The annual EEO public file report: who, what and when
Facts checked against their sources on November 5, 2026.
Once a year, every radio and TV station employment unit with five or more full-time employees puts an EEO public file report in its stations’ public files and on their websites. The rule, 47 CFR 73.2080(c)(6), sets the date: “annually, on the anniversary of the date a station is due to file its renewal application.”
Who prepares one
- Station employment units with five or more full-time employees. The rule’s small station exemption says the EEO program requirements, including this report, “shall not apply to station employment units that have fewer than five full-time employees” (73.2080(d)).
- A full-time employee is “a permanent employee whose regular work schedule is 30 hours per week or more,” and a station employment unit is “a station or a group of commonly owned stations in the same market that share at least one employee” (73.2080(e)).
- Commercial and noncommercial AM, FM, TV and Class A TV stations alike (73.2080(a)). A report is placed in the public file of each station in the unit.
- Time brokerage: the licensee reports its own recruitment; a licensee that brokers another station includes its recruitment for that station in its own reports (73.2080(f)(3)).
- Even in a year with no hires: the FCC’s Form 396 tips answer “If I had no hires, do I still need to provide a yearly EEO public file report?” with “Yes,” because the report also shows the outreach initiatives completed, or that there was no reportable activity.
What it must include
For the preceding year (73.2080(c)(6)(i)–(v)):
- A list of all full-time vacancies filled by the employment unit, identified by job title.
- For each vacancy, the recruitment sources used to fill it (including organizations that asked to be notified of vacancies, separately identified), with name, address, contact person and telephone number.
- The recruitment source that referred the person hired for each full-time vacancy.
- The total number of people interviewed for full-time vacancies, and the number of interviewees referred by each recruitment source.
- A list and brief description of the outreach initiatives the unit undertook under 73.2080(c)(2): job fairs, internships, mentoring, training, scholarship programs and the like. Units with more than ten full-time employees not in a smaller market need at least four initiatives in each two-year period; others need at least two.
A licensee that acquired the station during the year reports from the date it acquired it. Keep the underlying records (job notices, interviewee counts, initiative documentation) until the renewal application for the term is granted (73.2080(c)(5)).
When it’s due
On the anniversary of the station’s renewal filing date, which is the first day of the fourth full calendar month before its license expires (73.3539(a)). Radio and TV stations in the same state share the date, because TV licenses there expire a year after radio, in the same month. Each report covers the year before its due date: the report due June 1, 2026 covered June 1, 2025 through May 31, 2026.
| Due each year | States and territories | In 2027 |
|---|---|---|
| February 1 | Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, Oklahoma | Monday, February 1, 2027 |
| April 1 | Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, Texas | Thursday, April 1, 2027 |
| June 1 | Arizona, District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming | Tuesday, June 1, 2027 |
| August 1 | California, Illinois, North Carolina, South Carolina, Wisconsin | Monday, August 2, 2027 (August 1 is a Sunday) |
| October 1 | Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Missouri, Northern Mariana Islands, Oregon, Puerto Rico, U.S. Virgin Islands, Washington | Friday, October 1, 2027 |
| December 1 | Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, Vermont | Wednesday, December 1, 2027 |
- Weekends and holidays. When the date falls on a weekend or federal holiday, law firms’ deadline alerts move it to the next business day, as FCC rule 1.4(j) does for filings: Wiley’s alerts gave “Monday, June 2, 2025” and “Monday, August 3, 2026.” Uploading by the first of the month avoids the question.
- FCC extensions. The FCC has moved these dates by public notice: documents due in the online public file from January 1, 2023 were given until February 28, 2023, because of problems with the system (DA 23-16, DA 23-78), and after the 2025 government shutdown, EEO filings due October 1, 2025 were given until November 24, 2025 (DA 25-943).
- A station whose license expires on an unusual date (after a short-term renewal, for example) follows its own renewal filing date. Confirm your date with your communications counsel.
Where it goes
- The online public file. In the FCC’s Online Public Inspection File, the reports have their own folder: Equal Employment Opportunity Records, then Additional Documents, then EEO Public File Reports. Upload times are stamped by the FCC’s system. Put the year or the period in the file name (for example “WXYZ-FM 2027 EEO Public File Report (June 1, 2026 – May 31, 2027).pdf”).
- The station’s website, if it has one (73.2080(c)(6)). The FCC lets stations meet this with a link on their own website to the EEO materials in their online public file, but “the link to EEO materials must be a direct link to such materials on the FCC’s website, and not simply a link to the first page of the entity’s online public file” (FCC 16-4, para. 37, for radio; FCC 12-44, para. 77, for TV).
- How long: EEO materials stay in the public file until final action on the station’s next license renewal application (73.3526(e)(7); 73.3527(e)(6) for noncommercial stations).
At renewal time
Every station, including those in employment units with fewer than five full-time employees, files a Broadcast EEO Program Report (FCC Form 2100, Schedule 396) with its renewal application, on the date the application is due, and keeps a copy in its public file (73.2080(f)(1)). See the renewal guide for dates.
The mid-term review
- The FCC reviews the employment practices of TV stations in employment units with five or more full-time employees, and radio stations in units with eleven or more, four years after the station’s most recent license expiration date (73.2080(f)(2)).
- Stations no longer file a mid-term report: the FCC eliminated Form 397 in 2019 and reviews the annual reports in the online public file instead. Radio stations answer “Yes” or “No” in the online public file to whether they have eleven or more full-time employees (FCC 19-10, para. 9); Wiley’s 2025 alert places the question on a “Mid-Term Review” tab under the file’s Settings.
- Wiley’s 2026 alerts describe reviews beginning on the annual report date (August 1, 2026 for TV employment units in California, for example) and covering the prior two years of annual reports, and say the radio reviews for this cycle are complete.
- Separately, the FCC audits about five percent of radio and TV licensees at random each year (73.2080(f)(4)).
What changed in 2024–2026
- Form 395-B (workforce demographic data): the FCC reinstated the annual Form 395-B report in 2024; the Fifth Circuit vacated that order in National Religious Broadcasters v. FCC (2025), finding the FCC lacks authority to require it; and the Media Bureau removed the rule (47 CFR 73.3612) from the books effective November 3, 2026, saying the deletion “has no effect on the scope and nature of the currently enforceable Commission requirements” (DA 26-1058, 91 FR 69223).
- The public file report itself hasn’t changed. The eCFR shows only wording updates to 73.2080 since 2019 (form names, “website”, the end of Form 397), most recently in February 2026.
How StationClerk helps
The free check lists every annual EEO public file report due in your station’s current license term, year by year, with what the FCC’s EEO folder shows: found by the due date, uploaded after it, not found, or unclear. It can’t see how many people you employ, so it reads every station the same way. The Desk ($19 per station per month) emails a reminder 14 and 3 days before your report date until the report shows up in the folder; turn it off if your employment unit has fewer than five full-time employees.
Sources
- 47 CFR 73.2080 (EEO; the annual EEO public file report is paragraph (c)(6)), eCFR
- 47 CFR 73.3539 (time to file renewal applications), eCFR
- 47 CFR 73.3526 (commercial stations’ public inspection file), eCFR
- 47 CFR 73.3527 (noncommercial educational stations’ public inspection file), eCFR
- 47 CFR 1.4 (computation of time; holidays), Cornell LII
- FCC 16-4, Report and Order expanding the online public file to radio (January 29, 2016), para. 37: EEO materials and website links
- FCC 12-44, Second Report and Order on television stations’ online public files (April 27, 2012), para. 77: EEO materials and website links
- FCC 19-10, Report and Order eliminating the Broadcast Mid-Term Report, Form 397 (February 15, 2019)
- FCC Enforcement Bureau: Helpful Tips, Form 396 (includes “If I had no hires, do I still need to provide a yearly EEO public file report?”)
- Wiley: June 2, 2025 FCC EEO Deadlines for Stations in DC, MD, VA, WV, MI, OH, AZ, ID, NV, NM, UT, and WY (JD Supra)
- Wiley: August 3, 2026 FCC EEO Deadlines for Stations in NC, SC, IL, WI and CA (July 2, 2026)
- Broadcast Law Blog: January 2026 Regulatory Dates for Broadcasters (December 28, 2025)
- FCC Media Bureau public notice DA 23-16: extension of time for online public inspection file documents (January 6, 2023)
- FCC Media Bureau public notice DA 23-78: further extension of time for online public inspection file documents (January 27, 2023)
- FCC public notice DA 25-943: Revisions to Deadlines Following Resumption of Normal Operations (November 17, 2025)
- Federal Register: Review of the Commission’s Broadcast and Cable EEO Rules and Policies; Delete, Delete, Delete, 91 FR 69223 (November 3, 2026; Media Bureau Order DA 26-1058)
StationClerk is independent software. It is not affiliated with or endorsed by the Federal Communications Commission, and nothing it shows or produces is legal advice. Each station is responsible for its own public inspection file and quarterly lists.