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Important Reminder: Filing Broadcast Ownership Reports

The Federal Communication Commission's (FCC) Media Bureau recently released a reminder to commercial and noncommercial broadcasters of their upcoming requirement to file their 2023 biennial ownership reports on FCC Form 2100, Schedule 323 or 323-E, respectively. The reports are required to be filed by every commercial and noncommercial full power TV, Class A, LPTV and AM and FM station. The window for filing ownership reports will open on October 2, 2023, and all reports must be submitted by December 1, 2023.

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. The FCC 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 to timely file your reports. For further information about biennial ownership reports, please visit the Media Bureau's Form 323/323-E website, which has links to forms and instructions, FAQs, and information sessions. If you have questions, please contact your station’s legal counsel or the NAB legal department at 866.682.0276.

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