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It’s the start of another year, so it is time to dust off the crystal ball and look at what we expect to be the big regulatory and legislative issues facing broadcasters in the new year.  Looking back on our forecast for 2025 that came out just over a year ago, I was surprised to see that we had predicted that the new Commission would be interested in defining the public interest standard, reviewing network-affiliate relations, and looking at the political biases that broadcasters allegedly exhibited.  All of these were in fact issues that came up this year but, as no conclusions were reached on any of these matters, these same issues will no doubt continue to be on the FCC’s agenda in 2026.

Public Interest Standard

Throughout 2025, FCC Chairman Carr has been talking about the public interest standard in most of his many public discussions of media regulation, and those comments have prompted much legal analysis from all corners.  We expect that, in the coming year, there will continue to be discussions about what the public interest standard really means– and just how far that standard goes in authorizing the FCC to act to regulate broadcast operations.

Network-Affiliate Relations

The FCC has also received preliminary comments on the relationship between television networks and their affiliates.  As we noted last week, reply comments were due December 29, so the pleading cycle has now closed.  In the Public Notice asking for these comments, there was a statement that the comments would be used to inform the Commission as to whether a formal rulemaking proceeding was necessary to further review the issues.  With the comments in, we will be watching to see if the FCC moves forward with any additional proceedings. Continue Reading Crystal Ball Time – What Are the Regulatory and Policy Issues Broadcasters Should Be Expecting to Deal With in 2026?

Today, we would normally publish our look back at the prior week’s regulatory activity of importance to broadcasters but, as we noted last week, we are taking this week off and will publish a summary of the regulatory activity during the two week holiday period next Sunday.  But, as the start of a new month is upon us, we instead offer our regular look ahead at regulatory dates and deadlines for January.   

With each New Year, there are a host of new regulatory deadlines to keep broadcasters busy.  In January, this includes some recurring FCC deadlines like Quarterly Issues/Programs lists for all full power broadcasters, and a host of other quarterly obligations that are not as widely applicable.  For TV broadcasters, the month brings obligations including the annual children’s television reports on educational and informational programming and a public file certification on commercial limits, as well as the extension to stations in 10 additional markets of the audio description requirements. 

In addition to comments in rulemaking proceedings described below, January brings some new obligations.  For commercial broadcasters streaming audio programming on the Internet, there are new SoundExchange royalties that cover performances made on and after January 1, and a requirement for a higher minimum fee due at the end of the month.  There is also a freeze that will be imposed on applications for major changes by existing LPTV stations and TV translators related to a window that will open in March, the first window in well over a decade for the filing of applications for new LPTV stations. 

Let’s look at some of the specific dates and deadlines for broadcasters in January, starting with the routine deadlines that come up every January, and then moving to some of new obligations for 2026.  After that we provide January deadlines for comments in rulemaking proceedings (including reply comments on proposed changes to the FCC’s ownership rules and initial comments on proposals to speed the ATSC 3.0 conversion), a look at lowest unit rate windows that open in January for 2026 elections, and finally a few deadlines in early February.Continue Reading January 2026 Regulatory Dates for Broadcasters – Quarterly Issues/Programs Lists, Children’s Television Programming Reporting, New Webcasting Royalties, Expansion of Audio Description Requirements, Comment Deadlines, Political Windows, and More

  • The FCC and the FCC’s Media Bureau released several Public Notices (here, here, here, and here
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With the federal government shutdown finally ending yesterday, broadcasters need to be prepared to take steps to comply with FCC rules whose enforcement has been put on hold since October 1, when the government shut down most FCC electronic filing systems, including the online public files.  Now that the FCC has reopened, the FCC has recognized that its initial guidance (about which we wrote here), issued in the face of what might have been expected to be a short suspension of activities, was not realistic given the length of the shutdown and the potential issues that could arise with many broadcasters and other regulated entities all trying to upload their documents to various FCC systems by the end  of the next business day after government operations resumed (see our list of concerns here). 

Thus, yesterday, when the FCC reopened, it released a Public Notice postponing the deadline for filings due during the shutdown until at least Tuesday, November 18, with a promise of another public notice before that date to evaluate whether that date was in fact realistic or if a further extension for some or all filings would be warranted.  In fact, that Public Notice suggests that parties not rush to upload everything immediately, but only to submit time-sensitive documents to the FCC.  Given that, as of 9 AM Eastern on Friday morning (on November 14), some FCC databases including the online public file still are offline, it appears realistic to assume that some further extensions will be required.  [Update, 11/14/ 2025, 4:00 PM ET, the FCC has now posted notices on the help pages for both the Online Public Inspection File and for LMS where applications are filed, saying that neither system will be available for use until November 18, seemingly insuring a further extension of the dates by which filings will be due] Consult your own legal and technical advisors as to how these deadlines affect your operations and as to what filings should be prioritized once the FCC’s systems are back up and operating. Continue Reading Federal Government Reopens with FCC Decision to Provide More Time to Submit Delayed Filings – and Watch for Comment Deadlines in Major Proceedings on Media Ownership and the ATSC 3.0 Transition

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…

  • The FCC announced that comments and reply comments are due August 4 and August 22, respectively, responding to its Public
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Though school may be letting out for many, the FCC does not take a summer recess.  Instead, regulation continues.  Perhaps most importantly, Chairman Carr will have a Republican majority on the FCC for the first time since the change in administration, as Democratic Commissioner Starks has said that he is leaving the Commission before its June meeting.  See our article from earlier in the week for our views on some of the issues that may be prioritized once the Chairman’s majority is in place.  In addition, there are some routine deadlines – including EEO filing deadlines for broadcasters in several states across the country and deadlines for comments or reply comments in a number of rulemaking proceedings.  And there are political windows that open in June, principally for elections that will occur in August.

June 2 is the deadline for radio and television station employment units in Arizona, the District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, and Wyoming 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 June 2025 Regulatory Dates for Broadcasters – Annual EEO Public File Reports, Comment Deadlines, and More