October 2026 Regulatory Dates for Broadcasters – Quarterly Issues/Programs Lists; EAS Test Form One; Annual EEO Public File Reports; EEO Audit Responses; Filing Freeze on FM Translators; and more

October is another busy month of regulatory dates and deadlines for broadcasters.  Unlike previous years, there is no threat of a federal government shutdown on its October 1 start of the new fiscal year, so the dates and deadlines discussed below should not move on broadcasters.  As we detail below, all stations will need to observe EAS reporting requirements for the filing of ETRS Form One in anticipation of the upcoming Nationwide EAS Test, and all full-power stations need to remember the Quarterly Issues Programs list filing deadline.  While there always can be an October surprise, we take a look below at these and other significant dates and deadlines in the coming month. 

October 1 is the deadline for radio and television station employment units in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Missouri, Northern Mariana Islands, Oregon, Puerto Rico, the U.S. Virgin Islands, and Washington with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ Online Public Inspection Files (OPIFs).  A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having at least one common employee.  For employment units with five or more full-time employees, the annual report covers hiring and employment outreach activities for the prior year.  A link to the uploaded report must also be included on the home page of each station’s website, if the station has a website.  Be timely getting these reports into your station’s OPIF, as even a single late report has in the past led to significant FCC fines (see our article here about a $26,000 fine for a single late EEO report).

The filing of the Annual EEO Public File Reports triggers the Mid-Term EEO Review beginning October 1 for TV station employment units with five or more employees in Alaska, American Samoa, Guam, Hawaii, Northern Mariana Islands, Oregon, and Washington.  The Mid-Term EEO Review that analyzes the last two Annual EEO Public File Reports for compliance with the FCC’s EEO requirements.  See our articles here and here on stations’ Mid-Term EEO Review reporting requirements.

October 1 is also the deadline for all full-power TV and “qualified” Class A TV stations (those few Class A TV stations in areas without other television service that are entitled to MVPD carriage rights) to place in their OPIF notice of whether they elect retransmission consent or must-carry carriage from their area’s MVPDs for the upcoming three-year cycle beginning on January 1, 2027, and ending December 31, 2029.  If the station has decided to change its election from prior years, it must notify the MVPD by email, to an address set out in the MVPD’s public file.  We wrote about the FCC’s adoption of these requirements here.

A filing freeze begins at 11:59 p.m. ET on October 2 for all reserved and non-reserved band LPFM, FM translator, and FM booster station minor modification applications.  As we noted here and here, the filing freeze is being implemented to accommodate the upcoming filing window for new noncommercial educational FM translators in the reserved band (88.1-91.9 MHz).  The filing window for new NCE translators will begin on November 4 and end at 6:00 p.m. ET on November 17, at which time the filing freeze will also end.

October 11 is the deadline for all U.S.-based foreign media outlets classified as “an agent of a foreign government” under the Foreign Agents Registration Act to notify the FCC of their relationship to, and whether the outlet receives any funding from, a foreign government or political party.   This requirement applies to companies providing video programming to cable and satellite television systems. The FCC must report to Congress every 6 months on the operations of U.S.-based foreign media outlets, with the next report due on or before November 11.

October 13 is the deadline by which all full-power radio and TV stations (as well as Class A television stations), both commercial and noncommercial, must upload to their OPIFs their Quarterly Issues/Program lists for the third quarter of 2026.  The lists should identify the issues of importance to the station’s community and the programs that the station aired between July 1 and September 30, 2026 that addressed those issues.  It is important that these be uploaded timely to your public file, as late uploads of these documents probably have resulted in more fines in the last decade than any other violation of the FCC’s rules.  As you finalize your lists, do so carefully and accurately, as they are the only official records of how your station is serving the public and addressing the needs and interests of its community.  See our article here for more on the importance of the Quarterly Issues/Programs lists.

October 13 is also the deadline for certain stations to upload to their OPIF any of the following information from the period from July 1 to September 30, 2026, if a station has any such information:

October 19 is the deadline for comments responding to XGN/X1 Mobile and Tyche Media’s petition for rulemaking requesting that the FCC allow LPTV stations to use the 5G Broadcast transmission standard as an alternative to the ATSC 1.0 and 3.0 transmission standards.  The petition proposes authorizing deployment of the 5G Broadcast standard on a voluntary basis.    The proposal would require that 5G Broadcast stations offer a high-quality linear free-to-air stream, and it would prohibit any LPTV station qualifying for mandatory MVPD carriage from implementing 5G Broadcast operations. Reply comments are due November 18. 

October 20 is the deadline for the 400 radio and TV stations listed in the FCC Enforcement Bureau’s 2026 EEO Audit Letter to upload their EEO Audit Responses to their OPIFs (questions addressing DEI issues must be emailed directly to FCC staff).  See our article here about the FCC’s 2025 EEO audit that first included these questions targeting DEI practices.  The FCC randomly audits approximately 5% of all broadcast stations each year regarding their EEO compliance.  Audited stations and their station employment units must provide to the FCC their last 2 years of EEO Annual Public File Reports and documents showing that the stations followed the FCC’s EEO rules.  The FCC staff will review the audit responses and ask for more information if they find that the response is incomplete, but they will not inform audited stations that their EEO performance was found satisfactory.  See our articles here and here for more detail on EEO audits and how seriously the FCC takes broadcasters’ EEO obligations.

October 30 is the deadline for EAS participants, including broadcasters, to file their Form One in the FCC’s Emergency Alert Service (EAS) Test Reporting System (ETRS).  This requirement is triggered by the upcoming nationwide EAS test which is scheduled to occur at 2:20 p.m. ET on November 17 (or on December 3 if the test must be rescheduled).  ETRS Form One identifies the broadcaster and their EAS equipment.  Broadcasters must then file their ETRS Form Two, reporting whether they received the test, by 2:20 p.m. ET on November 19 (or by 2:20 p.m. ET on December 5 if the test is rescheduled).  ETRS Form Three, providing more information about test’s reception, is to be filed by January 4, 2027 (or by January 18, 2027 if the test is rescheduled).  We provide more details about this nationwide EAS test on our Broadcast Law Blog, here.

Broadcasters should already be offering lowest unit rates to political candidates running in the November 3 election.  As we noted in last month’s look at September regulatory dates, there are surprisingly state and local elections later in November (noted last month) and coming up in December.  Lowest Unit Rates apply to advertising sales to candidates in those state and local elections just as they apply to elections for federal office (see our article here on the basics of computing LUR).  Thus, this month, windows open for the following local elections in Delaware, Louisiana, New Jersey, and South Carolina occurring in December 2026:

STATE/TERRITORY LUR DATE ELECTION DATE ELECTION TYPE
South Carolina October 2, 2026 December 1, 2026 Municipal Election (Paxville)
Delaware October 6, 2026 December 5, 2026 Municipal Election (Dagsboro)
New Jersey October 9, 2026 December 8, 2026 Special School Board Elections
Louisiana October 13, 2026 December 12, 2026 Open General Election

As a refresher, in the 45 days before a primary election, and 60 days before a general or special election, broadcasters must extend to legally qualified candidates their lowest unit rate and continue to follow all other applicable political broadcasting rules.  For a deeper dive on how to prepare for the 2026 elections, see our post here, which also includes a link to our comprehensive Political Broadcasting Guide.  Also, look at our 2026 Broadcasters’ Calendar to see if your state has any upcoming primary, general, or special election (and confirm that all dates for political windows, including those listed above, are accurate as some dates have changed since the calendar was prepared).

Looking forward to November, Daylight Savings Time ends November 1.  The change in the clocks means that AM daytime only stations, AM stations with different daytime and nighttime patterns, and AM stations operating with pre-sunrise and/or post-sunset authority should check their sign-on and sign-off times on their current FCC authorizations to ensure continued compliance with the FCC’s technical rules.  AM stations need to note that all times listed in FCC licenses are stated in standard time, not daylight savings time even if it is in effect.

As always, consult your own legal and technical advisors for other dates of importance that might apply to your stations in the upcoming months.