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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.  The FCC on Friday announced the amount of those fees, and we expect that this coming week, the payment window will be set, and the FCC will issue fee filing guides for all the industries regulated by the FCC – including a Media Bureau filing guide for broadcasters.  Stay alert for those announcements. 

Later in the month is the filing window for broadcasters to submit their Auction 114 “short-form” construction permit applications necessary to participate in the action of 132 construction permits for new FM stations, (see the list of available channels here).  The filing window opens at 12:00 p.m. ET on September 14 and closes at 6:00 p.m. ET on September 30.  Bidding is scheduled to begin on February 2, 2027.  These “short-form” applications on FCC Form 175 are necessary to participate in the auction.  Among the information required from an applicant in the Form 175 is the identification of which of the 132 vacant allotments they intend to bid on, any bidding credits for which they may be eligible, and certain ownership information.  Applicants may also specify specific coordinates for tower sites that an applicant plans to use for any channel to protect that site from being precluded by subsequent applications by other FM stations.  For more on the process, see our article here and the FCC’s instructions for auction participation here.  In addition, the FCC just released a Small Entity Compliance Guide summarizing the requirements and procedures for the upcoming Auction.

Continue Reading September 2026 Regulatory Dates for Broadcasters – FCC Regulatory Fees, Auction 114 Short-Form Applications and Filing Freeze, Deadline for Implementation of EAS Security Practices, LUC Window for the November Election and More
  • 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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In early July, we wrote about the FCC’s decision to require that all broadcasters take measures to secure their EAS operations – and in the process secure their entire program chain – to make sure that malicious actors can’t hack into their systems and send false alerts.  The FCC today published in the Federal Register the order making those changes, which will require broadcasters to meet these security requirements in 60 days – by September 29.

By that date, the FCC requires that broadcasters have strong passwords for any part of their program chain that is connected to the internet, that they have the latest security updates installed in all hardware and software, and that they put all access to their program chain behind a firewall.  We wrote about the FCC’s decision and what is required back in early July and, now that the deadline for compliance is set, we reprint below much of that article to remind broadcasters of the details of what they need to do by the September 29 deadline:

At its regular monthly open meeting [in June], the FCC adopted an Order meant to enhance the security of the Emergency Alerting System.  Citing past hacks of the system that have resulted in false EAS alerts being transmitted to the public by broadcast stations, the FCC proposed in 2022 that broadcasters adopt a comprehensive cybersecurity plan with an annual filing requirement detailing how risks were managed and controlled (see our article here).  The Order adopted this week did not go that far, but it did adopt a mandatory three-point plan to secure not only EAS equipment at a station, but also to secure the entire program chain to ensure that bad actors can’t access station programming to insert false emergency information or other malicious content. 

While the first two requirements of the mandated plan should be relatively simple for broadcasters to quickly implement, the third may require some outside help – and the FCC has given broadcasters only a short time to implement this requirement.  The Order requires implementation within 60 days of the date that the Order is published in the Federal Register (see the just-released FCC Erratum correcting the Order to reiterate that the effective date will be 60 days after Federal Register publication).  As Federal Register publication should come soon, the Order requires quick action by broadcasters.  Let’s look at the new obligations.

Continue Reading New Security Obligations for Broadcasters Required by September 29 – Strong Passwords, Updated Software and Hardware, and Firewalls to Protect All Parts of the Program Chain

At its regular monthly open meeting last week, the FCC adopted an Order meant to enhance the security of the Emergency Alerting System.  Citing past hacks of the system that have resulted in false EAS alerts being transmitted to the public by broadcast stations, the FCC proposed in 2022 that broadcasters adopt a comprehensive cybersecurity plan with an annual filing requirement detailing how risks were managed and controlled (see our article here).  The Order adopted this week did not go that far, but it did adopt a mandatory three-point plan to secure not only EAS equipment at a station, but also to secure the entire program chain to ensure that bad actors can’t access station programming to insert false emergency information or other malicious content. 

While the first two requirements of the mandated plan should be relatively simple for broadcasters to quickly implement, the third may require some outside help – and the FCC has given broadcasters only a short time to implement this requirement.  The Order requires implementation within 60 days of the date that the Order is published in the Federal Register (see the just-released FCC Erratum correcting the Order to reiterate that the effective date will be 60 days after Federal Register publication).  As Federal Register publication should come soon, the Order requires quick action by broadcasters.  Let’s look at the new obligations.

Continue Reading FCC Adopts Order to Secure EAS System – Broadcasters’ Program Chain Must Be Behind Firewall Soon
  • FCC Chairman Carr announced that the FCC will be considering two orders concerning foreign ownership requirements, including those for broadcasters,
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  • The FCC announced that comments and reply comments are due August 4 and August 22, respectively, responding to its Public
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