ATLANTIC CITY ELECTRIC CO

2. Regulatory Matters (All Registrants)

As discussed in Note 2 — Regulatory Matters of the 2025 Form 10-K, the Registrants are involved in rate and regulatory proceedings at FERC and their state commissions. The following discusses developments in 2026 and updates to the 2025 Form 10-K.

Distribution Base Rate Case Proceedings

The following tables show the completed and pending distribution base rate case proceedings in 2026.

Completed Distribution Base Rate Case Proceedings

Pending Distribution Base Rate Case Proceedings

(a)On April 14, 2026, Pepco notified the MDPSC of pursuing a traditional base rate case.

(b)DPL can implement interim rates on July 9, 2026, subject to refund.

ComEd Distribution Base Rate Case Proceedings

The ICC approved ComEd's four-year MRP for the period January 1, 2024 through December 31, 2027. The MRP was originally approved by the ICC on December 14, 2023 and was subsequently amended on January 10, 2024, April 18, 2024 and December 19, 2024. The December 19, 2024 order provided a total revenue requirement increase of $1.045 billion inclusive of rate increases of approximately $752 million in 2024, $80 million in 2025, $102 million in 2026, and $111 million in 2027.

On May 1, 2026, ComEd filed its 2025 MRP Reconciliation reflecting a revenue increase of $234 million, which includes the tax benefit of NOLCs. While NOLCs were included in the MRP Reconciliation, the impacts of the NOLCs will not be reflected in the financial statements until the PLR is received from the IRS. See Note 6 — Income Taxes for additional information on NOLCs.

On March 20, 2026, ComEd filed its annual revenue balancing reconciliation for 2025. This reconciliation, which is a component of revenue decoupling, reflected a revenue reduction of $128 million. The reconciliation is effective January 1, 2027, subject to regulatory approval.

On December 18, 2025, the ICC approved ComEd's 2024 MRP Reconciliation reflecting a revenue increase of $243 million, including the tax benefit of NOLCs. While NOLCs are included in the MRP Reconciliation per the final order, the impacts of the NOLCs will not be reflected in the financial statements until the PLR is received from the IRS. See Note 6 — Income Taxes for additional information on NOLCs. On January 20, 2026, the Illinois Attorney General filed an Application for Rehearing of the December 18 order, which focuses solely on NOLCs. On February 5, 2026, the ICC denied the Illinois Attorney General's Application for Rehearing.

PECO Distribution Base Rate Case Proceedings

On December 12, 2024, the PAPUC issued their Opinions and Orders which approved the non-unanimous partial settlements with limited modifications for both the electric and natural gas base rate cases, and denied the Weather Normalization Adjustment requested in the natural gas base rate case.

PECO’s approved annual electric revenue requirement increase of $354 million is partially offset by a one-time credit of $64 million in 2025. In addition, the PAPUC approved the recovery of storm damage costs incurred by PECO in January 2024, up to $23 million, subject to review for reasonableness and prudency in PECO’s next distribution rate case.

BGE Distribution Base Rate Case Proceedings

In February 2023, BGE filed its three-year cumulative multi-year plan for January 1, 2024 through December 31, 2026 to the MDPSC, which was approved in December 2023 and went into effect on January 1, 2024. The MDSPC awarded BGE electric revenue requirement increases of $41 million, $113 million, and $25 million with an approved ROE of 9.50% in 2024, 2025, and 2026, respectively, and natural gas revenue requirement increases of $126 million, $62 million, and $41 million with an approved ROE of 9.45% in 2024, 2025, and 2026, respectively. The requested revenue requirement increases will be used to recover capital investments designed to increase the resilience of the electric and gas distribution systems and support Maryland's climate and regulatory initiatives.

The MDPSC also approved a portion of the requested 2021 and 2022 reconciliation amounts, which were recovered through separate electric and gas riders between March 2024 and February 2025. As such, the reconciliation amounts are not included in the approved revenue increases. The 2021 reconciliation amounts are $13 million and $7 million for electric and gas, respectively, and the 2022 reconciliation amounts are $39 million and $15 million for electric and gas, respectively. In April 2024, BGE filed with the MDPSC its request for recovery of the 2023 reconciliation amounts of $79 million and $73 million for electric and gas, respectively, with supporting testimony and schedules. In December 2025, the MDPSC authorized BGE to recover $31 million and $46 million for electric and gas, respectively, beginning in February 2026 and extending through December 2027, in the reconciliation rider. In addition to the amounts approved in the reconciliation rider, the MDPSC provided for additional regulatory assets related to minor storms of $24 million (to be recovered over 5 years) and the Baltimore City conduit of $4 million (to be reviewed along with a cost-benefit analysis in BGE’s next rate case).

Pepco District of Columbia Distribution Base Rate Case Proceedings

On April 13, 2023, Pepco filed an electric base rate case with the DCPSC (amended February 27, 2024) requesting a total revenue requirement increase of $186 million and an ROE of 10.50%. The DCPSC issued an order approving the two-year cumulative multi-year plan on November 26, 2024, which included a total revenue requirement increase of $123 million with an ROE of 9.50% effective January 1, 2025 through December 31, 2026. The DCPSC awarded Pepco electric incremental revenue requirement increases of $99 million and $24 million for 2025 and 2026, respectively. Subsequent to DCPSC approval of the order, interveners appealed the order on several grounds including that the DCPSC did not hold evidentiary hearings. On March 5, 2026, the District of Columbia Court of Appeals remanded the November 26, 2024, order back to the DCPSC to hold evidentiary hearings. On March 27, 2026, the DCPSC issued an order adopting a procedural schedule and requested supplemental briefing on what interim rates should be in effect during the remand period but did not order any refunds for previous amounts collected. Pepco is preparing for the proceeding and will continue to monitor developments.

Pepco Maryland Distribution Base Rate Case Proceedings

On May 16, 2023, Pepco filed an electric base rate case with the MDPSC (amended February 23, 2024) requesting a total revenue requirement increase of $111 million (before offsets) and an ROE of 10.50%. The MDPSC issued an order on June 10, 2024 awarding Pepco a one-year multi-year plan for April 1, 2024 through March 31, 2025 which included an incremental revenue requirement increase of $45 million and an ROE of 9.50%. The MDPSC did not adopt the requested revenue requirement increases of $80 million (before offsets), $51 million, and $14 million as filed for 2025, 2026, and the 2027 nine-month extension period, respectively. The MDPSC also approved the requested reconciliation amounts for the 12-month periods ending March 31, 2022, and March 31, 2023, which will be recovered through a rider between August 2024 through March 2026. As such, the reconciliation amounts are not included in the approved revenue requirement increases. The reconciliation amounts are $1 million and $7 million, for the 12-month periods ending March 31, 2022, and March 31, 2023, respectively. In July 2024, Pepco filed its request with the MDPSC, for recovery of the reconciliation amounts of $31 million for the 12-month period ended March 31, 2024, with supporting testimony and schedules. On March 31, 2026, the MDPSC issued an order authorizing Pepco to recover approximately $13 million through the reconciliation rider. This will be recovered through rates between May 2026 through April 2027. Additionally, the order disallowed the recovery of various assets. The order resulted in the write off of $11 million of Regulatory assets and $15 million of Property, plant and equipment with a total of $26 million recorded in Operations and maintenance expense.

DPL Maryland Distribution Base Rate Case Proceedings

On May 19, 2022, DPL filed an electric base rate case with the MDPSC requesting a total revenue requirement increase of $38 million based on an ROE of 10.25%. On December 14, 2022, the MDPSC issued an order awarding DPL a total revenue requirement increase of $29 million with an ROE of 9.60%. The order reflects a three-year cumulative multi-year plan for January 1, 2023 through December 31, 2025, with rates remaining in effect subsequent to the multi-year plan period. The MDPSC awarded DPL electric incremental revenue requirement increases of $17 million, $6 million, and $6 million for 2023, 2024, and 2025, respectively.

DPL Delaware Distribution Base Rate Case Proceedings

On December 15, 2022, DPL filed an electric base rate case with the DEPSC (amended September 29, 2023) requesting a total revenue requirement increase of $39 million and an ROE of 10.50%. On April 18, 2024, the DEPSC issued an order awarding DPL a total revenue requirement increase of $28 million with an ROE of 9.60%, effective July 15, 2023. As part of the approved order, the DEPSC approved the Significant Storm Expense Rate Rider (Rider SSER) which will allow DPL to recover expenses associated with qualified storms. A qualified storm will be an individual storm for which DPL incurs expenses between $5 million and $15 million. The Rider SSER allows DPL to recover significant storm damage expenses for the previous 12-month period over a future 24-month period. For individual storm events for which DPL incurs expenses of more than $15 million, the future recovery period will be evaluated on a case-by-case basis and the unamortized balance will earn a return at DPL's authorized long-term cost of debt. The Rider SSER will have an annual true-up filing, subject to DEPSC review and approval.

ACE New Jersey Distribution Base Rate Case Proceedings

On November 21, 2024, ACE filed an electric base rate case with the NJBPU requesting a total revenue requirement increase of $109 million, before NJ sales and use tax, and an ROE of 10.70%. On November 21, 2025, the NJBPU issued an order awarding ACE an electric revenue requirement increase, before NJ sales and use tax, of $54 million effective December 1, 2025, with an ROE of 9.60%. In addition, the NJBPU approved the recovery through a regulatory asset of work stoppage costs that were incurred by ACE in 2023 of $38 million.

Other State Regulatory Matters

Illinois Regulatory Matters

CEJA (Exelon and ComEd). On September 15, 2021, the Governor of Illinois signed into law CEJA. CEJA includes, among other features, (1) procurement of CMCs from qualifying nuclear-powered generating facilities, (2) a requirement to file a general rate case or a new four-year MRP no later than January 20, 2023 to establish rates effective after ComEd’s existing performance-based distribution formula rate sunsets, (3) requirements that ComEd and the ICC initiate and conduct various regulatory proceedings on subjects including ethics, spending, grid investments, and performance metrics.

ComEd Electric Distribution Rates

Beginning in 2024, ComEd recovers from retail customers, subject to certain exceptions, the costs it incurs to provide electric delivery services either through its electric distribution rate or other recovery mechanisms authorized by CEJA. On January 17, 2023, ComEd filed a petition with the ICC seeking approval of a MRP for 2024-2027. The MRP supports a multi-year grid plan (2024-2027 Grid Plan), also filed on January 17, covering planned investments on the electric distribution system within ComEd’s service area through 2027. Costs incurred during each year of the MRP are subject to ICC review and the plan’s revenue requirement for each year will be reconciled with the actual costs that the ICC determines are prudently and reasonably incurred for that year. The reconciliation is subject to adjustment for certain costs, including a limitation on recovery of costs that are more than 105% of certain costs in the previously approved MRP revenue requirement, absent a modification of the rate plan itself. Thus, for example, the rate adjustments necessary to reconcile 2024 revenues to ComEd’s actual 2024 costs incurred would take effect in January 2026 after the ICC’s review during 2025.

On December 14, 2023, the ICC issued a final order. The ICC rejected ComEd’s 2024-2027 Grid Plan as non-compliant with certain requirements of CEJA and required ComEd to file a revised 2024-2027 Grid Plan. On January 10, 2024, ComEd filed an appeal in the Illinois Appellate Court of portions of the ICC's December 2023 order, including but not limited to the allowed ROE, 50%equity ratio, and denial of a return on ComEd’s pension asset. There is no deadline by when the appellate court must rule. On March 13, 2024, ComEd filed its Refiled 2024-2027 Grid Plan with supporting testimony and schedules with the ICC and subsequently on March 15, 2024, ComEd also filed a petition to adjust its MRP to authorize increased rates consistent with the Refiled 2024-2027 Grid Plan. On December 19, 2024, the ICC approved the Refiled 2024-2027 Grid Plan and adjusted the approved MRP with rates effective on January 1, 2025. The final approved MRP, as adjusted, which reflects the Refiled Grid Plan, resulted in a total cumulative revenue requirement increase of $1.045 billion over the 2024-2027 plan years and remains subject to annual reconciliations in accordance with CEJA. ComEd filed timely requests for rehearing and an appeal of the MRP order, again limited to the issues on which rehearing of the December 2023 order was denied, including the allowed ROE,50% equity ratio, and denial of a return on ComEd's pension asset.

On January 16, 2026, ComEd filed a multi-year integrated grid plan (2028-2031 Grid Plan), seeking approval for planned investments on the electric distribution system within ComEd's service area in 2028-2031. The ICC must issue an order by December 15, 2026.

Carbon Mitigation Credit

CEJA establishes decarbonization requirements for Illinois as well as programs to support the retention and development of emissions-free sources of electricity. ComEd is required to purchase CMCs from participating nuclear power generating facilities between June 1, 2022 and May 31, 2027. The price to be paid for each CMC was established through a competitive bidding process that included consumer-protection measures that capped the maximum acceptable bid amount and a formula that reduces CMC prices by an energy price index, the base residual auction capacity price in the ComEd zone of PJM, and the monetized value of any federal tax credit or other subsidy if applicable. On October 31, 2025, the seller provided notification to ComEd and the IPA that it has reflected on its 2024 federal tax return $804 million of nuclear production tax credits associated with its participating nuclear power generating facilities. These amounts will be collected from the seller through an adjustment to the CMC price to be paid by ComEd and returned to customers in 2026. As of December 31, 2025, Exelon and ComEd's Consolidated Balance Sheets reflected these amounts as a receivable from the seller with an offsetting balance within the Carbon mitigation credit regulatory liability. These adjustments had no net impact on Exelon and ComEd’s Consolidated Statements of Operations and Comprehensive Income. The seller has not provided notification to ComEd or the IPA that any subsidies or tax credits, such as nuclear production tax credits, have been monetized for 2025. The consumer protection measures contained in CEJA will result in net payments to ComEd ratepayers if the energy index, the capacity price and applicable federal tax credits or subsidy exceed the CMC contract price. Beginning with the June 2022 monthly billing period, ComEd began issuing credits and/or charges to its retail customers under its CMC rider, the Rider Carbon-Free Resource Adjustment (Rider CFRA). A regulatory asset or liability is recorded for the difference between ComEd's costs associated with the procurement of CMCs from participating nuclear power generating facilities and revenues received from customers. The balance of the liability as of March 31, 2026 is $434 million.

On February 2, 2024, ComEd filed a petition with the ICC to initiate the reconciliation proceeding for the costs incurred in connection with the procurement of CMC’s during the delivery year beginning June 1, 2022 and extending through May 31, 2023. While both Staff and the Administrative Law Judge's proposed order supported ComEd’s proposed reconciliation adjustment, on September 4, 2025, the ICC issued its final order rejecting the proposed reconciliation adjustment. Specifically, the order disallowed portions of the administrative costs as well as a portion of ComEd's interest costs on the balance of credit extended to customers under the applicable tariff that were not yet funded by payments from the generator. The CMC costs themselves were not disallowed. The order resulted in an immaterial impact to the financial statements and on October 3, 2025 ComEd filed its Application for Rehearing. On October 16, 2025, the ICC denied ComEd's Application. On October 17, 2025, ComEd filed its appeal with the Illinois Appellate Court for review of the ICC's order and its denial of rehearing.

Energy Efficiency

CEJA extends ComEd’s current cumulative annual energy efficiency MWh savings goals through 2040, adds expanded electrification measures to those goals, increases low-income commitments, and adds a new performance adjustment to the energy efficiency formula rate. ComEd expects its annual spend to increase through 2040 to achieve these energy efficiency MWh savings goals, which is deferred as a separate regulatory asset that is recovered through the energy efficiency formula rate over the weighted average useful life, as approved by the ICC, of the related energy efficiency measures.

In 2026, Illinois enacted the CRGA, which makes certain changes to the energy efficiency framework established under CEJA.

CRGA modifies the manner in which ComEd’s energy efficiency savings goals are calculated by establishing a flat incremental annual savings requirement that applies indefinitely. CRGA also increases energy efficiency budget and low‑income commitments from levels established under CEJA, expands the categories of savings that may be credited toward annual goals, and revises the return on equity applicable to the energy efficiency regulatory asset to align with the distribution return on equity.

Beginning in 2027, ComEd expects that implementation of CRGA may result in higher annual energy efficiency spending. Incremental costs incurred in advance of recovery are expected to be deferred as a regulatory asset and recovered through ComEd’s energy efficiency formula rate over the weighted‑average useful life of the related measures, subject to approval by the Illinois Commerce Commission.

The energy efficiency provisions of CRGA are effective June 1, 2026. In advance of the effective date, ComEd has begun undertaking implementation activities, including regulatory filings and planning efforts.

Maryland Regulatory Matters

Summer and Winter Rate Mitigation (Exelon, BGE, PHI, Pepco, and DPL). As part of the passing of the Next Generation Energy Act of 2025 by the Maryland General Assembly, the MDPSC issued an order on June 26, 2025, to implement the Legislative Energy Relief Refund program under which bill credits were distributed to residential customers based on their consumption of electricity supply that was subject to the renewable energy portfolio standard. On July 24, 2025, the MDPSC issued an order accepting BGE, Pepco, and DPL's proposal for the implementation of the program. As a result, BGE, Pepco, and DPL received $49 million, $21 million, and $8 million, respectively, from the MDPSC on February 3, 2026. These amounts were used to reduce residential customer account receivable balances within the first quarter of 2026.

Other Federal Regulatory Matters

PJM Cost Allocation Methodology (All Registrants). On March 6, 2026, FERC issued an order requiring the removal of the de minimis threshold exemption in the calculation of the cost responsibility of certain transmission reliability upgrade costs allocated to the rate zones of PJM transmission owners, including the Utility Registrants. FERC further ordered PJM to recalculate historical cost allocations for the period beginning June 18, 2015, and to pass through additional charges or payments to PJM customers, including Utility Registrants, as applicable, with interest within 90 days. On April 29, 2026, the time for those calculations was extended until further order from FERC. The Utility Registrants expect to recover any incremental charges incurred or reimburse any payments received through prospective electric customer rates. On April 6, 2026, a number of parties filed petitions for rehearing or clarification.

The final impacts of the decision cannot be predicted and the results, while not reasonably estimable at this time, could be material to the financial statements.

Regulatory Assets and Liabilities

The Utility Registrants' regulatory assets and liabilities have not changed materially since December 31, 2025, unless noted below. See Note 2 — Regulatory Matters of the 2025 Form 10-K for additional information on the specific regulatory assets andliabilities.

ComEd. Regulatory assets increased $155 million primarily due to an increase of $127 million in the Electric energy and natural gas costs regulatory asset.

PECO. Regulatory assets increased $132 million primarily due to an increase of $72 million in the Deferred income taxes regulatory asset. Regulatory liabilities increased $88 million primarily due to an increase of $91 million in the Decommissioning the Regulatory Agreement Units.

BGE. Regulatory assets decreased $102 million primarily due to a decrease of $45 million in the Electric energy and natural gas costs regulatory asset and a decrease of $42 million in the Energy efficiency and demand response programs regulatory asset. Regulatory liabilities decreased $16 million primarily due to a decrease of $31 million in the Deferred income taxes regulatory liability.

Pepco. Regulatory assets decreased $42 million primarily due to a decrease of $27 million in the Energy efficiency and demand response programs regulatory asset.

DPL. Regulatory assets remained consistent primarily due to a decrease of $15 million in the Energy efficiency and demand response programs regulatory asset, partially offset by an increase of $8 million in the Electric energy and natural gas costs regulatory asset and an increase of $4 million in the Transmission formula rate annual reconciliations regulatory asset.

ACE. Regulatory liabilities increased $2 million primarily due to an increase of $13 million in the Electric energy and natural gas costs regulatory liability, partially offset by a decrease of $4 million in the Transmission formula rate annual reconciliations regulatory liability and a decrease of $4 million in the Over-recovered credit loss expense regulatory liability.

Capitalized Ratemaking Amounts Not Recognized

The following table presents authorized amounts capitalized for ratemaking purposes related to earnings on shareholders' investment that are not recognized for financial reporting purposes in the Registrants' Consolidated Balance Sheets. These amounts will be recognized as revenues in the related Consolidated Statements of Operations and Comprehensive Income in the periods they are billable to the Utility Registrants' customers. PECO hadno related amounts at March 31, 2026 and December 31, 2025.

(a)For the three months ended March 31, 2026 reflects ComEd's unrecognized equity returns earned for ratemaking purposes on its electric distribution rate regulatory asset. For the year ended December 31, 2025, reflects ComEd's unrecognized equity returns earned for ratemaking purposes on its electric distribution rates and distributed generation regulatory assets.

(b)BGE's amount capitalized for ratemaking purposes primarily relates to investments in rate base included in the multi-year plan reconciliations.

(c)Pepco's authorized amounts capitalized for ratemaking purposes relate to earnings on shareholders' investment on AMI programs, Energy efficiency and demand response programs, investments in rate base and revenues included in the multi-year plan reconciliations, and a portion of Pepco District of Columbia's revenue decoupling.

(d)DPL's authorized amounts capitalized for ratemaking purposes relate to earnings on shareholders' investment on AMI programs and Energy efficiency and demand response programs.

(e)ACE's authorized amounts capitalized for ratemaking purposes primarily relate to earnings on shareholders' investment on AMI programs.