With political advertising season getting underway, the VAB has three important items to share with you:

1. Unlimited use of the NAB PB-19 Forms for VAB Members:

We are excited to give you a new VAB member benefit that will likely save you money! The VAB has paid the NAB a fee to give all VAB members unlimited use of the NAB’s proprietary PB-19 forms for political candidate ads as well as non-candidate/issue ads that go into your Online Public Inspection Files. Normally, to use these forms, you have to pay the NAB $40.46 per station if you’re an NAB member or $44.95 per station if you are not an NAB member. But thanks to the VAB, you have unlimited use of both forms for all of 2026!

Download NAB-PB-19 Candidate Advertisements Form

Download NAB-PB-19_Non-Candidate Advertisements Form

2. Political Advertising Webinar Recording: 

In November 2025, Washington D.C. attorney David Oxenford hosted a webinar refreshing broadcasters on FCC political advertising rules and how to be compliant. Here is a link to watch the recording:

https://www.youtube.com/watch?v=3xnC9BdAYbQ

Download David Oxenford’s Political Refresher Slide Deck

3. New Vermont Law Requiring Synthetic Media Disclosures in Political Ads:
In March, the state legislature passed S23 and Gov. Scott signed it into law as Act 75 (attached). What this law says is, if a political candidate creates an ad or has an ad created by someone and it contains “deceptive and fraudulent synthetic media” and it airs 90 days before an election, it must have the following disclosure included:

“This media has been manipulated or generated by digital technology and depicts speech or conduct that did not occur.”

The VAB worked hard to ensure the new law included protections from liability and penalty for broadcasters who, because of FCC rules about equal time and censorship, have to air political ads they are given by the candidate making the ad buy. The law also has exemptions for broadcast news stories about a questionable political ad.

The VAB created a What You Need to Know About Use of Deceptive & Fraudulent Synthetic Media In Political Ads 90 Days Before An Election one-sheet. We are advising you read and share it with your sales, creative services and production departments and post it in your common areas so all your staff are aware of what is required if they create a political ad for a candidate that contains “deceptive and fraudulent synthetic media” that airs 90 days before an election.

It is the ad creator’s responsibility to include the mandatory disclosure if the ad contains “deceptive and fraudulent synthetic media” and airs 90 days before an election. If you’re given an ad by a political candidate, you will not be held liable or penalized for airing it even if it does contain such material. But, if your station employee is the one creating the ad for the candidate and they use “deceptive and fraudulent synthetic media” and it airs 90 days before an election, they must include the mandatory disclosure as outlined in the new law.

ADDITIONAL CAUTION FROM ATTORNEY DAVID OXENFORD – PLEASE READ:

Although broadcasters are protected from liability and penalty under S.23, D.C. Media Attorney David Oxenford cautions stations that an ad that is not sponsored by a candidate that uses AI and misrepresents what a candidate said or did, which a broadcaster runs knowing that the ad is untrue, can still create liability for the broadcaster under traditional concepts of defamation. A broadcaster who knowingly runs an ad that makes defamatory claims about a recognizable individual (like a candidate) can be held liable for continuing to run the ad once they are on notice of its contents. This is true whether the untrue statements contain any image of the candidate being attacked or not, and could apply whether a false image or voice of a candidate was generated by AI or by traditional editing techniques. An ad sponsored by a legally qualified candidate and only run over the air does not raise these issues even if it contains AI that misrepresents another candidate because the broadcaster cannot, under FCC rules, censor an ad from the candidate themselves. But ads from PACs, political parties, and other interested groups can raise this issue. Stations should contact their own attorney to see if there may be any liability under defamation law or under other legal principles.

David wrote more about this concern in this blog article:  https://www.broadcastlawblog.com/2026/03/articles/ai-in-political-attack-ads-watch-state-laws-on-deep-fakes-and-synthetic-media-in-political-content/. The discussion of defamation is in the second half of the article.