Why Is the FCC Reviewing the Broadcast EEO Report Form Again?

The Federal Communications Commission has opened a public comment period on the paperwork burden of Form 2100, Schedule 396. This is the form every broadcast licensee must file when renewing a license to show compliance with equal employment opportunity rules.

The form that travels with every license renewal

Schedule 396 is not a new requirement. It has been part of the renewal packet for decades. The form asks stations to document recruitment efforts, outreach activities, and self-assessment results tied to the FCC's EEO rules. Every AM, FM, TV, Class A, Low Power TV, and International station files it. Satellite Digital Audio Radio Service licensees file it too. The obligation kicks in at the moment a licensee seeks to keep its authorization. No form, no renewal.

Why the review exists

The Paperwork Reduction Act of 1995 forces agencies to revisit every information collection on a fixed cycle.

The legal cycle behind it

The FCC cannot simply let the form ride. It must publish a notice, estimate the burden, and ask the public whether the estimate is realistic. The current notice carries OMB control number 3060-0113. It asks for comment on five specific points: necessity, accuracy of the burden estimate, clarity, ways to automate, and relief for businesses with fewer than 25 employees. Comments are due by November 30, 2026.

What the numbers say

Agency figures show 1,479 respondents. Each respondent files once per renewal cycle.

The cost and the gap

The agency estimates each response takes between 0.5 and 2 hours. That range produces a total annual burden of 2,280 hours. The dollar cost attached to those hours is $333,000. The notice does not break down how many stations fall at the low end versus the high end. It does not say how many of the 1,479 are small businesses. The statutory authority cited is section 154(i) and 303 of the Communications Act of 1934, as amended.

Where to send comments

All PRA comments go to Nicole Ongele at the FCC. Two email addresses are listed: PRA@fcc.gov and nicole.ongele@fcc.gov. A phone number is also provided: (202) 418-2991.

What changes for a station owner

Nothing changes today. The form remains mandatory at renewal. The review only decides whether the current approval continues, gets modified, or gets trimmed. If the burden estimate is judged too low, the FCC could add time to the official paperwork budget. If it is judged too high, the agency might streamline questions. Either outcome would appear in a future Federal Register notice. Until then, the existing Schedule 396 stays in force.