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Even with the holidays upon us, there are many regulatory dates for broadcasters in December and early January.  That is particularly true this year, now that the federal government shutdown has ended and the FCC is playing catch-up on regulatory deadlines.  As we discuss below and in more detail here, many of these revised dates for the submission of documents that would have been due during the shutdown will fall in the month of December. 

But before we dive into the December dates, one item that broadcasters can scratch off their calendars this month is the Biennial Ownership Report, which would have been due December 1.  In August, the FCC’s Media Bureau waived the filing requirement while the FCC considers whether to even continue the requirement for the filing of these reports (see our discussion here).  Broadcasters now have until June 1, 2027 to file the report 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 new station’s construction permit) are still required.  It is simply the Biennial Report required from all full-power broadcasters and from LPTV licensees that is on hold. 

Here are some of the upcoming dates and deadlines in December that you should be watching:

December 1 is the extended deadline for all full power and Class A television stations and full power AM and FM radio stations, both commercial and noncommercial, to upload their Quarterly Issues/Program lists for the third quarter of 2025 to their Online Public Inspection Files (OPIFs).  These lists were originally due October 10 but could not be filed by stations due to the government shutdown.  The lists should identify the issues of importance to the station’s service area and the programs that the station aired between July 1 and September 30, 2025, that addressed those issues.  These lists must be timely uploaded to your station’s OPIF, as the untimely uploads of these documents probably have resulted in more fines in the last decade than for any other FCC rule violation.  As you finalize your lists, do so carefully and accurately, as they are the only official records of how your station is serving the public and addressing the needs and interests of its community.  See our article here for more on the importance that the FCC has, in the past, placed on the Quarterly Issues/Programs list obligation.Continue Reading December 2025 Regulatory Dates for Broadcasters – Post-Shutdown Deadlines, EEO Public File Reports, Comment Deadlines, Political Windows, and more

As 2024 comes to an end, 2025 is beginning to come into focus – a new year that will likely bring big changes to the Washington broadcast regulation scene with the inauguration of a new President and installation of a new FCC chair who has already promised to move forward with policies very different than those of the current administration (see our discussion here and here).  But while we are waiting for the big changes that may occur, there are many more mundane dates and issues to which broadcasters need to pay attention.  Let’s look at what is coming up in the next month.

Broadcasters need to remember that January 10 is the deadline for all full power and Class A TV stations, and full power AM and FM radio stations, both commercial and noncommercial, to upload to their Online Public Inspection Files their Quarterly Issues/Program lists for the fourth quarter of 2024.  The lists should identify the issues of importance to the station’s community and the programs that the station aired between October 1 and December 31, 2024, that addressed those issues.  These lists must be timely uploaded to your station’s OPIF, as the untimely uploads of these documents probably have resulted in more fines in the last decade than for any other FCC rule violation.  As you finalize your lists, do so carefully and accurately, as they are the only official records of how your station is serving the public and addressing the needs and interests of its community.  See our article here for more on the importance of the Quarterly Issues/Programs list obligation.Continue Reading January 2025 Regulatory Updates for Broadcasters – Quarterly Issues/Programs Lists, Children’s Television Programming Reporting, Expansion of Audio Description Requirements, Political Windows, and More

  • The FCC’s Public Safety and Homeland Security Bureau announced that October 4 is the deadline for EAS Participants to file
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  • Congress passed, and the President signed, a continuing resolution to extend funding for the Federal government, including the FCC, averting
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The new year brings a series of noteworthy regulatory deadlines for broadcasters in January.  As always, broadcasters should consult with their own attorneys and advisors to make sure that they are aware of and ready to act on any other deadlines that are not listed below.

Congress still has not passed budget bills for the fiscal year that started on October 1, and some of the “continuing resolutions” to fund the federal government at last year’s levels run out on January 19, with the FCC’s budget set to expire on February 2.  Thus, at least a partial government shutdown may well occur if Congress fails to act this month.  As we previously discussed here and here, if a government shutdown does occur, some government agencies may have to cease all but critical functions if they do not have any residual funds to continue operations.  If no funding is approved, the FCC will announce how any shutdown will affect it, including whether it has any residual funds to keep operating beyond any general funding deadline.  Watch Congressional actions and any FCC announcements to see how any deadlines that apply to your station will be affected by the funding deadline.

With those concerns in mind, let’s look at some of the specific dates and deadlines for broadcasters in January.  Beginning January 1, television stations affiliated with the Top 4 Networks and operating in Nielsen Designated Market Areas (DMAs) 91 through 100 will be added to the list of markets that are subject to the FCC’s audio description rules.  The DMAs where the rules become effective on January 1 are:  El Paso (Las Cruces), Paducah-Cape Girardeau-Harrisburg, Cedar Rapids-Waterloo-Iowa City & Dubuque, Burlington-Plattsburgh, Baton Rouge, Jackson, MS, Fort-Smith-Fayetteville-Springdale-Rogers, Boise, South Bend-Elkhart, and Myrtle Beach-Florence – in addition to Chattanooga and Charleston, SC, which were previously in DMAs 92 and 91, respectively, but are now in DMAs 84 and 88.  We reported here on the FCC’s recent reminder that these new markets will be subject to the audio description requirements as of January 1.  TV stations associated with the Top 4 networks in these markets are required to provide audio description for 50 hours of programming per calendar quarter, either during prime time or in children’s programming, and 37.5 additional hours of audio description per calendar quarter between 6 a.m. and 11:59 p.m. local time, on each programming stream that carries one of the top four commercial television broadcast networks (ABC, CBS, FOX and NBC). Continue Reading January Regulatory Dates for Broadcasters – Expansion of Audio Description Requirements, Music Royalty Cost of Living Increases, Quarterly Issues/Programs Lists, Childrens Television Programming Reporting, Political Windows, and More

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  • The FCC’s Enforcement Bureau released a Notice of Apparent Liability proposing a $25,000 fine on two commonly-owned clusters of broadcast
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