Quarterly Television Reports Due January 10; Annual KidVid Report Now Due March 30

By January 10, 2020, full power and Class A television stations must file their quarterly reports for the Fourth Quarter of 2019. For the first time, stations will not file a quarterly Children’s Television Programming Report. Instead, stations will file their first annual Children’s Television Report by March 30, 2020.

Documents That Must Be Uploaded to Each Station’s Online Public Inspection File by January 10, 2020:

• All commercial and noncommercial television stations: Issue-Responsive Programming List for programming broadcast between October 1, 2019 and December 31, 2019
• Commercial stations only: Documentation of compliance with Children’s Advertising Limits
• Class A TV stations only: Documentation that the station continues to meet Class A eligibility requirements

FCC Filing Due by January 10, 2020:

• Repacked full power and Class A stations, and transitioning stations: Progress Report

FCC Filing Due by March 30, 2020:

• As noted above, commercial stations will file their first annual Children’s Television Report by March 30, 2020. The FCC initially said that the report would be due January 30, but has now extended the filing deadline to March 30, 2020. The first annual report will cover programming aired between September 16, 2019 and December 31, 2019. In future years, annual reports will be due by January 30 and will cover programming aired between January 1 and December 31 of the preceding year.

Please note that even though the deadline to file the first annual Children’s Television Report is March 30, 2020, stations must still upload quarterly Children’s Advertising Limits compliance certifications to their public files by January 10, 2020. After that, stations will no longer need to file Children’s Advertising Limits certifications each quarter. Instead, stations will file an annual certification that will be due by January 30 of each year.

Here is a description of the various reports that stations must file:

I. Issue-Responsive Programming Lists

Commercial and noncommercial television and Class A stations must prepare and place in their public inspection files a list of programs that have provided the most significant treatment of community issues during the previous quarter. The listing should include a brief narrative statement that identifies the issues that were given significant treatment and should describe the programs in which the issues were addressed. Each program description must include the date, time, and title of the program, the duration of each responsive programming segment, and a brief explanation of how the programming addressed the issue(s).

II. Records Verifying Compliance with Children’s Advertising Limits

Commercial television stations must upload into their online public inspection files documentation verifying compliance with the children’s television advertising limits. This documentation must identify the programs that were subject to the limits and describe any instances of non-compliance.

III. Documentation of Continued Class A Eligibility

Class A television stations must maintain documentation in their public inspection files demonstrating compliance with both of the Class A eligibility requirements: (i) the broadcast of a minimum of 18 hours per day; and (ii) the broadcast of an average of at least three hours per week of locally produced programming each quarter.

IV. Repack Progress Report Filings

All full power and Class A TV stations that are being repacked (except those stations that have fully completed the repack process), and all television stations transitioning to new channels as a result of the Broadcast Incentive Auction, must file a quarterly Progress Report. Such stations include band-changing stations and displaced Class A stations.

V. Children’s Television Programming Report

Commercial television and Class A stations must file a Children’s Television Programming Report with the FCC. The report documents compliance with the children’s educational programming requirements during the preceding reporting period.

If you have any questions about these ongoing recordkeeping and related obligations, please contact any attorney in our office.