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Time to File Biennial FCC Ownership Reports

- System Opened Oct. 2; Avoid Costly Fines

The FCC’s Media Bureau last week activated the filing system broadcasters must use to submit their 2023 biennial ownership reports and stations are urged to act well before the Dec. 1 deadline.

Commercial and noncommercial broadcasters must file their ownership reports on FCC Form 2100, Schedule 323 or 323-E, respectively. This rule applies to every commercial and noncommercial full power TV, Class A, LPTV and AM and FM station – even if there was no change in ownership since the last report filing.

The final deadline is Dec. 1.

Ensuring that these reports are timely filed is important not only for compliance with the reporting rules but also for stations’ future renewal applications. 

Stations must certify on their renewal applications that they have filed their biennial reports as required by the Commission’s rules or disclose violations. Failing to file ownership reports on time can raise issues for stations during the license renewal process, including potential processing delays. 

The FCC has publicly stated that, as part of its review of license renewal applications, staff will review whether licensees have filed their biennial ownership reports and whether they have certified truthfully concerning compliance with the filing requirement. 

Further, the commission also has previously stated that it intends to take enforcement actions against broadcasters that fail to file timely and complete biennial ownership reports, and it may take additional actions against any broadcaster that makes a false certification on its renewal application regarding the filing of the reports. 
The FCC regards reporting ownership information as a fundamental obligation of broadcast licensees, so it is important for broadcasters to timely file their reports. 

Additional Information

Further information about biennial ownership reports is available at the Media Bureau's Form 323/323-E website, which has links to forms and instructions, FAQs, and information sessions.

Questions? Contact TAB’s Oscar Rodriguez or call (512) 322-9944.

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