FCC 47 CFR § 11.35(d) — compliance required by September 29, 2026
Station Compliance

Station Compliance›Television

For television stations

The rule covers more of your plant than you think.

Most coverage of the FCC's new program chain security rule has been written for radio. Read as a radio rule, it causes television stations to under-count what is in scope — because a TV plant has more equipment inside it, not less.

The rule's actual language. It applies to EAS equipment, studio transmitter link equipment, and any remotely managed equipment that routes, processes, or inserts content into the transmission of the EAS Participant's programming.

Three verbs — routes, processes, inserts. In radio those describe audio devices. In television they describe audio and video.

On June 29, 2026 the FCC adopted a new paragraph (d) to 47 CFR § 11.35. It requires three things of every EAS Participant: strong passwords of at least 15 characters, prompt installation of security patches, and a firewall or comparable network segmentation limiting remote management access.

Television stations are EAS Participants. The Commission's order names radio and television stations, cable systems, satellite services and wireline video providers together. There is no separate TV rule, no later TV deadline, and no small-station exemption. Compliance is required September 29, 2026.

The device nobody counts

Under 47 CFR § 11.51(d), a television station must transmit a visual EAS message — originator, event, location and valid time period, at the top of the screen, readable, in full at least once.

Something has to render that text onto the picture. A character generator, a dedicated crawl inserter, a keyer in master control, or the EAS box's own video output.

Whatever it is, it is inserting content into the transmission of your programming. That is the scope language word for word, applied to a device whose entire function is described by it.

And it is the one most likely to be missing from your inventory. It lives in the video world rather than the network world. It was commissioned years ago by an integrator who chose the password. It is boring until the crawl is wrong. And it is frequently remotely reachable on purpose — because a stuck crawl is a visible, embarrassing on-air fault that somebody wanted to be able to clear from home.

Every one of those is also a description of the Barix units the FCC cited in the incidents that produced this rule. Same shape of problem, different rack.

What else is in scope

If you run ATSC 3.0, the third requirement is doing considerably more work than in a legacy plant — a 3.0 facility is IP end to end, which is the point of it and also the reason segmentation matters more there.

Get it

Program Chain Compliance Kit — Television

$249 — one price, all the stations you own

Four documents, written for a television plant:

Get the television kit — $249

Instant download. If it is not the right fit for your station, reply to your receipt and it gets refunded.

Running radio as well? The radio edition is $149. If you operate both, or a cluster, get in touch before buying and we will sort out sensible pricing rather than charging you twice.

Two honest notes

The rule does not require you to file anything. There is no certification, no report and no new recordkeeping obligation attached to § 11.35(d). If someone tells you otherwise, they are selling you a filing that does not exist. The kit includes documentation templates because exceptions need justification and staff turn over — not because the FCC asks for them.

The device reference is honest about its limits. The EAS encoder/decoder entries rest on published manufacturer documentation. Television master control is far less standardised than a radio air chain — two stations of the same size run different switchers, different automation and different playout — so the rest of the reference gives you a repeatable method and tells you exactly what to confirm on your own units. An equipment reference that guesses is worse than one that admits the boundary, because you would act on the guess.

This isn't legal advice. It's an implementation guide written by a broadcast professional. It isn't a compliance certification or a security audit, and it doesn't guarantee any regulatory outcome. For contested questions, talk to your communications counsel or an SBE-certified broadcast engineer. Your station remains responsible for its own compliance.

Free reference — no purchase, no email required

The kit is the implementation version. The scope and the rule itself are published here in full.