Incomplete OPIF Political File uploads are now one of the FCC’s easiest enforcement targets — and how stations can protect themselves.
Recently, we’ve been asked to assist clients with their Political File uploads to OPIF, unfortunately, we’ve had to red-flag documentation shortcomings. Just as with your quarterly issues and programs reports, there should be no shortcuts with the political file documentation and uploads.
The FCC’s Standard Is Brutally Simple: Stations must upload “all requests for broadcast time” and “all dispositions” immediately. If it touches the transaction, it belongs in the file. If it explains the transaction, it belongs in the file. If it changes the transaction, it belongs in the file.
47 CFR 73.1943 requires broadcast licensees to maintain a political file documenting requests for broadcast time by candidates or for political matters, with records retained online for two years. Licensees must maintain a complete record of requests that are (a) made by or on behalf of a legally qualified candidate for public office, or (b) communicate a message relating to any political matter of national importance, including a candidate, a federal election, or a national legislative issue.
Incomplete uploads are not better than nothing. Incomplete uploads are evidence of non‑compliance. If you rely solely on the NAB Political Broadcast Agreement Form (PB-19) for OPIF uploads, you may not be in compliance. If you are an NAB member you can get the agreements for free. If you are not an NAB member, you can also obtain them for a reasonable fee.
CONTINUE READING for details regarding what the Political File must include and where Licensees are often exposed.
The Political File must include:
1. The Request for Time.
FCC requirement: upload the actual request — not just the contract. This includes emails, agency forms, or any document that initiated the buy. What too many are missing: no request form, no date received, no advertiser contact information.
2. The Disposition (most commonly missed element)
FCC requirement: upload whether the request was accepted or rejected, and why. What many are missing: uploading the schedule, but not the acceptance, no explanation for rejections, no documentation of changes after preemptions.
3. The Rate Documentation (where most fines are issued).
FCC Rule: upload the rate charged including discounts, package allocations, bonus spots, and make-goods. Ensure you are following the FCC Rules regarding Lowest Unit Rate. What many are missing: uploading the schedule, but not the rate card, no documentation of bonus spots, no evidence of class-of-time equivalency. See 47 USC 315(b) (Lowest Unit Charge and 47 CFR 73.1942 (LUC Rules).
4. The Schedule.
FCC Rule: upload the exact schedule sold, including dates, times or dayparts, class of time, length, and quantity. What many are missing: revised schedule after preemptions, no documentation of make-goods.
5. The Certifications.
FCC Rule: stations must obtain and upload sponsor certifications for issue ads and candidate certifications for candidate ads. See 47 CRF 73.1212(e) (sponsorship identification). What many are missing: issue advertiser certifications (missing 80% of the time), candidate certifications (missing 20% – 30% of the time).
6. Sponsor ID + Ad Description.
FCC Rule: upload a description of the ad and the sponsor identification as it appears in the spot. What many are missing: “Candidate ad” with no description, no sponsor ID, no identification of officers/directors for issue advertisers. For requests by or on behalf of a candidate, include the candidates’ name, authorized committee, and treasurer. For non-candidate requests, include the purchaser’s name, contact information, and a list of executive officers or board members.
MCH Enterprises has drafted a pre-OPIF intake checklist HERE. Feel free to use, modify, or ignore as you wish. Just make sure you are not found in non-compliance. Remember: the job isn’t complete until the paperwork is done. May you all make lots of money this political season!
Email: mchenterprises2026@outlook.com
Leave a Reply