Today, we would normally publish our look back at the prior week’s regulatory activity of importance to broadcasters but, as we noted last week, we are taking this week off and will publish a summary of the regulatory activity during the two week holiday period next Sunday. But, as the start of a new month is upon us, we instead offer our regular look ahead at regulatory dates and deadlines for January.
With each New Year, there are a host of new regulatory deadlines to keep broadcasters busy. In January, this includes some recurring FCC deadlines like Quarterly Issues/Programs lists for all full power broadcasters, and a host of other quarterly obligations that are not as widely applicable. For TV broadcasters, the month brings obligations including the annual children’s television reports on educational and informational programming and a public file certification on commercial limits, as well as the extension to stations in 10 additional markets of the audio description requirements.
In addition to comments in rulemaking proceedings described below, January brings some new obligations. For commercial broadcasters streaming audio programming on the Internet, there are new SoundExchange royalties that cover performances made on and after January 1, and a requirement for a higher minimum fee due at the end of the month. There is also a freeze that will be imposed on applications for major changes by existing LPTV stations and TV translators related to a window that will open in March, the first window in well over a decade for the filing of applications for new LPTV stations.
Let’s look at some of the specific dates and deadlines for broadcasters in January, starting with the routine deadlines that come up every January, and then moving to some of new obligations for 2026. After that we provide January deadlines for comments in rulemaking proceedings (including reply comments on proposed changes to the FCC’s ownership rules and initial comments on proposals to speed the ATSC 3.0 conversion), a look at lowest unit rate windows that open in January for 2026 elections, and finally a few deadlines in early February.
At the beginning of every year, the FCC adds 10 new markets to those in which TV stations, on each programming stream carrying a Top 4 Network (ABC, CBS, FOX, and NBC), must provide audio description of video programming for the visually impaired. The obligation is to provide 50 hours of audio-described programming per calendar quarter, either during prime time or in children’s programming, and 37.5 additional hours of audio description per calendar quarter between 6:00 a.m. and 11:59 p.m. local time. Beginning January 1, TV stations affiliated with a Top 4 Network operating in those Nielsen Designated Market Areas (DMAs) 111 through 120 will be subject to the FCC’s audio description rules. Those markets are: (111) Tyler-Longview, TX (Lufkin & Nacogdoches, TX); (112) Sioux Falls, SD (Mitchell, SD); (113) Fargo, ND; (114) Springfield-Holyoke, MA; (115) Lansing, MI; (116) Youngstown, OH; (117) Yakima-Pasco-Richland-Kennewick, WA; (118) Traverse City-Cadillac, MI; (119) Eugene, OR; and (120) Macon, GA. Top 4 network TV stations in DMAs 1 through 110 are already subject to this obligation. For more information, see the FCC Media Bureau’s reminder about this requirement issued at the beginning of December.
The deadline this month which applies to the most broadcasters is that which arises on the 10th day of the first month in each calendar quarter – the deadline for all full power and Class A TV stations and full power AM and FM radio stations, both commercial and noncommercial, to upload their Quarterly Issues/Program liststo their Online Public Inspection Files (OPIFs). For these lists for the fourth quarter of 2025, that date would be January 10th (but, as that deadline falls on a weekend, the Commission has in the past allowed the upload by the next business day, January 12, though we recommend that uploads be done earlier to avoid last-minute glitches in the OPIF system). The lists should identify the issues of importance to the station’s service area and the programs that the station aired between October 1 and December 31, 2025 that addressed those issues. These lists must be timely uploaded to your station’s OPIF, as untimely uploads of these documents probably have resulted in more FCC fines in the last decade than for any other 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 placed on the Quarterly Issues/Programs list obligation.
January 10 is also the deadline for certain stations to upload to their OPIF any of the following information from the period from October 1 to December 31, if a station has any such information (again, the FCC may allow the upload on January 12, the next business day since the 10th is a weekend, but we suggest an earlier upload to avoid any last minute technical glitches):
- 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 more details on this requirement);
- Class A TV stations’ certification of their continuing eligibility for Class A status; and
- Documentation from full power TV, Class A TV, 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).
Later in the month come routine children’s television obligations for full-power TV and Class A stations. January 30 is the deadline for all commercial full power TV and Class A TV stations to file the Children’s Television Programming Report (Form 2100, Schedule H – formerly Form 398), which details the programming broadcast by a station to meet its obligations to provide educational and informational programming addressing the needs of children during 2024. See our article here on the FCC’s basic requirements for children’s programming, and our articles here and here about this annual filing requirement.
January 30 is also the deadline for each commercial full power TV and Class A TV station to upload to its OPIF records documenting its compliance during 2025 with the limits on the number of commercial minutes that stations can include in children’s programming.
An important date for LPTV and TV translator stations is January 29 at 6:00 p.m., ET – the beginning of the freeze on the filing of all Class A, LPTV, and TV translator station major modification applications. The opportunity for filing major change applications just opened December 18. As we discussed here, the federal government shutdown this year impacted dates during the FCC’s LPTV/ TV Translator filing window that was to have begun in October. This freeze will last until March 19, 12:01 a.m., ET, when Class A, LPTV, and TV translator stations will be permitted to file, on an ongoing basis and without restriction until further notice, any minor or major change applications, any applications for new LPTV and TV translator stations. For more on this process, see our Broadcast Law Blog article here, but be sure to follow the new dates and deadlines as provided here.
For commercial radio broadcasters who stream their programming or other noninteractive programming on the Internet or through other digital devices, January 1 will bring the start of new, higher royalties payable to SoundExchange. All “performances” (a performance being a song played to one listener – so a song heard by 10 listeners would be 10 performances) will now trigger a payment of $.0028. up from $.0025. In addition, payments will be due 30 days after the end of each month, instead of the 45-day period that was in effect in 2025. Finally, on January 31, a commercial broadcaster must make an annual minimum payment for each of their streams of $1100, up from $1000 in 2025. Technically, these rates have not yet been approved by the Copyright Royalty Board, but they have been agreed to in a settlement between NAB and SoundExchange to which there were no objections, so broadcasters should plan on these obligations (see our article here on the settlement). Settlements with CPB for NPR stations, and for a college radio association for webcasting done by educational institutions, are also pending. Rates for other noncommercial broadcasters that stream, including religious broadcasters, will be approved by a Copyright Royalty Board decision that is expected at any time. It was supposed to have been released by December 15, but the government shutdown likely delayed that decision.
There are also numerous rulemaking comment deadlines in January, including reply comment deadlines on the local radio and television ownership rules, a proposal for FCC actions to speed the ATSC 3.0 transition, and several proceedings looking at satellite earth station licensing rules. These deadlines, listed chronologically, are:
January 2 is the deadline for comments responding to the FCC’s Notice of Proposed Rulemaking proposing to facilitate more intensive use of spectrum in the 24 GHz, 28 GHz, upper 37 GHz, 39 GHz, 47 GHz, and 50 GHz bands (the UMFUS bands), which are used by some earth stations, asking for comment on proposals to take actions to facilitate more intensive use of this spectrum. Reply comments are due February 2.
January 5 is the deadline for comments responding to the FCC’s NPRM proposing to auction a portion the Upper C-Band (3.7-4.2 GHz), which is intended to fulfill One Big Beautiful Bill’s mandate that the FCC complete an auction of that spectrum by July 2027. To deal with existing spectrum users, the FCC proposes to define “incumbent earth stations” as those that were operational as of April 19, 2018, and remain operational, were licensed or registered as of November 7, 2018, and timely certified the accuracy of their information on file with the FCC by May 28, 2019 (incumbent earth stations being ones entitled to interference protection or reimbursement during any C-band transition). Reply comments are due February 3.
January 16 is the deadline for reply comments responding to the FCC’s NPRM seeking public comment on 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 the number of radio stations one entity may own, in the largest markets, to at most 8), the Local Television Ownership Rule (limiting an entity to owning two TV stations in a DMA), and the Dual Network Rule (prohibiting 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). We looked at some of the questions in the 2022 Quadrennial Review, including an in-depth look at some of the issues facing the radio industry, in an article on our Broadcast Law Blog here, and on the TV industry, here. Comments were due December 17.
January 20 is the deadline for comments responding to the FCC’s Fifth NPRM on ATSC 3.0, proposing changes to its rules to provide TV stations with additional flexibility during the transition to the new transmission standard. The FCC asked if it should allow stations to determine when to stop broadcasting in ATSC 1.0 or to require continued simulcasting in both standards but with fewer restrictions on the currently required duplication of their ATSC 1.0 and 3.0 signals. The FCC also seeks comments on issues including the use of encryption and digital rights management, requirements for multichannel video programming distributors like cable and satellite TV to support ATSC 3.0 signals, requirements for manufacturers to include ATSC 3.0 tuners in new TVs, and the sunset of ATSC 1.0 service. Reply comments are due February 18.
January 20 is also the deadline (see here, here, and here) for comments responding to the following three FCC NPRMs related to earth station licenses, which used by some broadcasters:
- The FCC’s NPRM proposing changes to its existing regulatory framework for space and earth station licenses, including streamlined application requirements and expedited processing timeframes, extending the license terms for most earth stations, expanding the list of modifications that applicants can make without prior approval, and shifting to a predominantly nationwide blanket licensing approach for earth stations (see our note here).
- The FCC’s NPRM proposing to facilitate more intensive use of spectrum in the 24 GHz, 28 GHz, upper 37 GHz, 39 GHz, 47 GHz, and 50 GHz bands (the UMFUS bands), which are used by some earth stations (see our note here).
- The FCC’s NPRM proposing to auction a portion the Upper C-Band (3.7-4.2 GHz), which is s intended to fulfill Congress’ mandate in the One Big Beautiful Bill that the FCC complete an auction of that spectrum by July 2027 (see our note here).
Reply comments responding to these NPRMs are due February 18.
January 20 is also the deadline for comments responding to the FCC’s Notice of Proposed Rulemaking proposing to facilitate more intensive use of spectrum in the 24 GHz, 28 GHz, upper 37 GHz, 39 GHz, 47 GHz, and 50 GHz bands (the UMFUS bands), which are used by some earth stations.
There is another deadline in January that has broader ramifications for the federal government. Since the longest shutdown in history ended in November, Congress still has not passed a budget bill covering many parts of the federal government, and the “continuing resolutions” to fund the government at last year’s levels will expire January 31—which could result in another partial government shutdown beginning at the end of next month. As we discussed here with the last government shutdown, if a shutdown does occur, some government agencies may have to cease all but critical functions if they do not have any residual funds to continue operations. If no funding is approved, the FCC will announce how any shutdown will affect it, including whether it has any residual funds to keep operating beyond any general funding deadline. Watch for Congressional actions and any FCC announcements to see how any deadlines that apply to your station will be affected by the funding deadline.
With 2026 setting up to be an important election year, broadcasters need to be ready for the windows for lowest unit rates that will apply in the 45 days before a primary election, and 60 days before a general or special election. During these windows, broadcasters must extend to legally qualified candidates their lowest unit rate and continue to follow all other applicable political broadcasting rules. Broadcasters located in Arizona, Arkansas, Delaware, Florida, Georgia, Illinois, Louisiana, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, New Hampshire, New Mexico, New York, North Carolina, North Dakota, Oregon, Tennessee, Texas, Vermont, and Wisconsin should also be aware of the opening of the political windows listed below, tied to state and local primaries and general elections occurring in February and March 2026 – meaning that Lowest Unit Rates apply to advertising sales to candidates and their authorized committees (see our article here on the basics of computing LUR). These LUR windows include ones tied to Congressional races with primaries in March, including those in Texas, Mississippi, North Carolina, and Illinois. 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.
| STATE/ TERRITORY | LUR DATE | ELECTION DATE | ELECTION TYPE |
| Delaware | January 1, 2026 | March 2, 2026 | Municipal Elections (Felton, Kenton, Leipsic, and Middletown) |
| Arkansas | January 2, 2026 | March 3, 2026 | Nonpartisan General Election, School Election |
| Florida | January 2, 2026 | March 3, 2026 | Municipal Elections (Bunnel, Flagler Beach, and Beverly Beach) |
| Maryland | January 2, 2026 | March 3, 2026 | Municipal Election (Millington) |
| Massachusetts | January 2, 2026 | March 3, 2026 | Municipal Election (Wellesley) |
| Missouri | January 2, 2026 | March 3, 2026 | Charter Cities and Counties Elections |
| New Mexico | January 2, 2026 | March 3, 2026 | Municipal Officer Elections (various) |
| Vermont | January 2, 2026 | March 3, 2026 | Municipal Elections (Brattleboro, Colchester, Hartford, Lincoln, North Hero, and Waterbury)/ Town Meeting Day |
| Wisconsin | January 3, 2026 | February 17, 2026 | Municipal Primary Elections |
| Delaware | January 6, 2026 | March 7, 2026 | Municipal Elections (Bridgeville, Frederica, Little Creek, Millville, Milton, and Selbyville) |
| Florida | January 6, 2026 | March 7, 2026 | Municipal Election (Eatonville) |
| Arizona | January 9, 2026 | March 10, 2026 | Local and Municipal Elections (various) |
| Florida | January 9, 2026 | March 10, 2026 | Municipal Election (Atlantis, Apopka, Bay Lake, Belle Glade, Belle Isle, Boca Raton, Boynton Beach, Briny Breezes, City of Greenacres, Cloud Lake, Delray Beach, Edgewood, Glen Ridge, Golf, Gulf Stream, Haverhill, Highland Beach, Hillsboro Beach, Holiday Park, Hypoluxo, Juno Beach, Jupiter, Jupiter Inlet Colony, Lake Buena Vista, Lake Clarke Shores, Lake Park, Lake Worth Beach, Lantana, Lauderhill, Lazy Lake, Lighthouse Point, Longboat, Loxahatchee Groves, Maitland, Manalapan, Magnolia Park, North Palm Beach, Oakland, Ocean Ridge, Okaloosa, Pahokee, Palm Beach, Palm Beach Gardens, Palm Beach Shores, Palm Springs, Pembroke Pines, Riviera Beach, Royal Palm Beach, Sarasota, Sea Ranch Lakes, South Bay, South Palm Beach, Tequesta, Tri-Par Estates Park, Wellington, Westlake, West Palm Beach, Windermere, Winter Garden, and Winter Park) |
| Minnesota | January 9, 2026 | March 10, 2026 | Municipal Elections (LeRay and Rapidan) |
| New Hampshire | January 9, 2026 | March 10, 2026 | Town Elections and SB2 Town Elections |
| Louisiana | January 13, 2026 | March 14, 2026 | Special General Election (Louisiana State Sen., 3rd Senatorial District) |
| North Dakota | January 16, 2026 | March 17, 2026 | Township Elections (various) |
| Tennessee | January 16, 2026 | March 17, 2026 | Municipal Election (Berry Hill) |
| Arkansas | January 17, 2026 | March 3, 2026 | Primary Elections |
| Georgia | January 17, 2026 | March 18, 2026 | Special Election (TBD) |
| New York | January 17, 2026 | March 18, 2026 | Village Elections (Sinclairville and Westfield) |
| North Carolina | January 17, 2026 | March 3, 2026 | General Primary Elections |
| Texas | January 17, 2026 | March 3, 2026 | General Primary Elections |
| Florida | January 23, 2026 | March 24, 2026 | Special General Elections (Florida State Rep. – Districts, 51, 52, and 87/ Florida State Sen. – District 14) |
| Mississippi | January 24, 2026 | March 10, 2026 | General Primary Elections |
| Delaware | January 27, 2026 | March 28, 2026 | Municipal Elections (Farmington and Woodside) |
| Massachusetts | January 27, 2026 | March 28, 2026 | Municipal Election (Arlington) |
| Massachusetts | January 29, 2026 | March 30, 2026 | Municipal Election (Medfield) |
| Delaware | January 30, 2026 | March 31, 2026 | Municipal Elections (Cheswold and Viola) |
| Massachusetts | January 30, 2026 | March 31, 2026 | Municipal Election (Concord) |
| Illinois | January 31, 2026 | March 17, 2026 | General Primary Elections |
Looking ahead to early February, the deadline for Radio and Television Station Employment Units in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma with 5 or more full-time employees need to upload their Annual EEO Public Inspection File Report to their OPIF is February 1 (though, as that is a weekend day, the obligation likely rolls over to the next business day, February 2).
As always, please consult your own legal and technical advisors about these dates and deadlines that we have highlighted to make sure that your advisors share our interpretations, and for other dates of importance that might apply to your stations in the upcoming month.
