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.
December 1 is also the deadline for the filing of the Annual DTV Ancillary/Supplementary Services Report for the 12-Month Period Ending on September 30, 2025, and the submission of any payments that are due. This applies to commercial and noncommercial full-power TV stations, Class A TV stations, and LPTV stations (including those operating with FM broadcasts on Channel 6) that have fee-based, non-broadcast revenues from their digital transmission capabilities. This means that if TV stations earned fees for data transmission or other non-broadcast services, they must file the report and pay the fees. If they did not, the report is not required.
December 1 is also the deadline for radio and television station employment units in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont with 5 or more full-time employees to upload their Annual EEO Public File Report to their stations’ OPIFs. 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 5 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.
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. The Mid-Term EEO Review begins December 1 for these larger radio station employment units in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont. Radio stations located in those states 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 need a Mid-Term EEO Review. Television station employment units in Colorado, Minnesota, Montana, North Dakota, and South Dakota are also subject to a Mid-Term review but, as all TV stations subject to the requirement for the filing of an annual report (those with five or more full-time employees) are also subject to the Mid-Term review, no checkbox in the public file is required for TV. See our articles here and here for more on the Mid-Term EEO Review.
Following the end of the government shutdown, political file uploads that could not be made between October 1 and November 12 due to the shutdown are now due in December on a staggered basis, apparently to avoid an overload of the FCC’s public file system. As set forth in this Public Notice, the December filing windows for stations to upload their outstanding political file documents are as follows:
| Filling Window | Affected Licensees by State |
| December 1-8 | Licensees located in Virginia, Maryland, West Virginia, and the District of Columbia |
| December 9-16 | Licensees located in California |
| December 17-24 | Licensees in all other states and territories |
Station licensees located in New York, New Jersey, and Connecticut had between November 19 and November 26to upload their outstanding political file documents.
December 5 is the extended deadline for all broadcast stations with Special Temporary Authority (STA) that expired between October 1 and December 4 to file either an STA Extension Request or Resumption of Operations Notification.
December 8 is the deadline for broadcasters to begin complying with the FCC’s new foreign sponsorship identification rules adopted by the FCC in a June 2024 Report and Order, which expanded the requirement that broadcasters determine whether those who “lease” program time on their stations are foreign government agents and, if so, imposed enhanced sponsorship identification requirements (see our discussion here). In June 2025, the Media Bureau announced that June 10 was the effective date of the FCC’s new broadcast foreign sponsorship identification rules, but broadcasters did not need to comply with the new rules until December 8 (see our discussion here). Broadcasters have two options to show that they checked whether a lessee’s programming is sponsored by a “foreign governmental entity”: (1) both the station and the lessee must execute written certifications using standardized language, the lessee certifying that they are not acting on behalf of a foreign government and the licensee certifying that they explained this requirement to the lessee; or (2) the station must ask the lessee to provide screenshots of the search results for the lessee’s name in the Department of Justice’s Foreign Agent Registration Act database and the FCC’s most recent U.S.-based foreign media outlet report. The new requirement does not apply to commercial spots or political candidate advertisements, but the Commission has expanded the obligation to verify whether the sponsor is a representative of a foreign government so that it applies not just to those who provide program time to a station, but also to sponsors of political issue ads and paid PSAs. There are no exemptions from these requirements for religious or locally produced programming.
Comments and reply comments are due December 10 and December 24, respectively, responding to the FCC Media Bureau’s Public Notice seeking comment on the relationship between national TV networks and their affiliated local TV stations. The Bureau states that it is seeking to identify barriers that may be preventing local TV stations from meeting their public interest obligations and responding to the needs of their local communities. Specifically, the Bureau seeks comment on issues including the current status of the relationship between networks and their affiliates, whether their relative bargaining positions have changed in recent years, whether network affiliation agreements impede local affiliates’ ability to maintain control over station programming, whether national programmers are punishing local affiliates for exercising their right to preemption of network programming, and the extent to which networks use their positions in the market to unduly influence the terms of network affiliation agreements. The Bureau also asks whether the FCC should initiate a rulemaking proceeding to update its rules on network-affiliate relations and, if so, what network practices should be prohibited by any new rules.
The shutdown has also impacted dates during the FCC’s LPTV/TV Translator Window that was to have opened in October for major changes in the channel and site of LPTV and TV Translator stations. See this Public Notice for details. The new December dates for these filings are as follows:
- December 11, 2025, 6:00 p.m. ET: Temporary application filing freeze implemented on all minor change applications (including displacement applications) for Class A, LPTV, and TV translator stations. Minor change applications filed once the freeze is imposed will be dismissed and need to be re-filed after the freeze is lifted.
- December 18, 2025, 12:01 a.m. ET: Major modification filing freeze lifted to permit Class A, LPTV, and TV translator stations to file major change applications, on a first come, first served basis. Facility relocations are limited to no more than 121 kilometers (km), which is about 75 miles. Major change applications submitted during this filing opportunity must meet the 121 km distance limit and otherwise comply with the FCC’s rules. All other applications will be dismissed. Also on December 18, the freeze will be lifted on all minor change applications (including displacement applications) for Class A, LPTV, and TV translator stations.
December 17 is the deadline for comments responding to the FCC’s September Notice of Proposed Rulemaking initiating its 2022 Quadrennial Review of its media ownership rules. Congress requires the FCC to review its media ownership rules every 4 years to determine whether, as result of competition, they remain necessary, and to repeal or modify any rule that the FCC determines is no longer in the public interest. The NPRM seeks comment on whether the FCC should repeal or modify the Local Radio Ownership Rule (which limits in the largest markets the number of radio stations an entity may own to at most 8), the Local Television Ownership Rule (limiting an entity to owning no more than two TV stations in any DMA), and the Dual Network Rule (which prohibits TV stations from affiliating with an entity owning two or more networks – effectively barring mergers among the “Big Four” broadcast networks: ABC, NBC, CBS, and Fox). Reply comments are due January 16.
Before political windows open for the many 2026 primaries and elections, broadcasters located in Alabama, Delaware, and Minnesota should be aware of the opening of the political windows listed below tied to state and local elections occurring in February 2026 – meaning that Lowest Unit Rates apply to sales to candidates for these offices and their authorized committees (see our article here on the basics of computing LUR). Broadcasters should also check to see if there are any other special elections that we have missed that may be occurring in December and early next year, where political windows may be open.
| STATE | LUR DATE | ELECTION DATE | ELECTION TYPE |
| Alabama | December 5, 2025 | February 3, 2026 | State House District 38 Special General Election |
| Delaware | December 9, 2025 | February 7, 2026 | Municipal Election – Frankford |
| Minnesota | December 20, 2025 | February 3, 2026 | Precinct Caucus |
| Delaware | December 23, 2025 | February 21, 2026 | Municipal Election – Bethel |
| Delaware | December 30, 2025 | February 28, 2026 | Municipal Elections – Camden and Wyoming |
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.
Looking ahead to January 2026, radio broadcasters and others streaming their signals on the Internet should be aware that new rates for payments to SoundExchange become effective on January 1. Rates for broadcasters for 2026 through 2030 were agreed to in a settlement between the NAB and SoundExchange (see our article here for more details). There have been various other settlements filed with Copyright Royalty Board for approval, and the CRB is supposed to release a decision by December 15 as to rates for parties that have not settled. But these settlements have not yet been approved, and these approvals, and the expected CRB decision, could be delayed as a result of the shutdown. Yearly minimum fees payable to SoundExchange are also due in January for most webcasters.
Also in early January, licensees of full-power TV/AM/FM stations and Class A TV stations need to remember that Quarterly Issues/Programs lists are to be uploaded to their stations’ OPIFs by January 10. The lists should identify the issues of importance to the station’s community and the programs that the station aired in October, November, and December that addressed those issues. 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 service area. See our post here for more on the importance of the Quarterly Issues/Programs list obligation.
An extension of the FCC’s audio description rules will take effect on January 1 for TV stations affiliated with the Top 4 Networks (i.e., ABC, CBS, Fox, and NBC) operating in Nielsen Designated Market Areas (DMAs) 111 through 120: (111) Sioux Falls (Mitchell), SD; (112) Johnstown-Altoona-State College, PA; (113) Fargo-Valley City, ND; (114) Yakima-Pasco-Richland-Kennewick, WA; (115) Springfield-Holyoke, MA; (116) Traverse City-Cadillac, MI; (117) Lansing, MI; (118) Youngstown, OH; (119) Macon, GA; and (120) Eugene, OR. In 2023, the FCC expanded its audio description requirements to Top 4 Network-affiliated TV stations operating in DMAs 101 through 210 beginning with DMAs 91-100 on January 1, 2024, and ending with DMAs 201-210 on January 1, 2035 (see our discussion here). Audio description provides narrated descriptions of a television program’s key visual elements during natural pauses in the program’s dialogue, for the benefit of individuals who are blind or visually impaired.
Enjoy your holidays and, as always, consult your own legal and technical advisors for other dates of importance that might apply to your stations in the upcoming month.
