With a December 8 deadline to come into compliance with the FCC’s new sponsorship identification requirements for airing content connected to a foreign government, broadcasters have been racing to figure out how to comply in a practical way. As previously discussed here and here, the new rule requires that broadcasters determine whether leases of airtime (including certain advertising) involve content that is provided, funded, or distributed by “governments of foreign countries, foreign political parties, agents of foreign principals, and United States-based foreign media outlets.”
Under the rule, broadcasters must document their completion of a number of required steps to determine if provided content has such foreign government connections, and if so, ensure disclosures are included in the content when aired, and place documentation of those disclosures in the Public Inspection File on a quarterly basis.
The challenge is not so much the airing of the disclosures themselves, but collecting the required paperwork from potentially thousands of advertisers to determine if any are connected to a foreign government. Beyond the sheer paperwork and resources burden, broadcasters do not want to make it yet more difficult for advertisers to purchase broadcast airtime, particularly when those same advertisers can simply move their content to streamers or other online venues and skip the paperwork complexities entirely, whether connected to a foreign government or not.
The current version of the rule became effective on June 10, 2025, but on that date, the FCC extended the compliance deadline to December 8, 2025. This gave broadcasters a six-month reprieve, but even with that added time, compliance remained a daunting proposition.
It was therefore with a sigh of relief that broadcasters learned this afternoon that the FCC has again moved the compliance deadline, this time to June 7, 2026. This not only provides broadcasters with additional time to sort out a practical approach to complying with the new requirements, but keeps alive the hope that the FCC will use this added time to streamline these rather unwieldy requirements before next June.