FCC Updates Filing Deadline Extensions Following Resumption of Operations

The Federal Communications Commission has issued a series of Public Notices that revise deadlines for filings in certain systems and programs, in light of the FCC’s return to operations after the extended government shutdown.

The first Public Notice states that, in general, filings that were due between October 1, 2025 and November 17, 2025 are still due today (November 18, 2025), but with important exceptions:

Universal Licensing System (ULS)

ULS applications and notifications originally due October 1, 2025 through December 5, 2025 are now due on December 5, 2025. This does not apply to filings related to spectrum auction activities under section 309(j).

Online Public Inspection File (OPIF)

• • Quarterly Issues Report Filings: Quarterly issues report filings that were due by October 10, 2025 are now due by December 1, 2025.

• • EEO Filings: EEO filings that were due by October 1, 2025 are now due by November 24, 2025. Broadcast EEO audit responses that were due by October 17, 2025 are also due by November 24, 2025.

• • Political Programming Records: The Media Bureau released a separate Public Notice outlining the following staggered approach to uploading records of requests to purchase broadcast time received between October 1, 2025 and November 12, 2025:

• • • Licensees in New York, New Jersey, and Connecticut should upload records November 19 through November 26, 2025.
    • Licensees in Virginia, Maryland, West Virginia, and the District of Columbia should upload records December 1 through December 8, 2025.
    • Licensees in California should upload records December 9 through December 16, 2025.
    • Licensees in all other states and territories should upload records December 17 through December 24, 2025.

Licensing and Management System (LMS)

By separate Public Notice, the Media Bureau announced that any filings submitted in LMS between November 18, 2025 and November 25, 2025 will be considered filed on November 25, 2025 and treated equally in terms of processing priorities. Any facility with a consecutive 12-month period of broadcast non-operation ending October 1 through November 18, 2025 must resume authorized broadcast operations by November 18, 2025 to avoid license expiration. Any permittee whose construction permit expired October 1 through November 18, 2025 must file a license to cover application or tolling request by November 28, 2025.

Special Temporary Authority (STA)

STAs that would have expired October 1, 2025, through December 4, 2025 are extended until December 5, 2025.

Responsive Pleadings

The filing deadlines for reply or responsive pleadings will be extended for a period of time equivalent to the extension provided for initial filing. For example, if comments in a rulemaking proceeding were originally due on October 15 and reply comments were due fifteen days later, comments are now due on November 18 and reply comments are due fifteen days later on December 3.

Other Deadlines and Extensions

The Public Notice includes information about deadline extensions for several other proceedings and databases, including the Tower Construction Notification System (TCNS), the Antenna Structure Registration (ASR) system, DIRS modernization, 911 Reliability Certifications (PS Docket 13-75), and Next Generation 911 requests. Interested parties should review the Public Notice for details.

If you have questions about the FCC’s resumption of operations or need assistance submitting a filing, contact an attorney in our Broadband, Spectrum, and Communications Infrastructure; Media; Satellite; or Utilities practice groups.