertification is filed (August 2026). Similarly, any response to a protest must be filed within 30 days from the date that protest was filed (August 2026).

Utility Notice Obligations

When filing a self-certification, self-recertification, or an application for Commission certification, you must concurrently serve a copy of the filing on each electric utility with which you expect to interconnect.

For larger facilities, an electric utility is not required to purchase electric energy from a facility with a net power production capacity of 500 kW or more until 90 days after the facility notifies the utility that it is a qualifying facility (August 2026).

Revocation of Qualifying Status

FERC can revoke a facility's QF status under certain conditions. If a QF fails to conform with any material facts or representations presented in its submittals to the Commission, the notice of self-certification or Commission order may no longer be relied upon. The Commission may also, on its own motion or the motion of any person, revoke the qualifying status of a self-certified or self-recertified QF if it finds that the facility does not meet the applicable requirements for qualifying facilities.