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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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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…

It is time for our look at September’s regulatory dates and deadlines to which broadcasters should be paying attention – and the deadline that probably is most important to all commercial broadcasters is not yet known.  That, of course, is the deadline for the payment of annual regulatory fees – which must be made before the federal government’s October 1 start of the new fiscal year.  We expect an announcement of the final decision on the amount of those fees for various broadcasters, and the deadlines for payment, in the next few days.  Keep on the alert for that announcement. 

Below is our summary of the other dates affecting broadcasters this September, including the effective date of the Emergency Alert System’s (“EAS”) new Missing and Endangered Persons event code, comment and other pleading deadlines in several FCC proceedings, the deadline for affected broadcasters to file their responses to the FCC’s August 2025 EEO Audit Letter, in addition to several political file window dates.

September 8 is the effective date of the new EAS Missing and Endangered Persons event code to be used by all EAS Participants, including broadcast stations.  In August 2024, the FCC adopted a Report and Order creating a new EAS event code for persons over the age of 17 who are missing or abducted from states, territories, or tribal communities (known as Ashanti Alerts), but delayed its effective date to provide EAS Participants with enough time to update their EAS systems to use the code.Continue Reading September 2025 Regulatory Dates for Broadcasters – FCC Regulatory Fees, Political Windows, EAS Event Code, Rulemaking Comment Deadlines, and more

  • The Radio Music License Committee announced settlements with both ASCAP and BMI of rate court litigation over the royalties to
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  • The FCC’s Public Safety and Homeland Security Bureau announced that October 3 is the deadline for EAS Participants, including broadcasters,
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Last week, as we noted in our last regular summary of the prior week’s regulatory activity, the FCC’s Media Bureau announced that it had waived the requirement for broadcasters to file their next Biennial Ownership Reports while the FCC considers whether to even continue to require the use of this form.  Ownership reports were set to be filed by December 1 of this year, reporting on a broadcaster’s ownership as of October 1.  The obligation to file this report has now been extended to June 1, 2027, unless the FCC concludes its review before that date and announces a different filing requirement.  The Media Bureau made clear that ownership reports required at other times (e.g., after the consummation of an assignment or transfer of broadcast station licenses or after the grant of a construction permit for a new station) are still required.  It is simply the Biennial Report required from all full-power broadcasters and from LPTV licensees that has been put on hold.

The Bureau based this extension on its intent to review whether this form continues to be necessary.  As pointed out in some of the comments filed in the Delete, Delete, Delete proceeding, the Biennial Ownership report did not provide any information necessary for any purely regulatory purpose.  Baseline ownership information about licensees is provided in applications seeking authority to operate a station (either through acquisition from an existing licensee or through a construction permit to build a new station) and again reported in the ownership reports required after the grant of such applications.  While incremental changes not requiring FCC approval may be made in the interim (and would be captured on the Biennial Report), if there are any changes in the control of a licensee, those first need FCC approval.  The Biennial Reports themselves do not trigger any FCC review or approval.  One of the principal reasons for the adoption of the requirement for these biennial filings was to capture a snapshot of broadcast ownership that could potentially be used for FCC affirmative action considerations.  Only the Biennial Ownership Reports require the identification of the race and gender of individuals who hold interests in broadcast stations.  Given the current administration’s position on these race- and gender-based governmentally-imposed affirmative action obligations, it is perhaps no surprise that this justification for the filing of these reports appears likely be insufficient to justify the continued use of these forms.  This action to put the Biennial Report on hold does raise the question of what other routine broadcast filing obligations may also be under review in the Delete, Delete, Delete proceeding.Continue Reading FCC Delays Filing Date for Biennial Ownership Report While Considering Its Value – What Other Broadcast Regulatory Obligations May Be Under Review?