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  • The FCC’s Media Bureau announced that the deadline for broadcasters to comply with the new foreign sponsorship identification requirements has
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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

  • The FCC’s Media Bureau waived the requirement that broadcasters file their biennial ownership reports by December 1 of this year,
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  • The Senate voted 53-45 to confirm Olivia Trusty as an FCC Commissioner on a largely party-line vote.  As a result
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Just about a year ago, the FCC issued an Order which, as we wrote here, contained some good news and some bad news for broadcasters.  The good news was that the FCC came up with a relatively short form (far shorter than the multi-page form originally proposed) that broadcasters could use to assess whether a buyer of program time on the station was a foreign government or an agent a foreign government.  This assessment of buyers of program time was required by FCC rules that became effective in 2022.  In 2022, no form was provided, so broadcasters had to come up with their own certifications to get assurances that program time buyers were not foreign governments or their agents (and if they were, public file and other enhanced on-air disclosures were required).  Last week, the FCC announced the effective date of a new form which, if signed by the broadcaster and the ad buyer, provides broadcasters with a safe harbor for assurances that the buyer is not a foreign agent (the forms are at Appendix C and D on pages 47 and 48 of the 2024 FCC Order).[1] 

The bad news in the order from last year was that the FCC extended the requirement that this assessment be made from buyers of program time, to also include buyers of paid PSAs and other spots that are not for a commercial product or service (including political issue ads – but excepting candidate ads on the theory that those ads had already been vetted for foreign influence by the qualification of the candidate to run for office).  While these rules were adopted a year ago, they have been on hold, until now, while a standard Paperwork Reduction Act review was completed (as required for all rules imposing new paperwork obligations on those subject to the rules). Continue Reading FCC Announces Effective Date of Modifications to Rules Governing the Purchase of Broadcast Airtime By Agents of Foreign Governments

  • The FCC’s Media Bureau announced that June 10 is the effective date for the FCC’s modified broadcast foreign sponsorship identification
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  • The FCC announced that May 23 is the effective date of its January Order increasing its application fees, including those
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  • The NAB and SoundExchange filed with the Copyright Royalty Board a proposed settlement of the pending litigation over the 2026-2030
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  • In an effort to exert more control over independent federal agencies, including the FCC, President Trump signed an Executive Order
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It’s a new year, and as has been our custom at the beginning of each year, we dust off the crystal ball and take a look at what we think may be some of the significant regulatory and legislative issues that broadcasters will be facing in 2025.  This year, there is an extra layer of uncertainty given a new administration, both in the White House and at the FCC.  Already, it appears that a new administration will bring new priorities – some barely on the radar in past years – to the top of the list of the issues that broadcasters will need to be carefully monitoring.

One of those issues has been a possible FCC review of the meaning of the “public interest” standard under which all broadcasters are governed.  As we wrote when President-Elect Trump announced his pick for the new FCC Chair starting on Inauguration Day, Chair-Designate Brendan Carr has indicated that this public interest proceeding will be a high priority.  In his opinion, broadcasters, or perhaps more specifically the news media, have suffered from an erosion of trust, and it has been his expressed opinion that a reexamination of the public interest standard might help to restore public trust.  We noted in our article upon his selection that this is not the first time that there has been a re-examination of that standard.  It has traditionally been difficult to precisely define what the standard means.  In the coming days, we will be writing more about this issue.  But suffice it to say that we are hopeful that any new examination does not lead to more paperwork obligations for broadcasters, as seemingly occurred whenever any broadcast issue was addressed by the current administration.  As we note below, there are several paperwork burdens that we think may disappear in the new administration, so we are not expecting more paper – but we will all need to be carefully watching what develops from any re-examination of the public interest standard.Continue Reading Looking Into the Crystal Ball – What Legal and Policy Issues are Ahead for Broadcasters in 2025?