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Grid Supply Chain Assurance: What EO 14421 Requires of Utilities

Executive Order 14421 prohibits foreign-made equipment that poses a national security risk to the U.S. bulk-power system — and pushes provenance requirements down to 69 kV, below the NERC BES threshold. This brief breaks down what the order covers, why CIP-013 and CIP-010 attestations don't close the gap, and how firmware analysis builds the provenance record DOE's December rules will ask for.

September 15, 2026
Finite State Team

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