April 2026 Regulatory Dates for Broadcasters – EEO Public File Reports, Comment Deadlines, Quarterly Issues/Programs Lists, Political Windows, and More

With April showers come routine regulatory dates for broadcasters, including the requirement for posting Quarterly Issues/Programs Lists to the Online Public Inspection Files of all full-power radio and TV stations, and EEO Public File Reports for stations in a number of states.  Among the other dates in April is the reply comment deadline in the FCC’s inquiry on the sports broadcasting marketplace.  We also note lowest unit rate windows that open this month.  So here is a look at some of the most significant dates and deadlines for broadcasters in April. 

April 1 is the deadline for radio and television station employment units in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas 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 with 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 can lead to 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 by radio station employment units with eleven more full-time employees or TV station employment units with five or more employees triggers a Mid-Term EEO Review that analyzes the last two Annual Reports for compliance with the FCC’s EEO requirements.  The Mid-Term EEO Review begins April 1 for these larger radio station employment units in Delaware and Pennsylvania.  TV station employment units in Texas are also subject to this review.  Additionally, radio stations located in Delaware and Pennsylvania that are part of station employment units with five or more full-time employees must also indicate in their OPIFs whether their employment unit has eleven more full-time employees, using a checkbox now included in the EEO folder of each station’s OPIF.  This allows the FCC to determine which station groups need a Mid-Term EEO Review.  See our articles here and here on radio stations’ Mid-Term EEO Review reporting requirements.

April 10 is the deadline for all full power and Class A television stations and commercial and noncommercial full power AM and FM radio stations to upload their Quarterly Issues/Program lists for the first quarter of 2026 to their OPIFs.  The lists should identify the issues of importance to the station’s community and the programs that the station aired between January 1 and March 31, 2026, 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 of the Quarterly Issues/Programs list obligation.

April 10 is also the deadline for certain stations to upload to their online public file any of the following information from the period from January 1 to March 31, 2026, if a station has any such information:

  • documentation from noncommercial educational stations not affiliated with NPR or CPB of any on-air fundraising benefitting third parties that interrupted their normal programming (see our article here for a further explanation of this requirement),
  • documentation by Class A television of their continuing eligibility for Class A status, and
  • documentation from full power television, Class A television, and full power radio stations of any programming time that was leased by a foreign government or an agent of a foreign government or provided by a foreign entity for free in exchange for its airing (see our articles here and here for more information).

April 11 is the deadline for all U.S.-based foreign media outlets which would be classified as “an agent of a foreign government” under the Foreign Agents Registration Act to notify the FCC of their relationship to, and whether the outlet receives any funding from, a foreign government or political party.  This requirement applies to companies providing video programming to cable and satellite television systems.  The FCC must report to Congress every six months on the operations of these U.S.-based foreign media outlets.

April 13 is the deadline for reply comments responding to the FCC Media Bureau’s Public Notice concerning the status of the sports broadcasting marketplace.  The Bureau seeks comments on the impact of sports programming marketplace changes on consumers and broadcasters, whether sports media contracts impact broadcasters’ ability to meet their public interest obligations, streaming platforms’ impact on broadcasters’ ability to obtain sports programming rights, specifics of agreements for the rights to cover sports, and the authority of the FCC to ensure continued viewer access to live sports.  See our article here for more on the Bureau’s request for comments.

Broadcasters located in Alabama, California, Delaware, Florida, Georgia, Idaho, Iowa, Kentucky, Louisiana, Maine, Mississippi, Montana, Nevada, New Jersey, New Mexico, North Dakota, Oregon, Pennsylvania, South Carolina, South Dakota, and Tennessee should also be aware of the opening of political windows tied to state and local elections occurring in April, May, and June 2026—meaning that Lowest Unit Rates apply to sales to candidates and their authorized committees.  As noted in our last two monthly updates (here and here), there are already LUR windows open in a number of states for elections in April and May. See our article here on the basics of computing LUR.  The windows opening in April are set out below:

STATE/ TERRITORY LUR DATE ELECTION DATE ELECTION TYPE
Louisiana April 1, 2026 May 16, 2026 Municipal and Party Primary Elections
Delaware April 3, 2026 June 2, 2026 Municipal Election (Bellafonte)
Mississippi April 3, 2026 June 2, 2026 Mississippi Levee Board General Election
Tennessee April 3, 2026 June 2, 2026 Municipal Election (Livingston)
Alabama April 4, 2026 May 19, 2026 General Primary Elections
Georgia April 4, 2026 May 19, 2026 General Primary Elections
Idaho April 4, 2026 May 19, 2026 General Primary Elections
Kentucky April 4, 2026 May 19, 2026 General Primary Elections
Oregon April 4, 2026 May 19, 2026 General Primary Elections
Pennsylvania April 4, 2026 May 19, 2026 General Primary Elections
Tennessee April 5, 2026 June 4, 2026 Municipal Election (Parsons)
Florida April 8, 2026 April 21, 2026 Runoff Election (Municipal Election on April 7, 2026: Frostproof)
April 8, 2026 May 5, 2026 Runoff Elections (Municipal Elections on April 7, 2026: Bartow, Davenport, Dundee, Haines City, Lake Hamilton, and Mulberry)
April 8, 2026 May 26, 2026 Runoff Election (Municipal Election on April 7, 2026: Plant City)
April 10, 2026 June 9, 2026 Municipal Election (Greenwood)
Delaware April 14, 2026 June 13, 2026 Municipal Election (Millsboro)
Tennessee April 17, 2026 June 16, 2026 Municipal Election (Brownsville)
California April 18, 2026 June 2, 2026 General Primary Elections
Iowa April 18, 2026 June 2, 2026 General Primary Elections
Montana April 18, 2026 June 2, 2026 General Primary Elections
New Jersey April 18, 2026 June 2, 2026 General Primary Elections
New Mexico April 18, 2026 June 2, 2026 General Primary Elections
South Dakota April 18, 2026 June 2, 2026 General Primary Elections
Florida April 22, 2026 May 19, 2026 Runoff Elections (Municipal Elections on April 21, 2026: Mexico Beach and Springfield)
Tennessee April 24, 2026 June 23, 2026 Municipal Election (Maynardville)
Maine April 25, 2026 June 9, 2026 General Primary Elections
Nevada April 25, 2026 June 9, 2026 General Primary Elections
North Dakota April 25, 2026 June 9, 2026 General Primary Elections
South Carolina April 25, 2026 June 9, 2026 General Primary Elections
Tennessee April 26, 2026 June 25, 2026 Municipal Election (Plainview)
Florida April 29, 2026 May 12, 2026 Runoff Election (Municipal Election on April 28, 2026: Quincy)

As a refresher, in the 45 days before a primary election, and 60 days before a general or special election, broadcasters must extend to legally qualified candidates their lowest unit rate and continue to follow all other applicable political broadcasting rules.  For a deeper dive on how to prepare for the 2026 elections, see our post here, which also includes a link to our comprehensive Political Broadcasting Guide.  Also, take a look at our 2026 Broadcasters’ Calendar to see if your state has any upcoming primary, general, or special election (and confirm that all dates for political windows, including those listed above, are accurate as some dates have changed since the calendar was prepared).

As always, consult your own legal and technical advisors for other dates of importance that might apply to your stations in the upcoming month.