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We would normally provide you with some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.  But, as the government shutdown has drastically limited activity at the FCC, and as Congress did…

  • The FCC released a Public Notice announcing that, effective 12:01 AM on October 1, the agency will “suspend most operations”
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With the federal government shutdown now in its third day, having started on October 1, 2025, after Congress failed to fund the government for the coming year or to pass a “continuing resolution” to allow government agencies to function at their current levels, we thought that we should summarize the FCC’s guidance as to what is and what is not functional at the FCC during this period. In anticipation of a shutdown, on September 30, 2025, the FCC released a Public Notice announcing that it will “suspend most operations” in the event of a shutdown and providing some specifics as to what would and would not be operating during the shutdown.  A summary of the FCC’s guidance is set out below.  But it is important to note that much of this guidance is general, and how specific cases will be dealt with when the government reopens may be addressed in subsequent FCC notices – likely to be issued when the government reopens.  This is especially true if the shutdown is prolonged. 

On many specific issues, we suggest discussions with your own communications counsel to discuss what may happen when the government reopens.  While, as noted below, the FCC’s general rule will be that most deadlines that were to be met during the shutdown will be extended to the day after the day of the government’s reopening, there are exceptions.  For instance, targeted Enforcement Actions are still to be submitted on time.  There is no indication in the FCC’s Public Notice as to how responses to the open EEO audit will be dealt with.  Because the FCC-administered Online Public File database is offline, the general requirement to upload a station’s EEO audit response to the public file is impossible to meet.  But what about responses to the new DEI questions which, as we noted here, can now be submitted by email rather than uploaded to the public file?  There is no specific guidance in the Public Notice.  Similarly, the FCC’s major change window (which we wrote about here) may be suspended until after the shutdown as LMS is unavailable during the shutdown.  The same with Quarterly Issues/Programs lists as the online public file system is not functioning.  But will the FCC’s systems be able to handle a crush of filings due the first business day after the day that the government reopens?  These are all questions that broadcasters should consider with their counsel. Continue Reading The Government Shutdown and Issues it Raises for Broadcasters

October is, on paper, a busy month of regulatory deadlines for broadcasters.  As set forth below, the month includes the requirement for almost all broadcasters to complete and upload to their public file their Quarterly Issues/Programs Lists, as well as the date for broadcasters to submit to the FCC their ETRS Form One reporting basic information about their EAS equipment.  There are also routine EEO annual deadlines for stations in several states, and the response deadline for the 300 stations subject to the FCC’s first EEO audit under the new administration – which included new questions about stations’ DEI practices.  A “major change” filing window for LPTV stations and TV translators is also scheduled to open this month.  But these and other deadlines could be affected by the looming federal government shutdown beginning October 1 if Congress fails to fund the government for the coming year (or pass a “continuing resolution” to allow government agencies to function at their current levels).  If a shutdown does occur, the FCC, the FTC, the Copyright Office and other federal agencies may have to pause their operations, which may result in some of the regulatory deadlines discussed below for the FCC being delayed.  Note that, in some cases, agencies have some funds set aside that allow them to keep functioning for a few extra days, which has been the case for the FCC during several of the last government shutdowns, but that is not assured.  Because of the potential of this extended operation even if there is a shutdown, do not assume that regulatory deadlines set forth below will be postponed by a funding impasse. 

In the past, when there has been a pause in government operations and after any residual funds to keep the agency operating have been expended, agencies like the FCC ceased the processing of routine applications and paused all other routine work, staying open only to the extent necessary to deal with emergencies and other vital activity.  In at least one shutdown, the FCC even limited access to its website and online systems. In the past, FCC filings have been suspended, with additional time being provided after the government reopens to make filings that were due during the shutdown.  But details are different in each shutdown.  If Congress cannot resolve the funding issues by October 1, we would expect that the FCC and other agencies important to broadcasters to issue public notices about specific policies to be applied after funding runs out.  Stay tuned to see if any of the dates below have to be rescheduled.

October 1 is the deadline for radio and TV station employment units in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Missouri, Northern Mariana Islands, Oregon, Puerto Rico, U.S. Virgin Islands, and Washington with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ Online Public Inspection Files.  A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having at least one common employee.  For employment units with five or more full-time employees, the annual report covers hiring and employment outreach activities for the prior year.  A link to the uploaded report must also be included on the home page of each station’s website, if the station has a website.  Be timely getting these reports into your station’s OPIF, as even a single late report can lead to FCC fines (see our article here about a recent $26,000 fine for a single late EEO report).Continue Reading October 2025 Regulatory Updates for Broadcasters – Possible Government Shutdown, Quarterly Issues/Programs Lists, EEO Public File Reports, EEO Audit Responses, ETRS Filing Deadline, LPTV/TV Translator Filing Windows, and More

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As we noted in our weekly summary of regulatory activity of interest to broadcasters, the FCC on Friday released a number of public notices and fact sheets providing details of how broadcasters are to pay their annual regulatory fees. Included among the public notices was one setting the deadline for paying the regulatory fees as September 25th. The FCC’s filing system is open now so fees can be paid at any time prior to the September 25th deadline. The failure to pay fees by that deadline will result in a 25% penalty.  Interest will also accrue on late payments, as well as collection fees.  Thus, late payments are costly. 

Fees for each television station are set out in the FCC’s Report and Order setting those fees (in a table in Appendix F, pages 52-95 of the order – fees are established based on a station’s population coverage, so each station is assigned a specific fee).  Radio stations can look up their fees in a “look up database” that is available through a link that was set out in the Media Bureau Fact Sheet released on Friday. Broadcasters should check their fees carefully to make sure that they are paying the expected amount and are submitting payment for all of their affected facilities.  Remember, fees are based on a station’s facilities on October 1, 2024, the beginning of the last fiscal year.  For broadcasters with earth stations, those fees are set out in the Space Bureau Fact Sheet. Continue Reading Annual Regulatory Fees Due by September 25 – FCC Releases Public Notices and Fact Sheets on Paying Those Fees

Updated, 9/9/25 to correct typo in opening date for the filing of applications for new LPTV and TV translator stations in the second bullet below.

Here are some of the regulatory developments of significance to broadcasters from the past two weeks, with links to where you can go to find more information as to how…

Last Friday, the FCC released its Order adopting the regulatory fees to be paid by broadcasters and other regulated entities at some point before the October 1 start of the federal government’s new fiscal year.  The Commission slightly increased fees for TV stations by 1.2% from last year (from $0.006598 to $0.006674 per population served)…

  • The Radio Music License Committee announced settlements with both ASCAP and BMI of rate court litigation over the royalties to
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