FCC Releases New Filing Deadlines

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While many filings due during government shut down are now due Nov. 18, the agency also provided a long list of exceptions and a staggered schedule for political filings

WASHINGTON—The Federal Communications Commission has issued detailed guidance on filings that were disrupted by the government shut-down. While many of those filings are now due on Nov. 18, the regulator also provided a long list of exceptions and laid out a staggered schedule for political filings.

As previously reported, the government shutdown prompted the FCC to suspend most operations from October 1, 2025, through November 12, 2025. Certain electronic filing and database systems were unavailable during this time.

On November 13, 2025, the Commission further extended all such deadlines until at least November 18, 2025 and said it would provide additional guidance on specific deadlines to address the processing of what promised to be a backlog and flood of filings.

In providing the new guidance, the agency said that “While we recognize that these extensions do not afford an extension of time equal to the length of the funding lapse in all cases, we believe these extension periods are reasonable under the circumstances. Commission staff will consider requests for further extensions in individual matters, as appropriate.”

It also stressed that the new Public Notice on filing deadlines, “supersedes any filing deadline or time period set forth in the Public Notices of September 30, October 1, and November 13 to the extent that they are inconsistent with any deadlines or time periods set forth herein…The extensions contained in this Public Notice do not apply to NORS and DIRS filings and filings related to spectrum auction activities authorized by section 309(j).”

More specifically, the FCC described exemptions to the filing schedule as follows: :

  • ULS Applications and Notifications. "All ULS applications and notifications originally due to be filed in accordance with the Commission’s rules (e.g., sections 1.913, 1.946) on October 1, 2025, through and including December 5, 2025, are now due on December 5, 2025 (except certain Personal Radio Services renewals as described below). This extension does not apply to filings associated with spectrum auction activities authorized by section 309(j). In addition, all ULS filings that applicants attempted to file on October 1, 2025 (before ULS became unavailable on that day) will be considered received on November 18, 2025. For personal radio licensees (i.e., Amateur, Ship, Aircraft, GMRS, and Commercial Operator Licenses), renewal filings originally due on October 1, 2025, through and including March 5, 2026, are now due on March 5, 2026. Further, we confirm that licensees whose licenses have expired and whose renewal filing deadlines have been extended above may rely on their timely renewal filing (by the extended deadline) to support continued operation pursuant to section 1.62 of the Commission’s rules. 47 CFR § 1.62."
  • Licensing and Management System. "The Media Bureau will release an additional public notice that outlines the filing and processing deadlines for all Media Bureau filings in LMS."
  • Informal Consumer Complaints. "Service providers’ ability to respond to informal complaints was not affected by the partial lapse in funding. Nothing in this Public Notice changes any associated filing dates."
  • Quarterly Issues Report Filings: "All quarterly issue report filings that were to be filed by October 10, 2025, will now have a deadline of December 1, 2025. The Media Bureau encourages licensees to file earlier than the deadline noted above."
  • EEO Filings: "All EEO filings that were to be filed by October 1, 2025, will now have a deadline of November 24, 2025. The Media Bureau encourages licensees to file earlier than the deadline noted above. Broadcast EEO audit responses that were to be filed by October 17, 2025 as per the September 12, 2025 Public Notice See Enforcement Bureau Extends Deadline for 2025 EEO Audits and Issues Further Guidance to Respondents, Public Notice, DA 25-847 (EB Sept. 12, 2025) will likewise be due by November 24, 2025."
  • LPTV Major Modification Filing Opportunities. "On September 3, 2025, the Media Bureau issued a Public Notice announcing a phased approach for permitting Class A television, low power television (LPTV), and television (TV) translator stations to file major modification applications and new LPTV and TV translator station applications. Media Bureau Announces a Phased Resumption of First-Come, First-Served Processing of Applications for Major Changes for Class A, LPTV, and TV Translator Stations and Applications for New LPTV and TV Translator Stations, Public Notice, DA 25-792 (MB Sept. 3, 2025). The Media Bureau will release a further public notice providing revised deadlines for these filing opportunities. All major modification applications remain frozen. Id. at 2 (freezing all LPTV, TV translator and Class A major modification applications effective September 3, 2025). Minor modification applications (including displacement applications) may still be filed."
  • DIRS Modernization, PS Docket Nos. 21-346 and 15-80 and ET Docket No. 04-35. "Comments in response to the Third Further Notice of Proposed Rulemaking on modernizing DIRS were due on October 2, 2025, and reply comments were due on November 3, 2025. Resilient Networks, PS Docket No. 21-346, Third Further Notice of Proposed Rulemaking and Order on Reconsideration, FCC 25-45 (Aug. 6, 2025); Federal Communications Commission, Resilient Networks; Disruptions to Communications, 90 Fed. Reg. 42355 (Sept. 2, 2025). To ensure that there is sufficient time for commenters to review the record and submit reply comments, comments shall be due on November 18, 2025, and reply comments shall be due on December 18, 2025."
  • Petition for Rulemaking on Part 90 Signal Boosters, RM-12009. "Comments in response to the Public Notice seeking comment on Part 90 signal boosters were due on October 16, 2025, and reply comments were due on October 31, 2025. Public Safety and Homeland Security Bureau and Wireless Telecommunications Bureau Seek Comment on Safer Buildings Coalition Petition for Rulemaking on Part 90 Signal Boosters, RM-12009, Public Notice, DA 25-853 (PSHSB, WTB Sept. 16, 2025). To ensure that there is sufficient time for commenters to review the record and submit reply comments, comments shall be due on November 18, 2025, and reply comments shall be due on December 18, 2025."
  • 911 Reliability Certifications, PS Docket 13-75. "Covered 911 service providers may have been prevented from filing their annual 911 reliability certifications on or before October 15, 2025 during the partial lapse in funding. The 911 reliability certification deadline will be extended to December 12, 2025."
  • Next Generation 911 Requests, PS Docket 25-143. "NG911 valid requests that 911 Authorities filed in the Commission’s NG911 Registry in ECFS during the funding lapse may not have appeared to the public until after ECFS became available on November 13, 2025. The compliance deadlines for originating service providers from a request filed in the NG911 Registry during the funding lapse will run from the date the request is posted to ECFS, and is therefore available to the public to view. If a 911 Authority instead directly notified an originating service provider of its NG911 valid request during the funding lapse (i.e., the 911 Authority did not use the NG911 Registry), the originating service provider’s compliance deadlines are unchanged."
  • Equipment Authorization System – TCB and Test Lab Recognitions. "Telecommunications certification bodies (TCBs) and testing laboratories recognized by the FCC on September 30, 2025 may have been prevented from seeking timely renewal of recognition during the funding lapse. TCB and test lab recognition expiration dates will be extended until December 31, 2025 for TCBs and labs that were: (a) recognized by the FCC on September 15, 2025; (b) had their recognitions expire between September 15 and December 1, 2025; and (c) may be considered for recognition under 47 CFR § 2.951. Deadlines will not be extended for any laboratory in which a prohibited entity has, possesses, or otherwise controls equity or voting interests of 10% or more. 47 CFR § 2.951(b)(1)."
  • 11. Tower Construction Notification System (TCNS); Electronic Section 106 System (E-106); Antenna Structure Registration (ASR) System, and Environmental Assessments (EAs) submitted pursuant to section 1.1308(a) of the Commission’s rules. "Due to the unavailability of these systems during the period of time that the Commission suspended operations, deadlines and Tribal review timelines for filings made in connection with these systems or programs, including related submissions for environmental and historic preservation review, are tolled between October 1, 2025 and November 17, 2025. Regarding the TCNS database, Tribal Nations have a 30-day period to review an application once it is uploaded to the E-106 system. Tribes that fail to respond after 30 days may be referred to the Commission to conclude review obligations. For example, if an applicant uploaded a Form 620 into the E-106 system on September 29, 2025, the TCNS review clock would have stopped on October 1, 2025, and resumed on November 18, 2025. In this example, two days would have elapsed for purposes of Tribal notification, and the earliest that a non-responsive Tribe may be referred would be December 15, 2025. As to ASR and EA filings, the public comment deadline is similarly tolled during the Commission’s suspended operations. Commission staff will adjust dates accordingly for applications that were pending within any of these systems at the time the Commission suspended operations. Any questions about TCNS/E-106 timelines should be sent to tcnshelp@fcc.gov. Questions regarding EA and ASR filings should be directed to the FCC WTB Help Desk (1-877-480-3201). In addition, Bureaus and Offices may, by further public notice, set filing deadlines different than those specified in this Public Notice for filings in specific proceedings or classes of proceedings."
  • Responsive Pleadings. "Where reply comments or responsive pleadings are permitted with respect to initial filings with due dates extended by this Public Notice, the filing deadlines for such reply or responsive pleadings will be extended for a period of time equivalent to the extension provided for initial filing so as to afford responding parties the same amount of time. Thus, for example, if comments in a rulemaking proceeding were originally due on October 15 and reply comments were due fifteen days later, comments are now due on November 18, as set forth above, and reply comments are due fifteen days thereafter on December 3. The due dates for reply or responsive pleadings to pleadings filed prior to the suspension of operations, other than pleadings related to spectrum activities authorized by section 309(j), are extended according to the general extension schedule set forth above unless otherwise specified."
  • Statutory Deadlines. "The Commission cannot waive statutory filing deadlines such as those associated with petitions for reconsideration. Nonetheless, because of the disruption and uncertainty associated with the suspension of Commission activities and the relaunch of Commission filing systems, we will consider the Commission closed for purposes of section 1.4(e) of our rules until Tuesday, November 18, 2025 with respect to the filing of documents with statutory deadlines, other than for filings related to spectrum auction activities authorized by section 309(j) of the Communications Act of 1934, as amended. This determination does not impact statutory deadlines unrelated to filings with the Commission, such as broadcast operation requirements under section 312(g) of the Communications Act. 47 U.S.C. § 312(g). Also, extensions of deadlines for filing license applications or notifications of completion of construction of station facilities will not serve to extend existing deadlines for completion of construction. Existing rules and procedures for seeking extensions of deadlines unrelated to filings should be followed."
  • Special Temporary Authority (STA). "Any STAs that would have expired from October 1, 2025, through December 5, 2025, are extended until December 5, 2025."
  • Fee and Other Payments. "Due dates for fee payments that can only be made through the FCC’s Fee Filer System and that otherwise fell due between October 1, 2025, and December 5, 2025, are extended according to the same schedule set forth above for regulatory filings. All other payments remain due on their originally scheduled dates."
  • Transaction Shot Clock. "The Commission’s informal 180-day shot clocks for review of transactions that were suspended on September 30, 2025, due to the suspension of operations, are restarted as of November 13, 2025. For example, if September 30, 2025 was day 101 of the shot clock for a particular transaction, November 13, 2025 is day 102. This Public Notice has no effect on the timeframes for review of transactions as to which the informal shot clock was suspended on or before September 30, 2025, for reasons unrelated to the partial lapse in funding."
  • Enforcement Matters. "With the exception of broadcast EEO audit responses discussed above, the extension of filing deadlines does not apply to any enforcement matters for which other deadlines have been set by the Enforcement Bureau."

The FCC’s Media Bureau also established a staggered filing window approach for Commission licensees required to upload records of requests to purchase broadcast time. It described these windows for broadcasters in different states as follows:

  • November 19-26, 2025 for licensees located in New York, New Jersey, and Connecticut.
  • December 1-8, 2025 for licensees located in Virginia, Maryland, West Virginia, and the District of Columbia.
  • December 9-16, 2025 for licensees located in California.
  • December 17-24, 2025 for licensees in all other states and territories.

More details can be found here and here (for political).

George Winslow
George Winslow

George Winslow is the senior content producer for TV Tech. He has written about the television, media and technology industries for nearly 30 years for such publications as Broadcasting & Cable, Multichannel News and TV Tech. Over the years, he has edited a number of magazines, including Multichannel News International and World Screen, and moderated panels at such major industry events as NAB and MIP TV. He has published two books and dozens of encyclopedia articles on such subjects as the media, New York City history and economics.