• Senator Ron Wyden (D-OR) wrote a letter to the sole Democratic FCC Commissioner, Anna Gomez, highlighting questions about whether it
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October is another busy month of regulatory dates and deadlines for broadcasters.  Unlike previous years, there is no threat of a federal government shutdown on its October 1 start of the new fiscal year, so the dates and deadlines discussed below should not move on broadcasters.  As we detail below, all stations will need to observe EAS reporting requirements for the filing of ETRS Form One in anticipation of the upcoming Nationwide EAS Test, and all full-power stations need to remember the Quarterly Issues Programs list filing deadline.  While there always can be an October surprise, we take a look below at these and other significant dates and deadlines in the coming month. 

October 1 is the deadline for radio and television station employment units in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Missouri, Northern Mariana Islands, Oregon, Puerto Rico, the 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 (OPIFs).  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 has in the past led to significant FCC fines (see our article here about a $26,000 fine for a single late EEO report).

The filing of the Annual EEO Public File Reports triggers the Mid-Term EEO Review beginning October 1 for TV station employment units with five or more employees in Alaska, American Samoa, Guam, Hawaii, Northern Mariana Islands, Oregon, and Washington.  The Mid-Term EEO Review that analyzes the last two Annual EEO Public File Reports for compliance with the FCC’s EEO requirements.  See our articles here and here on stations’ Mid-Term EEO Review reporting requirements.

Continue Reading October 2026 Regulatory Dates for Broadcasters – Quarterly Issues/Programs Lists; EAS Test Form One; Annual EEO Public File Reports; EEO Audit Responses; Filing Freeze on FM Translators; and more
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  • The FCC announced that September 24 is the deadline for paying the 2026 annual regulatory fees which were set by
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  • The FCC’s Enforcement Bureau released an EEO Audit Notice targeting 400 radio and TV stations for review of their EEO
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  • The FCC’s Order adopted in June that requires broadcasters to quickly adopt new security practices to protect their EAS systems
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  • The FCC’s Media Bureau announced that the upcoming new noncommercial educational FM translator reserved band (88.1-91.9 MHz) filing window has
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This week, the FCC’s Enforcement Bureau entered into a Consent Decree with iHeartMedia to resolve its investigation into whether iHeart violated the FCC’s sponsorship identification rules. Interestingly, iHeart does not admit that it violated any rules, nor does the FCC suggest any specific conduct by iHeart violated any rule.  So why the Consent Decree?  The Decree say that it resolves an investigation into whether iHeart “violated the Commission’s sponsorship identification rules in connection with allegations that iHeart provided artists additional airplay on the Company’s radio stations in exchange for the artists’ performances at Company events, without the disclosure required under the Commission’s sponsorship identification laws.”  What is the disclosure that is required, and when is it required?  Again, the Decree does not make clear what identification would be required, nor does it say exactly what circumstances would trigger the requirement for a sponsorship identification.  So we have to look at the terms of the Decree itself to see if we can piece together exactly what is prohibited and when on-air sponsorship identifications are required. What we ultimately find is that the Decree really conveys a message that applies to broadcasters in many situations – when the station gets free or discounted “stuff” (whether it be a band’s appearance at a station event or free meals at a local restaurant) in exchange for something that is broadcast over the air, the audience needs to know that the airplay was sponsored.

The first place to look in trying to draw some specific guidance from this Decree is at its history.  The Decree stems from an Enforcement Advisory released by the Enforcement Bureau in February 2025, after Senator Blackburn from Tennessee alleged that bands had complained to her about some station practices in strongarming them into playing at station events for free or at reduced pay. The 2025 Advisory warned that any “deals” for bands to play at station events in exchange for more airplay, or any threats (express or implied) to reduce airplay if a band did not appear at an event, would be seen as a violation of the payola and sponsorship identification rules.  The Bureau referred to such threats as “covert manipulation of radio airplay.”  The Advisory states “[w]hen payola causes stations to broadcast programming based on their financial interests at the expense of community responsiveness, the practice is inconsistent with localism.” We wrote more about the Advisory when it was released, and included a broader discussion of the payola rules. 

Continue Reading FCC Consent Decree With iHeart Discusses how Exchanging Airplay for Discounts or Free Stuff Can Trigger Sponsorship Identification Requirements, Including for Songs Played in Exchange for a Band’s Appearance at Station Events