NAB pushes FCC for date-certain end to ATSC 1.0 in latest regulatory filing

The National Association of Broadcasters filed comments with the Federal Communications Commission on Jan. 20, 2026, requesting a firm sunset date for ATSC 1.0 transmissions as part of the transition to NextGen TV.

The filing responds to the FCC’s Fifth Further Notice of Proposed Rulemaking, issued in October 2025, which proposed eliminating mandatory simulcasting requirements and other regulatory barriers to the deployment of ATSC 3.0. NAB’s comments outline three specific requests aimed at completing the transition from the legacy broadcast standard.

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NAB requested the FCC establish a firm sunset date for ATSC 1.0 transmissions, arguing that regulatory certainty would drive investment and reduce consumer confusion. 

“A firm 1.0 sunset date is the most effective pro-consumer action the Commission can take at this stage,” the organization stated in its filing. “Without a clear endpoint, consumers face higher device costs, uncertain upgrade decisions and delayed access to improved audio, video, accessibility and public-safety features.”

The association also called for updates to receiver standards to ensure new television sets can receive ATSC 3.0 signals. NAB noted that more than 14 million ATSC 3.0-capable televisions and hundreds of thousands of external converter devices have been sold, with Pearl TV recently launching a converter box program expected to bring devices to market later this year.

Receiver standards and implementation timeline

NAB proposed that updated receiver standards take effect 12 months after the FCC adopts an order, citing changes in manufacturing cycles since the original digital television transition. During that transition 20 years ago, consumer electronics manufacturers cited 18-24 month manufacturing and planning cycles, according to the filing.

“In the intervening decades, competitive pressures, platform standardization and globalized supply chains have significantly shortened development and production timelines,” NAB stated. “Today, television manufacturers routinely operate on annual model-year refresh cycles, with incremental hardware and software updates introduced as a matter of course.”

The organization opposed tying implementation to receiver-penetration or market-availability thresholds, arguing such conditions would “unnecessarily delay its benefits and reintroduce regulatory uncertainty.”

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NAB also addressed what it described as a growing trend in user interface design that makes broadcast television harder to access.

“There is a growing trend on some models toward user interfaces and setup flows that make antenna-delivered television more difficult to locate or require additional steps compared to other video services,” the filing stated.

Rather than proposing specific interface requirements, NAB asked the FCC to establish expectations that broadcast reception capabilities remain accessible to consumers while monitoring how device design evolves. “Setting that expectation will help guide industry practices and ensure that receivability keeps pace not only in theory, but in everyday consumer use,” the organization stated.

The filing noted that Section 303(s)’s requirement that receivers be capable of “adequately receiving” broadcast signals should encompass both technical reception capability and the ability of viewers to readily find and access broadcast television on devices marketed as televisions.

Regulatory flexibility and content protection

NAB supported the FCC’s proposals to eliminate mandatory simulcasting and “substantially similar” programming requirements, describing these rules as barriers to deploying advanced capabilities.

“These rules were appropriate as temporary safeguards during the earliest stage of the transition but have now become barriers to progress and constrain deployment of ATSC 3.0’s core public interest benefits,” the filing stated.

On content protection, NAB argued that encryption capabilities are necessary for broadcasters to compete for high-value programming, particularly live sports. The organization noted that competing platforms routinely offer content protection as a standard feature during rights negotiations for major agreements including upcoming NFL renewals.

The filing maintained that encrypted ATSC 3.0 transmissions meet the Communications Act’s definition of broadcasting and pointed to industry efforts through A3SA to address early implementation challenges with encrypted signals on certain devices.

Must-carry and technical standards

NAB requested that must-carry rights extend to ATSC 3.0 signals, arguing this is essential for stations to use the flexibility the FCC’s proposals would provide. The filing referenced newly published ATSC standards, including A/371:2025, which addresses delivery of ATSC 3.0 services for redistribution to cable and other MVPD systems.

The association opposed requirements to dedicate specific spectrum portions to free over-the-air programming, noting that ATSC 3.0’s OFDM-based architecture allows dynamic capacity allocation. “There is no meaningful mechanism by which a broadcaster or the Commission could calculate, monitor or enforce a requirement that a specific percentage of spectrum be dedicated to any particular use,” NAB stated.

Regarding the ATSC A/322 physical layer standard requirement set to expire, NAB noted that while no alternative standard has emerged in nine years, it would support a limited three-year extension if the FCC determines one is warranted for regulatory certainty.

The filing also addressed emergency alert systems, accessibility requirements and privacy considerations, stating that existing rules adequately cover ATSC 3.0 deployments and that no broadcast-specific privacy regulations are necessary beyond current consumer protection frameworks.

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Rick Kaplan, Emily Gomes and Alison Martin signed the filing on behalf of NAB.