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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

Late yesterday afternoon, the FCC issued a series of Public Notices setting out the due date for filings and uploads that were due during the shutdown. By a Public Notice released last week, most dates were already extended to today, November 18, as many FCC filing systems were not operational – and are expected only to become operational today.  The FCC yesterday issued another Public Notice stating that, in general, filings that were due during the shutdown and through yesterday, November 17, will be due today, November 18.  However, that Public Notice, and a series of additional notices also released yesterday, extend most deadlines that apply to broadcast filings – with some of those extensions listed below. 

For broadcasters, today’s due date appears to apply to station-specific deadlines like responses to pleadings that were due between October 1 and November 17, comments in certain rulemaking proceedings (including the modernization of the Disaster Information Recovery System that, at this time, is voluntary for broadcasters), filings related to Antenna Structure Registrations and related tower filings, any responses to targeted enforcement matters (which were actually to be submitted during the shutdown), and other deadlines set by the Communications Act that cannot be waived by the Commission.  Review the Public Notice for more details on these deadlines.

Many other FCC dates and deadlines have been postponed.  A summary of the broadcast deadlines that have been extended, with links to Public Notices that provide more information, are set out below:Continue Reading FCC Reopening – New Deadlines Established for Many Broadcast Applications and FCC Filings

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

  • The US Court of Appeals for the Fifth Circuit issued a decision that raises significant questions about the FCC’s ability
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Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • On October 17, Sen. Brian Schatz (D-HI), Sen. Marsha Blackburn (R-TN), and Rep. Anna Eshoo (D-CA) introduced the Identifying Propaganda

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Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • Follow field testing by GeoBroadcast Solutions of its zonecasting system, the FCC opened a new comment period for interested parties

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The FCC this week released a Public Notice (that we mentioned in our update on regulatory dates for May) announcing that, on May 17, many new applications and other filings will be migrating to the FCC’s newer LMS filing platform.  These include many of the documents that had been until recently filed in the FCC’s old CDBS platform.  These applications had, since CDBS was closed for new filings, been submitted through emails to the FCC (see our articles here and here).

Most notably, the new LMS filings will include requests for Special Temporary Authority – and future requests for extensions of STAs.  The FCC notes that for STAs that had originally been filed in CDBS, rather than filing an extension request for such STAs, applicants should initially file for a new STA in LMS and indicate in an exhibit that the request is for an extension of an existing STA that was filed in CDBS (or by email in the interim processing period).  The full list of applications that will, as of May 17, be filed in LMS is as follows:

  • FM Engineering Special Temporary Authorizations (STAs)
  • Request for Silent STA
  • Extension of STA – Silent
  • Extension of STA – Engineering
  • Suspension of Operations Notification
  • Resumption of Operations
  • AM/FM Digital Notification
  • Modulation Dependent Carrier Level (MDCL) Notification
  • Change of Primary Station Notification
  • Tolling Notification
  • Reduced Power Notification
  • Withdraw Pending Applications

Continue Reading More FCC Broadcast Applications Moving to LMS – Including Requests for STAs