Although many, including Congress, take the last of their summer vacations in August, there are still many dates to which broadcasters should be paying attention this month. One deadline that most commercial broadcasters should be anticipating is the FCC’s order that will set the amount of their Annual Regulatory Fees, which will be paid sometime in September before the October 1 start of the federal government’s new fiscal year. As we noted here, the FCC proposed to decrease fees this year for broadcasters from the amounts paid in prior years. Also, as we noted here, the FCC has adopted a new regulatory fee calculation methodology for earth stations. Watch for the announcement of the final amounts for the Annual Regulatory Fees, along with an announcement of the deadline for their payment. These announcements usually come in late August or in the first few days of September.
Here are some of the other regulatory deadlines this month:
August 1 the deadline for radio and television station employment units in California, Illinois, North Carolina, South Carolina, and Wisconsin with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ Online Public Inspection Files. A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having 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 has in the past lead to significant FCC fines (see our article here about a recent $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 or more full-time employees or TV stations 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. TV station employment units inIllinois and Wisconsin, who were to file their reports by August 1, are subject to this mid-term review. Larger radio station employment units in California are also subject to the mid-term review. Radio stations in California 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 or more full-time employees, using a checkbox now included in the OPIF’s EEO folder. This allows the FCC to determine which station groups are subject to the Mid-Term EEO Review. See our articles here and here on these reporting requirements.
There are a number of comment deadlines in FCC proceedings in August. August 4 is the deadline for comments responding to the FCC’s Public Notice seeking to refresh the record in the National Television Multiple Ownership Rule proceeding. In December 2017, the FCC released a Notice of Proposed Rulemaking seeking comment on whether to retain, modify, or eliminate the national television ownership cap (prohibiting attributable ownership interests in broadcast TV stations that reach more than 39% of the TV households nationwide), and the UHF discount (a 50% discount for UHF stations in calculating compliance with the 39% cap). On our Broadcast Law Blog, we took a closer look at the Public Notice and how it related to other potential changes to the FCC’s broadcast ownership rules. Reply comments are due August 22.
August 19 is the deadline for reply comments responding to the FCC’s Notice of Proposed Rulemaking proposing to require certain FCC-regulated entities and auction applicants, including all broadcast licensees and permittees, to file a certification stating if they are owned or controlled by a foreign adversary. As we noted here and here, the FCC proposes to define foreign adversaries as the Peoples’ Republic of China, Cuba, Iran, North Korea, Russia, and Venezuela. Entities certifying yes would need to disclose all ownership interests of 5% or more held by a foreign adversary (including interests held by their citizens or companies organized under their laws). The FCC proposes to revoke FCC authorizations for entities filing false or incomplete certifications or for failing to file certifications after being warned that they missed the compliance deadline. For broadcasters, the FCC seeks comments on whether to use the broadcast ownership rules’ attribution criteria to determine a foreign adversary’s attribution to a broadcaster, and whether to make any changes to the existing foreign sponsorship identification rules to require additional disclosures when foreign adversaries provide station programming. Comments were due July 21.
August 22 is the deadline for reply comments responding to the FCC’s April NPRM proposing updates to its foreign ownership rules under Section 310(b) of the Communications Act of 1934 applicable to many FCC licensees, including broadcasters. Section 310(b) prohibits foreign entities, individuals, and governments from holding ownership interests of more than 20% in an FCC licensee and ownership interests of more than 25% in a U.S. entity that directly or indirectly controls an FCC licensee. FCC licensees, however, can ask the FCC to approve foreign ownership interests above the 25% threshold. We provide more details about this NPRM in our note here. Comments were due July 23.
In past monthly updates, we have noted certain Lowest Unit Rate windows for primaries or elections to be held in August, so be aware of any elections that might be occurring in your state this month. We have also noted LUR windows for special Congressional elections in Virginia and in Arizona to fill vacant seats in the US House of Representatives. In Virginia’s 11th District, an election to fill the vacant seat will be held on September 9, so stations serving that District have an LUR Window that opens on July 11th. In the Arizona 7th District, the special election to fill the seat will be held on September 23, meaning that the Window will open on July 25th. Broadcasters located in Alaska, Delaware, Louisiana, Maryland, Massachusetts, North Carolina, and Tennessee should also be aware of the opening of the following political windows tied to state and local elections occurring in September and October – meaning that Lowest Unit Rates apply to sales to candidates and their authorized committees (see our article here on the basics of computing LUR):
| LUR DATE | STATE | ELECTION DATE | ELECTION TYPE |
| August 2, 2025 | Maryland | September 16, 2025 | Municipal Primary Election – Annapolis |
| August 5, 2025 | Tennessee | October 4, 2025 | Municipal Election – Centerville |
| August 7, 2025 | Delaware | October 6, 2025 | Municipal Election – Delmar |
| August 8, 2025 | Alaska | October 7, 2025 | Regional Educational Attendance Area (REAA) Elections |
| August 9, 2025 | Massachusetts | September 23, 2025 | Municipal Primary Election – Boston |
| August 23, 2025 | North Carolina | October 7, 2025 | Municipal Primary Elections – Durham, Hickory, and Mooresville |
| August 27, 2025 | Louisiana | October 11, 2025 | State Primary Election/Municipal Primary Election – Orleans |
| August 29, 2025 | Tennessee | October 28, 2025 | Municipal Election – Franklin |
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 2025 elections, see our post here, which also includes a link to our comprehensive Political Broadcasting Guide. Also, take a look at our 2025 Broadcasters’ Calendar to see if your state has any upcoming primary, general, or special election (though confirm these dates locally 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.
