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May 2007

11 Tips to Ensure Your Third-Party Sales Program Qualifies

Third-party sales circulation programs are popular for many newspapers. According to Sept. 30, 2006-ending Publisher’s Statements, approximately 400 newspapers reported some form of a third-party transaction.

Here are some tips to help ensure that your third-party sales program complies with ABC rules. A complete guide to ABC’s third-party sales rules and guidelines is available on our Web site.



  1. Make sure that your purchaser is an eligible purchaser according to ABC’s guidelines and rules. Examples of eligible purchasers include realtors, restaurants, theaters and airlines.

  2. Make sure that a qualifying price is paid. For U.S. newspapers this means the newspaper must be paid at least 25 percent of the basic price, net of all considerations.

  3. When calculating the qualifying price for your third-party circulation, make sure you base it on the correct basic price. Distribution that is only for one specific date is based on the single-copy basic price. Distribution for multiple dates is based on the home-delivery basic price that most closely resembles the frequency of distribution and the term of the third-party program.

  4. Ensure that your third-party sales contract is easy to follow and that all considerations are billed at the fair market value. Considerations include advertising on wraps, ROP advertising and delivery or distribution credits.

  5. Notify the recipients who have purchased or sponsored the newspaper they are receiving. A sample of the written notification must be retained for the auditor’s review.

  6. Know where the third-party sales newspapers are distributed. Newspapers need to maintain records, such as route lists, detailing the distribution method and ensure that the newspapers are actually distributed.

  7. If barter payment is used for your third-party sales program, ensure that the items are eligible per ABC’s guidelines and available for sale in the public domain. All bartered items must be given a value that is supported by documentation, such as a rate card, price sheet or Web site listing.

  8. If barter payment is used for your third-party sales program, maintain supporting documentation of receipt of the bartered items as payment within the newspaper’s accounting records. The third-party purchaser must also reflect the bartered item as an expense. Financial management representatives from both the newspaper and the third-party purchaser familiar with the companies’ financial recordkeeping are required to sign barter attestations.

  9. Ensure that you invoice the third-party purchaser during the first normal billing cycle following the distribution dates. Also, ensure that the invoice itemizes the cost of the newspapers in the third-party program separately from the cost of any additional goods or services provided to the purchaser as part of the third-party sales transaction.

  10. Make sure the purchaser pays the invoice in full after the normal net “30/60/90” day accounting cycle. For any invoice that remains unpaid or written off as bad debt, the newspaper must remove those copies from paid circulation on ABC reports.

  11. Most importantly, it is required that you notify ABC of all third-party sales programs you intend to include as paid circulation on ABC reports at least 14 days before the beginning date of distribution. Without this notification, the copies associated with your program will be reported as unpaid on ABC reports.

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