SECOND MEASUREMENT SM-017

Every broadcast station must post its quarterly list of community programming by the tenth. 90% of the lists went up on time in 2025; 3,231 were more than a month late, and the FCC's base fine for a late list is $10,000

Markovian ProtocolMeasured 2026-10-06 to 2026-10-10Status: published 2026-10-10; questions to the FCC Media Bureau go with the 14 October readDOI: 10.5281/zenodo.23287991

Every full-power television and radio station keeps a public file on the FCC's website, and four times a year it has to put a list there of the programs that dealt with local issues, by the tenth of the month after the quarter. The FCC's site shows the day each file was uploaded. We read that date for every full-power and Class A TV, FM and AM station, 18,043 of them (1,995 TV, 11,622 FM, 4,426 AM), for every quarter from the start of 2025 to Apr-Jun 2026. For 2025, 53,772 of 59,842 lists went up by the deadline. 6,070 were late, the median by 38 days; 3,231 were more than a month late. At licence renewal the FCC has settled late lists by consent decree, with payments of $6,000 to $42,500.

Disclosure: Markovian Protocol holds no financial position in any organisation named here, was paid by no one for this work, and showed it to no one before publication. How we work.

What the rule says, what we found

6 deadlines, 18,043 stations

All services together, newest quarter first. Earliest upload per station and quarter, read from publicfiles.fcc.gov 2026-10-06 to 2026-10-10. “No list found” means no file we could assign to that quarter: the station may have named it in a way the script did not recognise, put it in another folder of its public file, or not have one. Where the business-day and tenth-of-the-month deadlines differ, “by the tenth” gives the stricter count.

TV, FM and AM, quarter by quarter

Full-power and Class A television, full-power FM and AM. Translators, low-power TV, LPFM and unbuilt construction permits, whose call sign is still a file number, keep no issues/programs list and are excluded: 69 TV, 10 FM, 5 AM call signs dropped on that rule. 4 stations have no Issues and Programs folder at all (KDBU, WDRG, WJCE, WTXO) and 1 more could not be read: KSJI (FM, its page returned HTTP 302); they are outside the 18,043.

The shutdown quarter

The third-quarter 2025 list was due 10 October. The FCC suspended most operations from 1 October through 12 November; its filing systems came back on 18 November.⁴⁵ On the public-file site, 1,768 stations have a third-quarter list dated on or before 10 October, 12,043 between 11 October and 1 December, and 1,008 after the 1 December deadline the Bureau set. 7,490 of the in-between uploads carry 18 November, the day the systems returned, and none is dated between 2 October and 17 November, while they were down. Whether 18 November is the day the station uploaded or the day the system recorded files that had been waiting is our first question to the Bureau.

More than a month late

4,018 station-quarters were uploaded more than 30 days after the deadline. The sixteen furthest past it (the cut at fifteen falls inside a tie at 519 days, so every station at 519 is shown):

Days from the deadline to the earliest upload we found for that quarter. Community and licensee from the station’s FCC profile page.

Nothing for 2025

2,199 stations uploaded nothing at all to their issues/programs folder during 2025 (24 TV, 1,402 FM, 773 AM). That number reads only upload dates, so it does not depend on our file-name reading. A second count, 2,288 stations (25 TV, 1,459 FM, 804 AM), had no file we could assign to any 2025 quarter. The two overlap but neither contains the other: 1,973 stations are in both. 226 uploaded nothing in 2025 but have since put up lists labelled for 2025 quarters, dated 2026: 188 of them missed at least one 2025 deadline, and 38 uploaded only the fourth-quarter list, on time in January, with the first three quarters missing. 315 uploaded something in 2025 but nothing we read as a 2025 list: for 217 a 2025-dated file had no quarter we could read, which may be our miss or theirs; for 98 every 2025 upload was an earlier quarter’s list, typically the fourth quarter of 2024 uploaded in January. 491 stations have an empty folder (6 TV, 430 FM, 55 AM); the table shows 25 of them, alphabetically, AM first. All 2,288 are in no_2025_list_stations.csv and all 2,199 in no_upload_2025_stations.csv. Two cautions. The 226 with every 2025 list dated 2026 look exactly like the re-upload case above, a file replaced after the fact, and we cannot tell the two apart. And a station that was silent for a whole quarter has no programs to list; the facility list does not mark silence, so some of these stations owed nothing.

Every file under the station’s Issues and Programs Lists folder, any year. Empty folders first.

How this ends

Two acts close it. The station uploads the missing list, which the next quarterly read will see as a new file with a later date; or the FCC’s Media Bureau raises it at the station’s next renewal, where the licensee has to certify that the public file was complete and on time, and a late list becomes a consent decree with a civil penalty. The television renewal cycle whose filings ended in April 2023 produced those decrees; radio’s next cycle opens on 1 June 2027, when stations in D.C., Maryland, Virginia and West Virginia file first.⁹ We re-read every station the morning after each quarterly deadline, in January, April, July and October, and print the result here.

The evidence

Every quote below was checked against a saved copy. Copies and SHA-256 hashes: SHA256SUMS.

Issues and Programs Lists / 2025            Date Uploaded
2025 WNBC Q1 ISSUE REPORT     322.50 KB     04/01/2025 2:13 PM
2025 WNBC Q2 ISSUE REPORT     360.96 KB     07/02/2025 3:37 PM
2025 WNBC Q3 ISSUE REPORT     372.66 KB     11/18/2025 10:27 AM
2025 WNBC Q4 ISSUE REPORT     365.07 KB     01/05/2026 3:33 PM

Our questions to the FCC

For the Media Bureau. Answers will be printed here as written.

1. Is the Date Uploaded shown on publicfiles.fcc.gov the moment the licensee uploaded the file, or can it be the moment the system processed it? 7,490 third-quarter 2025 lists carry 18 November 2025, the day systems returned, and none is dated between 2 October and 17 November.
2. Does the Bureau review Issues/Programs upload dates outside the renewal cycle, or only when a licensee certifies at renewal?
3. Is a list uploaded late but before renewal treated differently from one never uploaded?

Their reply, scored

What we can’t be sure of

• Date Uploaded is the FCC site’s own field, and we take it as given. If a station uploaded a list, deleted it and uploaded it again, we see only the surviving file; a list that was on time and later replaced reads as late. The reverse, a file dated earlier than it was really uploaded, we cannot detect.
• A file is matched to a quarter by its folder and name. 56,873 of 1,044,789 files had no quarter we could read, most of them older than 2023 or named without any period at all. A station whose list we missed is counted as “no list found”, not as late. The error runs the other way too: a file we read as a later quarter’s list would count that quarter on time. We drop any match dated before its quarter began, 489 files on this read; a misread dated inside the quarter we cannot catch.
• Noncommercial stations file under 73.3527(e)(8) on the same schedule, except that the rule exempts Class D FM stations and stations whose programming is wholly instructional. The facility list does not mark either, so we do not separate commercial from noncommercial, and some noncommercial stations counted under “no list found” owed none.
• One snapshot per station, 2026-10-06 to 2026-10-10. A station can upload a missing list tomorrow; the recheck will show it.
• The dates hold still between reads: a 150-station TV sample read twice on 6 October, two hours apart, returned the same Date Uploaded for all 9,010 files (the script matches a file by its name and folder, 8,894 distinct pairs) (drift_check.py, both reads in the exhibits folder).
• The only earlier measurement we found was done on foot: before the files went online, two researchers asked nearly 100 Missouri radio stations in person for their lists and one in five could not produce them on request; the paper’s list of failures begins with files not reachable within twenty minutes.⁸ Different method, different question; we cite it as the baseline, not as a comparison.

Run it yourself

The scripts use only Python’s standard library and read the public site. A 150-station sample takes minutes; every station of one service takes one to four hours.

curl -O https://markovianprotocol.com/measurements/sm-017/scan.py
curl -O https://markovianprotocol.com/measurements/sm-017/analyze.py
curl -O https://markovianprotocol.com/measurements/sm-017/combine.py
for s in tv fm am; do curl -s https://publicfiles.fcc.gov/api/service/$s/facility/getall -o ${s}_all.json; done
FCC_SERVICE=fm python3 scan.py 150 20261007 results.json     # 150 random full-power FM stations
python3 analyze.py results.json summary_fm.json
python3 combine.py summary_fm.json

What you can do with this

• If you run a station, open your Issues and Programs folder and read the dates; a late list found by you is cheaper than one found at renewal.
• If you are a listener or viewer and want to know what your station says it covered, the list is in the same folder, and it is public.

References

1. 47 CFR § 73.3526(e)(11)(i) and (e)(12), Online public inspection file of commercial stations. law.cornell.edu/cfr/text/47/73.3526. Accessed 2026-10-06.
2. 47 CFR § 73.3527(e)(8), Online public inspection file of noncommercial educational stations. law.cornell.edu/cfr/text/47/73.3527.
3. 47 CFR § 1.80(b), Forfeiture proceedings, Table 1. law.cornell.edu/cfr/text/47/1.80.
4. FCC. Revisions to Deadlines Following Resumption of Normal Operations, Public Notice DA 25-943, 17 November 2025. docs.fcc.gov/public/attachments/DA-25-943A1.pdf.
5. Wiley Rein LLP. FCC Systems Back Online Post-Shutdown; Media Bureau Announces Revised Deadlines, 18 November 2025. wiley.law.
6. Pillsbury Winthrop Shaw Pittman LLP. FCC Enforcement Monitor, May 2025 and February 2026. May 2025, February 2026. Saved copies May 2025, February 2026.
7. FCC. Public Inspection Files, publicfiles.fcc.gov; facility lists tv, fm, am. tv list accessed 2026-10-06, fm and am 2026-10-07; saved copies in the exhibits folder.
8. Smith, M. and Clark, E. Significant Treatment: An Assessment of Issues-Programs List Availability in Missouri Radio Station Public Inspection Files. Journal of Radio Studies 14(2), November 2007. doi:10.1080/10955040701583288, pp. 178–195. Abstract and Crossref record saved: smith-clark-2007-abstract.txt.
9. FCC. Broadcast Radio License Renewals by DATE: licences expire 1 October 2027 to 2030; first applications due 1 June 2027 (D.C., Maryland, Virginia, West Virginia). fcc.gov/media/radio/broadcast-radio-license-renewal-dates-by-date. Accessed 2026-10-08; saved copies radio, television (TV filings June 2020 to April 2023, the table less eight years).
10. FCC. Report and Order FCC 16-4, Expansion of Online Public File Obligations, MB Docket 14-127, adopted 28 January 2016, released 29 January 2016, para. 1: “In 2012, the Commission adopted online public file rules that required broadcast television stations to post public file documents to a central, FCC-hosted online database”; saved copy FCC-16-4A1.pdf. FCC. About, publicfiles.fcc.gov/about: “All other radio stations are exempt from online filing until March 1, 2018”. Accessed 2026-10-08; saved copy publicfiles-fcc-gov-about.html.
11. FCC Media Bureau, Audio Division. Ward Broadcasting Corporation, Station WTOY(AM), Salem, Virginia, Order and Consent Decree DA 23-156, 1 March 2023: the licensee “failed to place any issues and programs lists in its online public file” during the licence term; compliance plan, no penalty for the lists, renewal granted (the $7,000 notice of apparent liability the order cancels concerned a late renewal application and unauthorized operation). docs.fcc.gov; saved copy DA-23-156A1.pdf.

Cite as

@misc{markovian-sm017,
  author = {{Markovian Protocol}},
  title  = {Upload dates of quarterly issues/programs lists
            in the FCC public file, full-power and Class A TV, FM and AM, 2025--2026},
  number = {SM-017},
  year   = {2026},
  month  = oct,
  url    = {https://markovianprotocol.com/measurements/sm-017.html},
  doi    = {10.5281/zenodo.23287991}
}