Reminder: December 8 Deadline for Compliance with Revised Foreign Sponsorship ID Requirements

The FCC’s foreign sponsorship identification rules for broadcasters have been around for a few years, requiring disclosures when foreign governments or their agents purchase air time on commercial stations. The FCC recently announced the effectiveness of a revised part of the rule allowing stations to optionally use two short “forms” when assessing whether a buyer of program time on the station is a foreign government or agent.  Stations have been using their own certifications until now, with any affirmative responses requiring on-air disclosure and public file uploads.

The Media Bureau’s notice makes December 8, 2025 the effective date for the part of the rule that allows the use of the two forms – one a licensee certification that details the actions taken and attempts to get the programmer to sign a certification, and the other being the programmer certification itself.  When signed by the station or ad buyer, the station enjoys a safe harbor that the buyer is not a foreign agent.  The forms can be found at Appendix C and D of the FCC’s 2024 Order.