FCC mid-term EEO review

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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

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