2023 Broadcasters’ Calendar

Pillsbury Winthrop Shaw Pittman LLP

Items of Note in 2023[1]

I. Commercial and Noncommercial Biennial Ownership Report: December 1, 2023 is the deadline by which all commercial and noncommercial radio and television stations must file their biennial ownership reports. Commercial stations will file FCC Form 2100, Schedule 323, and noncommercial stations will file FCC Form 2100, Schedule 323-E. The filing window opens October 1, 2023, and all ownership reports must reflect information current as of that date.

II. Applications for Renewal of License: The three-year long state-by-state license renewal cycle ends in April 2023 for stations in the television services (full-power television, Class A television, LPTV, and TV Translator). The three-year renewal cycle for stations in the radio services (AM, FM, FM Translator, and LPFM) ended in April 2022. Stations will file their license renewal applications on FCC Form 2100, Schedule 303-S (“Form 303-S”) along with their Equal Opportunity Employment Reports on Form 2100, Schedule 396 (“Form 396”). The date by which the licensee must file a station’s application for license renewal depends on the state or territory of the station’s community of license. All licensees should familiarize themselves now with the dates associated with this important filing. As noted in previous Calendars, stations are no longer required to air pre-filing announcements during the two months preceding the filing of their license renewal application and instead need only air six post-filing announcements over four consecutive weeks, beginning within five business days after the FCC has “accepted for filing” their license renewal application. Additional information can be found in our License Renewal Advisories published on CommLawCenter prior to each state-by-state application deadline.

III. TV Spectrum Repack Progress Report and Reimbursement Deadlines: Because the 39-month post-auction transition period for full-power and Class A television stations ended in 2020, the post-repack Transition Progress Report (FCC Form 2100, Schedule 387) filing deadlines are not noted in this year’s calendar. However, stations that received an extension of time to complete their transition must continue to file Transition Progress Reports on a quarterly basis until they have ceased operating on their pre-repack channels, completed construction of their post-repack facilities, and reported that information to the FCC. In addition to these quarterly reports, transitioning stations must file Transition Progress Reports ten weeks before the end of their assigned construction deadline, ten days after completion of all work related to constructing their post-repack facilities, and five days after ceasing operations on their pre-auction channel. Throughout 2021 and 2022, all repacked full-power and Class A television stations and FM stations and LPTV/translator stations that sought reimbursement had to submit all invoices and supporting documentation, and initiate interim close-out procedures. The FCC announced in February 2022 that it intends to visit a random sample of Broadcaster Relocation Fund participants to verify the existence and operational status of equipment for which the participant received reimbursement.

Read More: 2023 Broadcasters’ Calendar


1 The deadlines in the 2023 Broadcasters’ Calendar are based on information known as of the date hereof and may or may not apply to any particular broadcaster. They are provided for general informational purposes only and should be double-checked for currency close to each pertinent date/deadline. Actions by the FCC, Congress, or the courts could affect any of these deadlines by, for example, eliminating a particular reporting/filing obligation altogether or modifying the form used, content, deadline, fee, or manner of reporting/filing. It should also be noted that, as a general rule, when a deadline for filing a document with the FCC falls on a weekend or a federal holiday, the filing deadline shifts to the next business day. The listing below is not intended to be complete or exhaustive of all regulatory and non-regulatory deadlines that may apply to a given broadcaster year-to-year. Accordingly, broadcasters should seek the advice of communications counsel to assure timely and proper filing. This edition of our annual Broadcasters’ Calendar supersedes all prior editions and accordingly any prior editions should no longer be used.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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