Children’s Television Reporting Due by January 30, 2026

The surest way for full power and Class A television stations to have issues with license renewal is to forget or incorrectly report compliance with the FCC’s children’s television rules.  The renewal application contains important certifications about station compliance with the rule limiting the amount of commercial matter during children’s programming targeting children 12 years old and under, and the separate rule requiring stations to air particular amounts of children’s educational/informational programming targeting children 16 years old and younger.

Both rules have an annual reporting obligation with the same deadline – January 30^th.  By that date, stations must upload into their public file supporting material certifying compliance with commercial limits for the prior calendar year, and complete and file a children’s television programming report reflecting adequate amounts of children’s E/I programming aired during the prior calendar year.

The commercial limits rule prohibits stations from airing more than 10.5 minutes of commercial matter during children’s programming on weekends, or more than 12 minutes during weekdays.  A certification and any other supporting documentation must be uploaded to the public file by the January 30 deadline.  Violations can occur if more than the allowed commercial matter is aired, or if the commercial matter is related to an adjacent program (i.e., a Hot Wheels ad aired during a Hot Wheels cartoon), in which case the entire program is considered commercial matter.

For the children’s television E/I programming rule, a form must be completed and submitted in the License Management System by January 30 reporting the total number of children’s E/I programming hours aired and how much on each channel. The form is intensive, so best to start working on it now.  While stations are obligated to air a minimum of 156 hours of children’s E/I programming annually on their main channel, there are scenarios that allow stations to shift a percentage of E/I programming to secondary digital channels each quarter.  Stations should pay close attention to the criteria in rule 73.671(c) that must be satisfied in order for a program to qualify as educational/informational.  Coming up short on the required number of hours gets a station further scrutiny, and unless other reported activities can “count” toward educational opportunities for children, the FCC staff must elevate the renewal application to the full Commission for further action, and potential fines. Several station renewals from the prior renewal cycle remain pending, awaiting Commission action.

We are available to assist stations in preparing or reviewing the form before submission. We encourage completion of these children’s television requirements well in advance of the January 30 deadline, as OPIF and LMS slow down and malfunction when filings are crammed into the final day. The other reason to complete these early is the looming possibility that a new government shutdown at the end of January is possible, which would make OPIF and LMS unavailable.