Radio and TV Stations located in Indiana, Kentucky, Tennessee, Texas, Delaware and Pennsylvania:  if five (5) full time employee threshold is met, prepare EEO public file report covering the period from ‘April 1, 2025 to March 31, 2026, upload it to the station online public inspection file and post it on the station website

Mid-Term EEO Review for Radio stations located in Delaware and Pennsylvania: if station employment unit has eleven (11) or more full-time employees, an independent mid-term EEO review of the SEU’s last two EEO public file reports by the FCC will occur in connection with the 2025-26 EEO public file report due April 1, and when uploading the report, each station in the SEU must indicate that the SEU has 11 or more full-timers using the “Mid-Term Review” tab is the OPIF settings section.  If the SEU has between five and ten full-time employees, when uploading the 2025-26 report, each station in the SEU should indicate that the SEU has fewer than 11 full-time employees using the “Mid-Term Review” tab in the OPIF settings section (by doing so, no mid-term EEO review of the SEU will take place)

Mid-Term EEO Review for Television stations located in Texas: if station employment unit has five (5) or more full-time employees, an independent mid-term EEO review of the station’s last two EEO public file reports by the FCC will occur in connection with your upload of the 2025-26 EEO public file report due April 1.  By uploading an EEO public file report, the FCC automatically knows that the television station meets the 5 or more full-time employee threshold for a mid-term review. So unlike for radio, there is no OPIF mechanism available or needed for TV stations to specify the number of SEU employees

Specifically, in addition to the candidates themselves and their campaigns, LUC requirements are also applicable to (1) authorized committees, including authorized committees that engage in joint fundraising with legally qualified candidates for federal office, and (2) advertisements that qualify as coordinated expenditures of political parties and legally qualified candidates for federal office.  For determining if a committee is authorized, the FCC relies upon the Federal Election Campaign Act’s “committee” definition as “the principal campaign committee or any other political committee authorized and designated by a candidate to receive contributions or make expenditures on behalf of such candidate.”

The purchase of advertising time by political parties as an independent expenditure is not entitled to LUC because those expenditures involve no coordination between the party and a candidate. But candidate-party coordinated advertisements are subject to the LUC provisions, provided that the ad otherwise complies with other applicable FCC rule requirements.

As a reminder, LUC rates apply during the 60 days prior to general or special elections and 45 days prior to a primary or runoff elections.  Outside of those windows, stations may charge regular advertising rates. Whether sold or airing during or outside of these windows, stations have public file disclosure obligations for the purchase and disposition of political ads.

Among other changes, the order (1) replaced references to FCC legacy filing systems with newer systems, (2) updated rules to correspond to new forms/schedules, (3) updated the AM station power increase rules to eliminate the requirement that stations seeking facility modifications request at least a 20% increase in power, and to reflect current AM station classifications, (4) modified LPFM rules so that LPFM applicants must protect FM, LPFM and FM translator applications submitted prior to LPFM filing windows, (5) modified the “Signature” rule to authorize not just officers, but also “duly authorized employees” and directors to sign applications, (6) clarified local notice requirements, and (7) removed language limiting special temporary authority to 90 days.

Still pending in the Delete Delete proceeding are numerous proposals to modify or eliminate more substantive rules such as the public file rule, EEO rules, and others.  The ownership reporting rule could be revised later this year to codify the temporary waiver of the biennial report filing requirement into a permanent deletion. For the moment, biennial ownership reporting is suspended through June 1, 2027.

According to the notice, “many sporting events that were previously available through free broadcast and traditional pay TV packages are now only available through a myriad of stand-alone subscription streaming services. This shift has led to notable frustration among many consumers and sports fans” who must navigate a “fragmented ecosystem” that requires “multiple subscriptions to watch live sports programming or their favorite teams.”

The notice asks for comment on the extent current sports media rights contracts conflict with or impede broadcasters from meeting their public interest obligations and how the arrangements should be considered in the context of broadcasters’ public interest obligations.  The “public interest” continues to be a major theme for Chairman Carr as he attempts to restore an emphasis on and prioritization of service to local communities and viewers.

In one instance, the FCC’s regional personnel in the Dallas, Texas office inspected a tower that needed painting and was out of compliance, requiring a response within 20 days.  In another, the Bureau’s New York office inspected four towers and found numerous violations, including painting, lighting, RF emissions, dense brush/vegetation at the base of towers, and lack of operational EAS equipment.

Tower owners are charged with compliance for the safety of air flight in connection with tower operations.  The notices of violation allow those cited to respond with an explanation but based upon the facts described in the notices, it seems likely that the tower owners will eventually be ordered to pay fines to the U.S. Treasury.

While estimates vary, well over 1,000 applications were filed on March 19^th.  The FCC has not yet begun to process the applications, as time still remains to remit filing fees associated with the filings.  The Media Bureau has not published any specific outline of processing steps for applications that are mutually exclusive with one another, but may do so in coming days.

Class A, LPTV, TV Translator minor change applications filing freeze begins 6p ET. Application for new LPTV and TV translator applications should be available as of this date also.

March 19, 2026

Class A, LPTV, TV Translator major change applications resume, minor change freeze is lifted, and acceptance of applications for new LPTV and TV translator stations begins 12:01 am ET

April 1, 2026

Radio and TV Stations located in Indiana, Kentucky, Tennessee, Texas, Delaware and Pennsylvania:  if five (5) full time employee threshold is met, prepare EEO public file report covering the period from ‘April 1, 2025 to March 31, 2026, upload it to the station online public inspection file and post it on the station website

Mid-Term EEO Review for Radio stations located in Delaware and Pennsylvania: if station employment unit has eleven (11) or more full-time employees, an independent mid-term EEO review of your last two EEO public file reports by the FCC will occur in connection with the 2025-26 EEO public file report due April 1, and when uploading the report, each station in the SEU must indicate that the SEU has 11 or more full-timers using the “Mid-Term Review” tab is the OPIF settings section.  If the SEU has between five and ten full-time employees, when uploading the 2025-26 report, each station in the SEU should indicate that the SEU has fewer than 11 full-time employees using the “Mid-Term Review” tab in the OPIF settings section (by doing so, no mid-term review of the SEU will take place)

Mid-Term EEO Review for Television stations located in Texas: if station employment unit has five (5) or more full-time employees, an independent mid-term EEO review of your last two EEO public file reports by the FCC will occur in connection with your upload of the 2025-26 EEO public file report due April 1.  By uploading an EEO public file report, the FCC automatically knows that your television station meets the 5 or more full-time employee threshold for a mid-term review. So unlike for radio, there is no OPIF mechanism available or needed for TV stations to specify the number of SEU employees

The certification form itself is not yet available and will need to be approved by the Office of Management & Budget before it becomes due. Once OMB approves, the FCC will issue a public notice announcing the launch of the new system, and stations will have 60 days (120 days for smaller entities) to submit their first certification. The timing of future certifications will depend on the characteristics of filing entities, earlier certification submission disclosures, or the addition of new foreign adversaries to the defined list.

Broadcasters that answer “yes” to the certification will also have to disclose any program lease agreements with the applicable foreign adversary.  State or local government and Tribal Nation broadcast licensees are exempt from the new certification filing requirements. Stations not filing the certifications or inaccurately filing the certifications will be subject to a streamlined license revocation proceeding.

Based on the tight comment deadlines, we anticipate that the FCC will vote on this item at its April meeting, which will give the FCC’s Media Bureau a green light to issue a public notice announcing filing window dates and procedures. For your planning purposes, our educated guess is that we’ll see the Media Bureau’s notice sometime in May with a filing window in July or August.  Applications will require certification of various matters to be decided using a points system.

The application form for new LPTV and TV translator stations will not become available in LMS until approximately a week or so before the March 19, 2026 start date for such applications. But, in the interim, stations filing applications of any kind should secure their engineering exhibits and reasonable tower assurance so they are ready to file applications on March 19^th or when desired.

All the prior filing opportunities and the new ones beginning on March 19 are using a first-come, first-served daily cutoff procedure, meaning all applications filed on the same day will have priority over applications filed on the following day or days.