How the Government Shutdown Affects the FCC & Broadcasters
FROM THE FCC WEBSITE:
Due to a partial lapse in federal government funding, the FCC has suspended most operations effective 12:00 a.m. EDT on October 1, 2025. As a result, information on this website may not be up to date. Transactions submitted via this website or other FCC-systems might not be processed altogether or processing time may be delayed until appropriations are enacted. The FCC may not be able to respond to inquiries or response time may be delayed until appropriations are enacted. For more information, refer to: Impact of Potential Lapse in Funding on Commission Operations.
Although the FCC website will remain up, it will not be updated except for matters related to spectrum auction activities and threats to life and property. The FCC has issued a Public Notice advising on which systems and databases will be available and which will not during the government shutdown, as well as guidance on deadlines: https://docs.fcc.gov/public/attachments/DA-25-922A1.pdf.
The primary databases used by broadcasters, the Licensing and Management System (LMS) and the Online Public File system (OPIF), will not be available. Thus, no license applications, modifications, applications for special temporary authority (STA), assignment applications, etc. can be filed during the shutdown. Likewise, no applications can be processed. The Emergency Alert System Test Reporting System (ETRS) is also not available, so stations will be unable to file ETRS reports that were to be due earlier this month.(1)
As of now, no specific deadlines have been altered. However, the FCC has announced a blanket extension to one business day after the government reopens, whenever that may be. In prior shutdowns, the FCC has generally granted additional time and/or re-set deadlines once the shutdown has concluded, but they announce any such further extensions AFTER the government reopens. For now, broadcasters should assume that any deadline you currently have will change to one business day after the first day of the government reopening.(1)
For Class A TV Only: Because the OPIF will be unavailable, stations will not be able to upload their issues-programs reports, nor will they be able to timely upload political broadcasting files. However, the FCC’s rules direct that stations must maintain a physical record of political broadcasting files at all times, so you should retain all political spot orders received during this time and have them available if an interested party requests them for review.(2)
Political Filings. When the FCC’s systems are not available, broadcasters are supposed to maintain their political file in an alternative format so that it can be viewed by interested parties. The political file is the only portion of the public file where such alternatives must be maintained.(2)
Class A, LPTV, and TV Translator Stations. The FCC has not explained if and how dates in the FCC’s major change filing window and associated filing freezes on Class A, LPTV, and TV translator stations will be rescheduled after the FCC reopens including the filing freeze on minor change applications and LPTV and TV translator displacement applications which was supposed to begin on October 15, and the major change filing window which was supposed to begin on October 22. There is also no announcement as to whether delays in the major change window will affect the opening of the window for seeking new LPTV and TV translator stations that is now scheduled to open in January – the first opportunity to file for new LPTV and TV translator stations in over 15 years.(2)
Comment Deadlines: Comment deadlines in several FCC rulemaking proceedings that began just before the shutdown have not been set as the notices of proposed rulemaking have not been published in the Federal Register, as the Federal Register is also affected by the shutdown. The delays affect proceedings including the rulemaking to address the local radio and TV ownership rules where the FCC seeks to determine if it should relax those.(2)
Enforcement Matters: Most deadlines for enforcement matters and investigations are at the discretion of the FCC’s Enforcement Bureau. Please consult with your legal counsel if your station is part of an open enforcement matter.
Tower Lights: If you have a tower light out, you are still required to make the required filings to the FAA’s Notice to Airmen (NOTAM) Management Service (NMS) and the FCC, at https://nms.aim.faa.gov/.
1 From Davina Sashkin, LPTVBA Legal Counsel and Partner at Wilkinson Barker Knauer LLP
2 From the Broadcast Law Blog, published by David Oxenford. www.broadcastlawblow.com