On 26 August 2026, President Trump signed Executive Order 14420, declaring a national emergency to secure the United States bulk-power system from foreign threats.
The order invokes the International Emergency Economic Powers Act, the National Emergencies Act, and section 301 of title 3 of the United States Code as its legal foundation.
It declares that foreign supply of bulk-power system electric equipment presents an unusual and extraordinary threat to U.S. national security, foreign policy, and the economy.
EO 14420 broadly prohibits certain foreign-produced bulk-power system electric equipment, including associated critical software and digital capabilities that could pose cybersecurity or operational risks, from being purchased or installed in the United States.
The order defines the bulk-power system to include facilities and control systems necessary for operating interconnected electric energy transmission networks, covering transmission lines rated at 69 kilovolts or more.
Growth in advanced manufacturing, data centres, artificial intelligence, and defence production has increased reliance on reliable electricity and enhanced the potential consequences of a supply chain disruption or attack.
The order specifically calls out two vulnerabilities: digital backdoors permitting remote access by foreign actors and concentrated foreign sourcing that could leave the U.S. market without essential equipment during trade disruptions.
EO 14420 is deliberately broader than its predecessor, Executive Order 13920, which President Trump first issued in May 2020 and which addressed the same core national security risk.
One major difference involves the range of foreign actors targeted, with EO 14420 replacing the term “foreign adversary” with the wider concept of “Covered Foreign Entity.”
Covered Foreign Entities include any country or person owned by, controlled by, or subject to the jurisdiction of a government subject to a U.S. arms embargo or sanctions regime under 22 C.F.R. § 126.1.
Countries captured by this definition include China, Russia, Iraq, Iran, and North Korea, among others updated periodically through Federal Register publications.
The equipment scope under EO 14420 is also significantly expanded, expressly adding utility-scale and grid-connected inverters, battery energy storage systems, and uninterruptible power supply systems supporting critical infrastructure.
Associated software, firmware, remote access capabilities, lifecycle maintenance mechanisms, and other supply chain dependencies may also be considered when determining whether equipment falls within the order’s scope.
Perhaps most consequentially, EO 14420 extends its reach to equipment already acquired or installed before 26 August 2026, giving the Secretary of Energy authority to impose conditions on its continued use or operation.
Those conditions could include requirements to identify, isolate, monitor, secure, disconnect, replace, or remove equipment, though the Secretary must consider effects on reliability, safety, and continuity of essential service before directing removal.
The Secretary of Energy is directed to publish implementing rules or regulations within 120 days of the order’s signing, setting a deadline of 24 December 2026, in consultation with senior executive branch officials.
Within 180 days, by 22 February 2027, the Secretary must also develop recommended revisions to the Federal Acquisition Regulation to prioritise U.S.-manufactured energy infrastructure in federal procurement.
Utilities previously identified as Responsible Utilities under the December 2020 Prohibition Order should now conduct thorough manufacturer and country-of-origin analyses of all installed equipment, with close attention to inverters and storage systems.
Because the order’s reach extends to hardware, software, firmware, remote access capabilities, and maintenance services, existing vendor service agreements must be reviewed alongside purchase and supply contracts.
Utilities, project developers, equipment suppliers, and federal contractors should closely monitor the 120-day rulemaking process and prepare for significant changes to procurement and compliance obligations.