Portions of New Foreign Sponsorship ID Rules to Take Effect August 15, 2024

As discussed in our June 21, 2024 client alert, the FCC recently amended its foreign sponsorship identification rules. These rules require broadcast licensees to disclose the identity of any foreign governmental entity that leases time on a radio or television station. One of the changes was that the FCC expanded the application of the rules to include issue advertising and paid public service announcements.

Due to the need for Office of Management and Budget (OMB) approval under the Paperwork Reduction Act (which has yet to be initiated), the expansion of the rules and certain other changes will not go into effect for some time. This includes (i) the application of the rules to issue advertising and paid public service announcements, and (ii) the new two-option method to obtain information about foreign governmental entity sponsorship. OMB approval may take several months and will likely happen after the 2024 election.

Effective August 15, 2024, the rules will apply to programming delivered to foreign broadcast stations under a Section 325(c) permit. This is a narrow application that applies only to a small subset of broadcasters. In addition, the requirement of the original rules regarding obtaining a certification from each entity that leases or brokers time on a station has not changed and is still in effect.

For more information about the foreign sponsorship identification rules, contact an attorney in our Media practice group.