The Federal Communications Commission (FCC or Commission) has set the deadlines for commenting on the Foreign Government-Provided Programming Sponsorship ID Requirements Notice of Proposed Rulemaking (NPRM), which it adopted in October. Comments are due on December 24, 2020, and reply comments are due January 25, 2021.

The NPRM proposes to update the FCC’s existing sponsorship identification rules to require disclosure “if a foreign governmental entity has paid a radio or television station, directly or indirectly, to air material, or if the programming was provided to the station free of charge by such an entity as an inducement to broadcast the material.” Our Client Alert summarizes the full item.

While this proposal grew from concerns from both political parties about radio and television programming originating from Chinese and Russian government sources, the scope and impact of the proposed rules are broader. Given the FCC’s practice of strictly enforcing its sponsorship identification requirements, as well as continued scrutiny being given to foreign involvement in U.S. discourse, we encourage broadcasters and others across the programming ecosystem to weigh in as the Commission considers this new requirement.