ERCOT reports broad compliance under Lone Star act but flags attestation gaps; PUC, AG outline enforcement limits

Austin — ERCOT told the Senate Business & Commerce Committee on the first day of an interim hearing that it has implemented attestation and verification procedures required by the Lone Star Infrastructure Protection Act and has moved against market participants that failed to comply.

Chad Seeley, senior vice president for regulatory policy and general counsel at ERCOT, said the market operator has collected two types of attestations — corporate-affiliate disclosures and five-year grid-equipment look-backs — from market participants and used requests for information and periodic sampling to verify submissions. Of roughly 2,194 attestations received through February 2026, Seeley said 113 participants reported affiliate ties to designated countries but “all of them but one indicated that there was no direct control or access to the power grid.”

“Through those two attestation processes we get necessary information before executing agreements,” Seeley said. He added that ERCOT has terminated participants who failed to respond and can revoke digital certificates or instruct operators to isolate a resource if it poses an immediate reliability or security risk.

The Public Utility Commission’s executive director, Connie Corona, told the committee that the PUC can investigate violations and—under current statute—impose civil penalties of up to $1,000,000 per violation per day. She said the PUC’s enforcement division resolved roughly 99% of recent investigations initiated for late or missing attestations by securing the required filings or seeing entities leave the market.

An official from the attorney general’s office, Will Wozdorf, said the AG can audit attestations and accept referrals from ERCOT but that the Lone Star statute “does not actually give any additional investigatory authority” to the AG. “The act as currently drafted does not provide any direct cause of action,” he said.

Committee members pressed witnesses over the reliability of self-reported attestations and the practical limits of third‑party checks. Seeley said ERCOT uses outside tools (including Dun & Bradstreet and commercial supply‑chain services) and performs weekly and monthly sampling, but acknowledged gaps remain and recommended further protocol refinements and enhanced statutory language to require more detailed disclosures.

What’s next: ERCOT said it will expand its RFI process, refine the attestation form to require country‑specific disclosure, and continue stakeholder work. PUC staff urged the Legislature to consider explicit authorities to enable inspections and formal partnerships with national laboratories for technical verification.

Quoted: “We have the authority now to cut that access off” when a genuine threat is found, Seeley said. Corona added that the commission has used removals rather than million‑dollar fines in recent cases.

The committee asked agencies to return with more granular metrics and documentation of enforcement actions and to outline legislative language that would strengthen verification without unduly disrupting market activity.