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October 1 is the deadline for broadcast stations licensed to communities in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, the Mariana Islands, Missouri, Oregon, Puerto Rico, the Virgin Islands, and Washington to place their Annual EEO Public File Report in their Public Inspection File and post the report on their station website.

Under the FCC’s EEO Rule, all radio and television station employment units (“SEUs”), regardless of staff size, must afford equal opportunity to all qualified persons and practice nondiscrimination in employment.

In addition, those SEUs with five or more full-time employees (“Nonexempt SEUs”) must also comply with the FCC’s three-prong outreach requirements.  Specifically, Nonexempt SEUs must (i) broadly and inclusively disseminate information about every full-time job opening, except in exigent circumstances, (ii) send notifications of full-time job vacancies to referral organizations that have requested such notification, and (iii) earn a certain minimum number of EEO credits based on participation in various non-vacancy-specific outreach initiatives (“Menu Options”) suggested by the FCC, during each of the two-year segments (four segments total) that comprise a station’s eight-year license term.  These Menu Option initiatives include, for example, sponsoring job fairs, participating in job fairs, and having an internship program.

Nonexempt SEUs must prepare and place their Annual EEO Public File Report in the Public Inspection Files and on the websites of all stations comprising the SEU (if they have a website) by the anniversary date of the filing deadline for that station’s license renewal application.  The Annual EEO Public File Report summarizes the SEU’s EEO activities during the previous 12 months, and the licensee must maintain adequate records to document those activities.

For a detailed description of the EEO Rule and practical assistance in preparing a compliance plan, broadcasters should consult The FCC’s Equal Employment Opportunity Rules and Policies – A Guide for Broadcasters published by Pillsbury’s Communications Practice Group.

Deadline for the Annual EEO Public File Report for Nonexempt Radio and Television SEUs

Consistent with the above, October 1, 2026 is the date by which Nonexempt SEUs of radio and television stations licensed to communities in the states identified above, including Class A television stations, must (i) place their Annual EEO Public File Report in the Public Inspection Files of all stations comprising the SEU, and (ii) post the Report on the websites, if any, of those stations.  Once the new Report is posted on a station’s website, the prior year’s Report may be removed from that website. Continue reading →

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October 1, 2026 is the deadline for commercial TV stations to (1) upload to their online Public Inspection File their must-carry/retransmission consent carriage election statements for the three-year cycle covering January 1, 2027 to December 31, 2029, and (2) directly notify MVPDs of any changes to their carriage elections.

Under the FCC’s electronic carriage election procedures, commercial TV stations must place statements electing either must-carry or retransmission consent in their Public Inspection File by October 1 every third year and retain the statement there throughout the three-year election cycle.  A separate notice sent directly to an MVPD is only required when a station wishes to change from the carriage status it elected with respect to that MVPD for the prior three-year cycle.  Television stations and satellite providers must maintain up-to-date contact information for carriage-related issues in their online Public Inspection File, and cable operators must do the same in the FCC’s Cable Operations and Licensing System (COALS) database.  If they have not already done so, stations and MVPDs should immediately check to confirm that the contact information currently listed in their Public Inspection File or COALS is accurate and up to date.

A station wishing to change from its current carriage election with respect to an MVPD must, in addition to uploading the new carriage election statement, send notice of that change directly to the MVPD’s email address provided in the MVPD’s Public Inspection File or COALS (and copy the FCC at ElectionNotices@FCC.gov).  The station must also place a copy of the emailed election change notice in its Public Inspection File alongside the station’s carriage election statement.  MVPDs are required to confirm receipt of the change notice as soon as possible.  If a station does not receive confirmation, it must follow up using the telephone number provided in the MVPD’s Public Inspection File or COALS.  A station that retains records demonstrating it took the required steps and timely uploaded its election materials to its Public Inspection File will be able to demonstrate that it complied with the FCC’s election procedures.

Noncommercial educational (“NCE”) television stations are not entitled to elect retransmission consent, so their process is slightly different.  These stations are required to make an initial request for carriage, which most did back when the FCC’s electronic election procedures took effect in 2020.  Thereafter, NCE stations are required to maintain their carriage requests in their Public Inspection File.  As a result, NCE stations do not make new triennial elections every three years, but should verify that their carriage-related information remains accurate and current in their Public Inspection File.

Separate procedures also apply to those Low Power TV stations that qualify for must-carry but which are not required to maintain a Public Inspection File.  Qualified LPTV stations must provide an initial carriage election by email directly to MVPDs and thereafter provide a new email notice when changing their election for the upcoming three-year cycle.  As with full-power commercial television stations, a qualified LPTV station must copy ElectionNotices@FCC.gov when making initial or change notifications to MVPDs.  Because these stations do not have an online Public Inspection File, they must ensure that their contact information in the FCC’s Licensing and Management System is up to date so that MVPDs can contact them with any carriage-related questions.

To avoid last-minute issues in meeting the October 1 deadline, commercial TV stations should review their carriage arrangements now, determine whether they will maintain or change them for the 2027-2029 cycle, and then place the appropriate election documentation in their Public Inspection File and send any required email notifications to ensure those are received by the October 1 deadline.

Stations that are planning to change their election with respect to an MVPD should also confirm the MVPD’s listed contact information well in advance of the deadline to avoid last-minute issues, such as discovering that the FCC’s Public Inspection File or COALS databases are offline for maintenance or other reasons, or that the MVPD’s contact information is simply missing from those databases.  This will ensure the station has sufficient time to determine and implement the best alternative approach should that be necessary.

Finally, after uploading these documents to the Public Inspection File, stations should take the added step of confirming that the uploaded documents are visible on the public-facing side of the Public Inspection File so it is clear that the station completed all steps by the October 1 deadline.

A PDF of this article can be found at October 1 Deadline Approaching for TV Stations’ Must-Carry/Retransmission Consent Elections.

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As we reported last week, the FCC adopted its Report and Order establishing the annual regulatory fees for Fiscal Year (FY) 2026.  Today, the FCC released a Public Notice announcing that those regulatory fees must be paid no later than 11:59 PM, Eastern Daylight Time, on September 24, 2026.

In a second Public Notice, the Commission provided more details regarding how to pay those fees.  Fees are due for feeable authorizations granted on or before October 1, 2025.  As in recent years, the fees must be paid electronically through the Commission’s CORES system, which can be found here.  Payments may be made by credit card, debit card, ACH transfer, or wire transfer.  The Commission will not accept payments made by check, money order, or cashier’s check.  There is a $24,999.99 maximum for the use of a credit card.  A larger fee amount cannot be broken into multiple payments of less than $24,999.99 and multiple payments on the same credit card in one day may be aggregated for purposes of hitting that limit.  So those whose fees will exceed $24,999.99 are encouraged to use another payment method.

Early payment is advisable given the large number of submissions to be made on the FCC’s platform in a short period of time, as well as the processing time required for wire transfers or ACH payments, to ensure that payments are processed by the deadline.  Late payments trigger a mandatory 25% penalty, along with interest charges on any unpaid fees.  The FCC will credit partial payments, but any unpaid balances are still subject to the 25% penalty and interest.  Failure to timely pay all regulatory fees can also result in dismissal of pending applications, a stop on all future application processing, and potentially license revocation.

In a third Public Notice issued today, the FCC outlined the procedures licensees should follow if they need to seek relief from regulatory fee obligations by filing a request for waiver, reduction, deferral, or installment payment plan.  Requests citing financial hardship must include supporting documentation sufficient to demonstrate that payment of the fees would impose a financial hardship on the licensee.  Any such filing is due by the payment deadline, as late or unsupported requests are generally denied.