The online playing field is in a state of constant evolution. This doesn’t mean you shouldn’t play. It simply means that you need to be flexible and ready to adjust your practices and guidelines to adapt to the shifting landscape. That said, the need to develop guidelines for online ad units offers unique challenges to public broadcasters, as the online space, unlike on-air, is not regulated by the Federal Communications Commission (FCC). If the government isn’t regulating, and stations have little experience with visual corollaries to on-air guidelines, how do you draw the line?
Most stations are seeking to retain the noncommercial feel of underwriting when it comes to online sponsorship and are creating online underwriting guidelines that keep the spirit of their on-air guidelines, while leveraging the unique qualities that digital creatives offer (immediate click through, instant engagement etc.). This provides continuity of experience from broadcast to web. Other stations are creating separate guidelines for their online activity that go beyond on-air restrictions. Keep the following considerations in mind as you think about your station’s approach to online sponsorship guidelines. ^top
Your online consumers are by-and-large your broadcast consumers. They don’t like “Lower My Bills” ads, they don’t want to hear about “One night only!” and they don’t expect to hear from you: “Try it FREE today!” The FCC does not regulate sponsor messaging in the online space like they do on-air, but just because you can go there, should you? If possible, try to conduct some research with your web users or members to gauge their tolerance of online sponsorship messages on your site -- both the content of the messages themselves, and the amount of space/time you have devoted to messages. ^top
Unrelated Business Income Tax (UBIT) is something you need to be aware of and understand. UBIT applies specifically to nonprofit organizations and involves earned revenues not substantially related to furthering the tax-exempt purpose of the organization. UBIT does not apply to traditional on-air underwriting because your station is not selling advertising: it is acknowledging station funders. However, as stations move more into the online sponsorship world with more aggressive messaging and sales techniques, you may find that UBIT applies. A good rule of thumb is the “better safe than sorry” approach. If you allow sponsor messages that would not be permitted on-air because they fall outside of FCC regulations (i.e. they include a call to action, qualitative or comparative language or references to price or value), or if you sell by impression with guarantees, you most likely need to pay UBIT. If you’re reasonably close to or exactly following the same guidelines you do on-air and avoiding per-impression sales in favor of monthly placements without impression guarantees, UBIT should not apply to underwriting announcements on your site. Does this mean you should have the same guidelines on-air and online or that UBIT is bad? No. It just means you pay taxes and must account for that in your projections.
We strongly advise your station to review the IRS’ UBIT documentation with your legal counsel and determine your own best way to approach UBIT, especially if you are moving into any gray areas or if your UBIT is excessive in comparison to your station’s other revenue, which could threaten your station’s non-profit status. That documentation is available here. ^top
Guidelines can be lengthy or brief. Be as specific as possible in your guidelines—not only what the messages can contain, but also the technical guidelines (is audio allowed, animation limits, Flash parameters, file size etc.) We’ve includedstation online sponsorship guidelines examples on myPBS. The Internet Advertising Bureau is also a good resource, as is the National Public Media site. NPM reps both PBS and NPR digital properties nationally. NPM guidlines and specs are available here. ^top
As with PBS’ on-air underwriting guidelines, PBS has adopted its own online sponsorship guidelines as a form of self-regulation. This is in the interest of creating and preserving an uncluttered online environment similar to PBS’ uncluttered, noncommercial on-air environment while still permitting us to effectively receive the benefit of the upsurge in demand for online sponsorship.
PBS national online sponsorship guidelines apply uniformly to national sponsors and producers that have underwriting credits attached to content that is distributed by PBS’ national online distribution services (e.g. PBS.org, pbskids.org, PBS mobile apps) and/or via PBS’ national agreements with third party online content distributors (e.g. AppleTV, Roku and other Over The Top (OTT) content streaming partnerships). In the case of multi-platform sponsorships, where a sponsor is acknowledged both on-air and online around specific content, the on-air credit is typically used in both environments.
The national PBS Online Sponsorship Acknowledgement Guidelines for program sites are available here: https://docs.pbs.org/display/PX/Digital+Sponsorship. They contain the following considerations specifically:
- Program Site Messaging Requirements
- Message-to-Content Proportions
- Links to Specific Technical and Creative Parameters for Enhanced Sponsorship Messages on Program Web Sites (includes display ads, streaming, podcasts, message length & placement etc. )
- Categorical Exclusions
- Strictly Prohibited Units/Creative/Message Content
- Strict Reviews (calls to action, pricing/offers, competitive claims, controversial topics, rated R movies, superlatives, prescription drugs etc.)
PBS recognizes that some sponsors may wish to promote their relationship with PBS, and/or PBS KIDS on their own website(s) or online materials. In these instances, PBS has specific requirements and rules for brand partners and third parties, including national sponsors.
Local stations may adopt the national PBS online sponsorship guidelines as their local online underwriting guidelines; however, local stations are not required to adhere to national underwriting policies for local online credit content, duration and placement on their respective local station website(s). Please note that at this time, it is not possible to credit local sponsors on the national PBS.org website(s); suggested considerations for local online sponsorship guidelines, as discussed in this publication, relate exclusively to local sponsors credited on local station website(s) and other local digital assets. ^top
PBS National Approval Process
National online sponsorships must be approved by the PBS Digital Sponsorship staff, in consultation with the PBS Standards and Practices staff when appropriate.
The process for securing approval for online underwriting credits on PBS national Web sites is built into the process for delivering national online program content to PBS for hosting on PBS.org.