FCC Waives Requirement for Broadcasters to File Biennial Ownership Reports for 18 Months
Licensees of commercial and non-commercial full-power television, Class A television, low power television, AM radio, and FM radio stations are usually required to file biennial ownership reports with the Commission in odd-numbered years. The next filing window for biennial ownership reports was scheduled to open on October 2, 2025, with reports due by December 1, 2025. However, in connection with the Commission's proceeding—Delete, Delete, Delete, GN Docket No. 25-133—the Commission has decided to waive the biennial ownership report filing requirement for a period of 18 months and has set a new filing deadline of June 1, 2027, or until further notice, whichever comes first. The Commission agreed with commenters who argued that the biennial ownership report filing requirement is a costly and burdensome requirement without sufficient public benefit. See here.
This decision does not pause the requirement for broadcasters to file ownership reports in connection with other instances required by Section 73.3615 of the Commission's rules, such as after receiving an original construction permit, with an application for a station license, and after the consummation of authorized assignments or transfers of control of permits and licenses.
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If you have any questions, please contact Burt Braverman at burtbraverman@dwt.com or broadcast paralegal Sharon Mathis at sharonmathis@dwt.com.
Disclaimer
This advisory is a publication of Davis Wright Tremaine LLP. Our purpose in publishing this advisory is to inform our clients and friends of recent legal developments. It is not intended, nor should it be used, as a substitute for specific legal advice as legal counsel may only be given in response to inquiries regarding particular situations.
*David Silverman is a contract attorney and former partner of DWT. Broadcast paralegal Sharon Mathis also contributed to this advisory.