Annual EEO Public File Report
Radio and television station employment units (SEUs) located in
North Carolina, South Carolina, Illinois, Wisconsin, and
California with five or more full-time employees must
prepare by Tuesday August 1, 2023, an annual EEO
Public File Report (PFR). By August 1, the report must be posted on
the website belonging to each station in the SEU and uploaded to
its online public inspection file at the Federal Communication
Commission's (FCC's or Commission's) website.
Note: It is the licensee's responsibility to ensure
the PFR is uploaded to the online public inspection file by the
deadline. Files receive an electronic date/time stamp when uploaded
to the online public file, making it clear to FCC staff if they are
posted late.
The PFR should summarize the SEU's recruitment activity from
August 1, 2022 through July 31, 2023, including full-time positions
filled, the recruitment sources used to advertise those job
openings, and the total number of interviewees and hires produced
by each recruitment source. The PFR must also include a summary of
the SEU's recruitment initiatives.
Mid-Term Review
The FCC has begun its mid-term review of EEO compliance. During the mid-term review, the FCC will review the SEU's Annual EEO Public File Reports for the prior two years. The mid-term review beginning on August 1, 2023 will apply to Radio SEUs located in North Carolina and South Carolina. The FCC no longer requires SEUs to file a Form 397 (Broadcast Mid-Term Report) with a copy of the last two EEO annual reports, instead, the FCC will review the reports that are uploaded to the online public inspection file (OPIF).
For Radio SEUs: The FCC applies the mid-term review to Radio SEUs with 11 or more full-time employees, which the FCC defines to mean individuals who work 30 hours or more per week. (To be clear, if the Radio SEU has between 5-10 employees, it must still prepare and upload a copy of the Annual EEO Public File Report to the OPIF for each station.) To provide the FCC with information about the size of the SEU, each radio licensee must complete a new section of the OPIF. Under the "Settings" section of the OPIF, there is a new tab called "Mid-Term Review." Each radio licensee will need to update this tab to answer whether it has 11 or more full-time employees. The FCC has indicated that licensees that fail to answer this new question will be contacted by Enforcement Bureau staff.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
