Published on:

By , and

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.

Published on:

By and

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.

Published on:

By and

Yesterday, the FCC released its Report and Order adopting a schedule of regulatory fees to cover the Commission’s Fiscal Year 2026 salaries and expenses appropriation of $416,112,000. The Order largely follows the approach set out in the FCC’s April 2026 Notice of Proposed Rulemaking (NPRM), continuing the full-time employee (FTE)-based methodology the FCC has used in recent years and again reallocating certain FTEs from indirect FTEs of the Office of General Counsel, Office of Economics and Analytics, and Public Safety and Homeland Security Bureau, to direct FTEs of various of the core licensing bureaus.

Continue reading →

Published on:

By , and

This advisory is directed to television stations with locally produced programming whose signals were carried by at least one cable system located outside the station’s local service area or by a satellite provider that provided the station’s signal to at least one viewer outside the station’s local service area during 2025. These stations may be eligible to file royalty claims for compensation with the U.S. Copyright Royalty Board. These filings are due by July 31, 2026.

Continue reading →

Published on:

By and

The deadline to file the 2025 Annual Children’s Television Programming Report with the FCC is January 30, 2026, reflecting programming aired during the 2025 calendar year.  In addition, commercial stations’ documentation of their compliance with the commercial limits in children’s programming during the 2025 calendar year must be placed in their Public Inspection File by January 30, 2026.

Overview

The Children’s Television Act of 1990 requires full power and Class A television stations to: (1) limit the amount of commercial matter aired during programs originally produced and broadcast for an audience of children 12 years of age and under, and (2) air programming responsive to the educational and informational needs of children 16 years of age and under.  In addition, stations must comply with paperwork requirements related to these obligations.

Since the Act’s passage, the FCC has refined the rules relating to these requirements a number of times.  The current rules provide broadcasters with flexibility that prior versions of the rules did not in scheduling educational children’s television programming, and modify some aspects of the definition of “core” educational children’s television programming.  Quarterly filing of the commercial limits certifications and the Children’s Television Programming Report has been eliminated in favor of annual filings.

Commercial Television Stations

Commercial Limitations

The FCC’s rules require that stations limit the amount of “commercial matter” appearing in programs aimed at children 12 years old and younger to 12 minutes per clock hour on weekdays and 10.5 minutes per clock hour on the weekend.  The definition of commercial matter includes not only commercial spots, but also (i) website addresses displayed during children’s programming and promotional material, unless they comply with a four-part test, (ii) websites that are considered “host-selling” under the Commission’s rules, and (iii) program promos, unless they promote (a) children’s educational/informational programming, or (b) other age-appropriate programming appearing on the same channel. Continue reading →

Published on:

By and

On August 29, 2025, the FCC released its Report and Order establishing the annual regulatory fees for Fiscal Year (FY) 2025.  The Commission followed that release with a Public Notice announcing that regulatory fees must be paid no later than 11:59 PM, Eastern Daylight Time on September 25, 2025. The fees must be paid for all licenses and initial construction permits granted on or before October 1, 2024.

Continue reading →

Published on:

By , and

The FCC’s rules require that all Emergency Alert System (EAS) Participants update their identifying information in the EAS Test Reporting System (ETRS) annually.  Accordingly, the FCC has released a Public Notice announcing that the deadline for updating and submitting the ETRS Form One for 2025 will be Friday, October 3, 2025.

For broadcasters, EAS Participants include full power radio and TV broadcast stations, including Class D noncommercial educational FM stations, and low power FM stations, program-originating FM booster stations, and low power TV stations that are not operating as TV translators.  Stations must file a Form One even if they are silent pursuant to a grant of Special Temporary Authority.

The following types of stations are exempt from this filing requirement:

  • TV translator stations
  • FM translator or booster stations that only rebroadcast the programming of a local radio station
  • Stations that operate as satellites or repeaters of a hub station (or of a common studio or control point if there is no hub station) which rebroadcast 100% of the programming of that hub station, common studio, or control point.  The hub station, common studio, or control point will still need to file its own Form One, however.

The Public Notice states that the Federal Emergency Management Agency will not be conducting a nationwide test this year, so stations will only be filing a Form One, and not a Form Two or Form Three, which are used when reporting on a national EAS test.  The last nationwide test was conducted nearly two years ago, on October 4, 2023. Continue reading →

Published on:

By , and

This post is directed to television stations with locally-produced programming whose signals were carried by at least one cable system located outside the station’s local service area or by a satellite provider that provided the station’s signal to at least one viewer outside the station’s local service area during 2024.  These stations may be eligible to file royalty claims for compensation with the United States Copyright Royalty Board.  These filings are due by July 31, 2025.

Under the federal Copyright Act, cable systems and satellite operators must pay license royalties to carry distant TV signals on their systems.  Ultimately, the Copyright Royalty Board divides the royalties among those copyright owners who claim shares of the royalty fund.  Stations that do not file claims by July 31, 2025 will not be able to collect royalties for carriage of their owned programming outside their local service area during 2024.

To file a cable royalty claim, a television station must have aired locally-produced programming of its own and had its signal carried outside of its local service area by at least one cable system in 2024.  Television stations with locally-produced programming whose signals were delivered to subscribers located outside the station’s Designated Market Area in 2024 by a satellite provider are also eligible to file royalty claims.  A station’s distant signal status should be evaluated and confirmed by communications counsel. Continue reading →

Published on:

By and

The deadline to file the 2024 Annual Children’s Television Programming Report with the FCC is January 30, 2025, reflecting programming aired during the 2024 calendar year.  In addition, commercial stations’ documentation of their compliance with the commercial limits in children’s programming during the 2024 calendar year must be placed in their Public Inspection File by January 30, 2025.

Overview

The Children’s Television Act of 1990 requires full power and Class A television stations to: (1) limit the amount of commercial matter aired during programs originally produced and broadcast for an audience of children 12 years of age and under, and (2) air programming responsive to the educational and informational needs of children 16 years of age and under.  In addition, stations must comply with paperwork requirements related to these obligations.

Since its passage, the FCC has refined the rules relating to these requirements a number of times.  The current rules provide broadcasters with flexibility that prior versions of the rules did not in scheduling educational children’s television programming, and modify some aspects of the definition of “core” educational children’s television programming.  Quarterly filing of the commercial limits certifications and the Children’s Television Programming Report has been eliminated in favor of annual filings.

Commercial Television Stations

Commercial Limitations

The FCC’s rules require that stations limit the amount of “commercial matter” appearing in programs aimed at children 12 years old and younger to 12 minutes per clock hour on weekdays and 10.5 minutes per clock hour on the weekend.  The definition of commercial matter includes not only commercial spots, but also (i) website addresses displayed during children’s programming and promotional material, unless they comply with a four-part test, (ii) websites that are considered “host-selling” under the Commission’s rules, and (iii) program promos, unless they promote (a) children’s educational/informational programming, or (b) other age-appropriate programming appearing on the same channel.

Licensees must upload supporting documents to the Public Inspection File to demonstrate compliance with these limits on an annual basis by January 30 each year, covering the preceding calendar year.  Documentation to show that the station has been complying with this requirement can be maintained in several different forms.  It must, however, always identify the specific programs that the station believes are subject to the rules, and must list any instances of noncompliance. Continue reading →

Published on:

By

The FCC’s rules require that all Emergency Alert System (EAS) Participants update their identifying information in the EAS Test Reporting System (ETRS) annually.  Accordingly, all EAS Participants must update and submit their ETRS Form One for 2024 by Friday, October 4, 2024.

For broadcasters, EAS Participants include full power radio and TV broadcast stations, low power FM stations, and Class D noncommercial educational FM stations.  Low power TV stations, unless they are operating as a TV translator station, must also submit a Form One.  Stations must file a Form One even if they are silent pursuant to a grant of Special Temporary Authority.

The following types of stations are exempt from this filing requirement:

  • TV translator stations
  • FM translator or booster stations that entirely rebroadcast the programming of a local broadcast radio station
  • Stations that operate as satellites or repeaters of a hub station (or common studio or control point if there is no hub station) and rebroadcast 100 percent of the programming of the hub station (or common studio or control point). Note that the hub station (or common studio or control point) must file a Form One.

While the FCC often ties the deadline for filing the annual Form One to the occurrence of a nationwide EAS test, the Federal Emergency Management Agency and FCC have not announced a national test this year.  As a result, the Form One must be filed independently to satisfy the annual filing obligation.  The most recent nationwide test was held October 4, 2023.  That test was largely successful, with nearly 97 percent of EAS Participants receiving the test message and about 94 percent of Participants successfully relaying the message.  These numbers represent a seven percent increase over the receipt and relay success rates reported for the 2021 test (the last nationwide test conducted prior to 2023).

Form One filers should review the FCC’s Public Notice concerning this filing requirement, as well as the FCC’s ETRS Form One Filing Guide and Frequently Asked Questions for information about using the ETRS, and consult their state’s EAS Plan before responding to the EAS operational area and monitoring assignments prompts.

Filers should be sure to have on hand the FCC username and password associated with the FCC Registration Number(s) (FRN) of the entity(ies) for which they are filing.  Users who have not previously created a username may do so by visiting the User Registration System.  Filers should visit the main ETRS page to file their Form One in advance of the October 4 deadline in case they encounter any filing portal errors and need time to resolve them before the deadline.