Nepra fines the National Grid Company and CPPA Rs25m each for weak blackout recovery planning, missing procedures with power plants and risking Pakistan’s grid security.
Regulator Penalises Lapses in Grid Safety and Recovery Planning
The National Electric Power Regulatory Authority (Nepra) has imposed fines of Rs25 million each on the National Grid Company and the Central Power Purchasing Agency (CPPA) for repeatedly failing to meet key safety and legal requirements. These requirements are designed to protect Pakistan’s power system and ensure that electricity can be restored quickly after a major breakdown.
In separate but similar orders, Nepra found that both entities had violated Section 48 of the NEPRA Act by not completing mandatory operating procedures with dozens of power plants and by failing to put in place robust plans for restarting the grid after a system failure. The fines must be paid within 15 days, and the regulator has warned that if they are not settled within this period, the amounts will be recovered as land revenue.
Missing Operating Procedures with Power Plants
Nepra’s investigation revealed that more than one-third of the required operating procedures with power plants remain unsigned, even though deadlines were set several years ago. These procedures, often referred to as standard operating procedures or SOPs, cover critical issues such as coordination during normal operations, emergency responses and blackout conditions.
Both the National Grid Company and CPPA attempted to shift responsibility onto power producers, arguing that delays were due to disagreements with generation companies. However, Nepra rejected this defence, pointing out that power purchase agreements already include dispute-resolution mechanisms. According to the regulator, the existence of unresolved disputes does not excuse the failure to meet legal obligations that are central to keeping the grid stable.
By leaving a significant portion of these procedures incomplete, the two entities increased the risk that operators and power plants would not have clear instructions during emergencies. Nepra noted that such gaps in documentation and planning can lead to confusion at exactly the moment when coordination needs to be at its strongest.
Weak ‘Black Start’ Framework Blamed for Delayed Restorations
A major focus of Nepra’s orders is the so-called “black start” framework, the system used to restart the grid after a nationwide or large-scale blackout. In a black start scenario, selected power plants must be able to start without relying on the external grid and then gradually energise transmission lines and other plants in a carefully sequenced process.
Nepra linked weaknesses in this framework to delays in restoring power during major outages in 2021, 2022 and 2023. The regulator found that several power plants failed to synchronise with the grid on time because they lacked clear, blackout-specific procedures or because those procedures had never been finalised. As a result, the system remained down longer than necessary, affecting millions of consumers and damaging public trust in the power sector.
The authority also criticised the fact that mandatory black start tests were only carried out after legal proceedings had already begun. Nepra described this behaviour as evasive and unacceptable, arguing that tests needed to be routine and proactive, not reactive steps taken under regulatory pressure.
No Extra Payments for Black Start Services
In its orders, Nepra clarified that black start services are already covered under existing power purchase contracts and do not entitle companies to additional payments. The regulator stressed that reliable black start capability is a core requirement of grid operations, not an optional service that can be monetised separately after the fact.
By underlining this point, Nepra aimed to close the door on any arguments that financial incentives were needed before companies could be expected to comply. Instead, the authority said that both the National Grid Company and CPPA have a legal and contractual duty to ensure that the system can be restarted quickly and safely following a failure.
Signal of Tougher Oversight on Grid Security
The fines send a clear signal that Nepra is prepared to use its enforcement powers more aggressively when core system security obligations are ignored. Pakistan has faced several large-scale blackouts in recent years, with investigations often tracing the causes back to weak planning, poor coordination and delayed investment in critical grid infrastructure.
By penalising both the National Grid Company and CPPA and publicly documenting their failures, the regulator is putting the wider power sector on notice. Market participants are being reminded that ensuring a resilient grid is not just a technical challenge but a legal responsibility. How quickly the two entities move to address the gaps identified by Nepra will be seen as an important test of the sector’s commitment to reliability and consumer protection.

