January 2025 Regulatory Updates for Broadcasters – Quarterly Issues/Programs Lists, Children’s Television Programming Reporting, Expansion of Audio Description Requirements, Political Windows, and More

By David Oxenford & Keenan Adamchak (Broadcast Law Blog)

As 2024 draws to a close, 2025 is coming into focus, promising significant changes in the Washington broadcast regulatory landscape. With the inauguration of a new President and the appointment of a new FCC chair, who has already signaled plans to implement policies markedly different from those of the current administration (see our discussions here and here), broadcasters are anticipating shifts that could reshape the industry. However, while awaiting these potential changes, there are numerous routine deadlines and obligations that require immediate attention. Here’s a look at what’s ahead in the coming month.

January 10 is the deadline for all full-power and Class A TV stations, as well as full-power AM and FM radio stations, both commercial and noncommercial, to upload their Quarterly Issues/Programs Lists for the fourth quarter of 2024 to their Online Public Inspection Files. These lists must outline the issues of importance to the station’s community and identify the programs aired between October 1 and December 31, 2024, that addressed those issues. Timely submission is critical, as delayed uploads have resulted in more fines over the last decade than any other FCC rule violation. As these lists are the sole official record of a station’s efforts to serve the public and address community needs, it is essential to complete them with accuracy and care. For more on the importance of this requirement, see our article here.

For television broadcasters, January also brings additional compliance deadlines. By January 30, all commercial full-power TV and Class A TV stations must file their Children’s Television Programming Report (Form 2100, Schedule H, formerly Form 398). This report details the programming aired in 2024 to fulfill the station’s obligation to provide educational and informational content for children. In addition, January 30 is the deadline for these stations to upload documentation to their OPIF demonstrating compliance with the FCC’s limits on commercial advertising during children’s programming throughout 2024.

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