General
Q: When were these changes effective?
A: October 1, 2010. The first Publisher’s Statement to reflect the new reporting format is for six-months ending March 31, 2011.
Q: Do you have a document that simply lists and summarizes all the changes that were effective October 1, 2010?
Q: Is there a prototype of the March 31, 2011, Publisher’s Statement?
Q: Is there a prototype of the March 31, 2011, FAS-FAX?
Q: Is there a prototype of an Audit Report available?
Q: Who do I contact with specific questions about my newspaper and the rules and reports?
Individually Paid
Q: What is individually paid circulation?
A: Individually paid circulation represents subscriptions and single-issue sales of print and electronic editions ordered and paid for by individual consumers, at not less than one cent per copy or subscription, net of considerations. The phrase ‘net of all considerations’ means the purchaser paid a qualifying price for the subscription or single copy in addition to the value of any other product or service bundled with it.
Individually paid circulation has the following subclasses:
- Home Delivery/Subscriptions
- Joint Distribution Agreements (JDAs)
- Mail
- Single-Copy/Single-Issue Sales
Q. Have the individually paid circulation requirements changed since October 1, 2010?
A: Not really. The subclasses and their respective qualification requirements are the same as they were prior to October 1, 2010. Intermittent subscriptions, also known as bonus days, continue to be included in individually paid circulation through April 1, 2011, but are limited to a maximum of 25 (for the 12-months ending March 31, 2011). As of April 1, 2011, this type of home-delivered distribution will fall under verified, home delivery-targeted circulation.
Q: Do you have a resource that outlines the qualification requirements and promotional material for specific types of common individually paid programs—like discounts, premiums, combination sales, etc.?
Paid Business/Traveler
Q: What is paid business/traveler circulation?
A: Paid business/traveler circulation represents subscriptions and single-issue sales of newspapers, including:
- Copies purchased by a business for designated employees known by name or title (group).
- Copies purchased by hotels for distribution to its guests in common areas or rooms.
- Copies purchased by the guest via a refund approach upon registration.
See also ABC Rule C 3.4 Business/Traveler Copies.
Paid business/traveler circulation discloses the following subclasses:
- Group
- Hotel Distribution - Guest refund based
- Hotel Distribution - Purchased by hotel for guests
Q: Do you have a resource that outlines the qualification requirements for each of these subclasses?
A: Yes. Please see the business/traveler guide for detailed qualification requirements and examples of hotel notifications for each subclass of business/traveler circulation.
Q: I have a company that wants to purchase copies for its employees. But they want to have them available in lunch areas, break rooms and at the front desk, rather than addressed to specific people or positions. Do these fall under business/traveler?
A: No. Paid business/traveler only includes copies purchased by a company for specific employees known by name or title. If the copies are for common areas, they may be eligible for classification as verified, retail business circulation.
Q: I have a guest-refund based program that was classified as other paid, single-copy sales. Are the guest-refund based programs under paid business/traveler the same thing?
A: Yes, exactly the same. The only difference is how it is classified. As of October 1, 2010, it is no longer other paid, single-copy sales, but rather paid business/traveler circulation.
Q: I have third-party sales programs where the hotel buys copies for distribution to its guests. Are the “purchased by hotels for guests” programs under paid business/traveler the same thing?
A: Yes, exactly the same. The only difference is how it is classified. As of October 1, 2010, it is no longer third-party sales, but rather paid business/traveler circulation.
Q: I have current third-party sales programs where a sponsor buys copies for distribution at hotels. Does this fit into business/traveler?
A: No. Paid business/traveler only includes hotel copies that are purchased by the guest (via refund option) or by the hotel. However, if the hotel requests and controls the distribution of the copies, but they are non-paid or paid for by third party, the copies are eligible for classification as verified, retail business circulation.
Verified Circulation – General
Q: What is verified circulation?
Q: Do you have a resource that outlines the qualification requirements for each of the verified circulation subclasses?
A: Yes. Please see the verified circulation guide for detailed qualification requirements and program examples for each verified subclass.
Q: Is there a limit to verified circulation?
A: To maintain ABC membership eligibility, at least 70 percent of a U.S. newspaper’s total circulation must be classified as paid on ABC documents. This 70 percent total excludes verified circulation, other audited distribution and unpaid circulation. As a result, the total verified, other audited distribution and unpaid circulation, combined, is limited to 30 percent of the total average circulation on any Publisher’s Statement or Audit Report. See ABC Bylaw 2.11 that governs a newspaper publication’s eligibility for ABC membership. See example calculation.
A: No. ABC’s qualification review and audit processes doesn't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.).
- The focus of ABC qualification and classification for verified circulation is confirmation of request, distribution location and delivery.
- Payment for verified newspapers may be obtained from third parties (sponsors) who wish to partner with the newspaper to promote their business. Since the consumer isn’t paying for the newspaper, the copies are still classified as verified for ABC reporting purposes, regardless if any payment for the newspapers is obtained from an outside source.
- A newspaper may also wish to charge a third party (sponsor) for additional services related to the verified circulation effort, such as ROP advertising, in-store signs, and wraps to promote the partnership. The decision to charge any amount or nothing for these services is up to each individual newspaper and not governed by ABC.
Q: Is the "Retail/Business" subclass the same as what was once considered third-party sales?
A: No. This subclass has been defined with specific parameters and may only include a portion of what you had previously classified as third-party sales. Please refer to the qualification requirements for verified, retail business circulation.
Q: Are "Educational Copies" the same as what was once considered classroom NIE programs and are "University Copies" the same as registered college student programs?
A: Yes, however ABC no longer considers or reviews any financial transactions related to school copies. Please refer to the qualification requirements for verified, educational program copies.
Q: Are "Employee Copies" the same?
A: Yes, exactly the same. The only difference is how it is classified. As of October 1, 2010, it is no longer classified as other paid circulation, but rather verified, employee copies.
Verified, Home Delivery – Requested
Q: What is verified, home delivery – requested circulation?
Q: Do you have a resource that outlines the qualification requirements for verified, home delivery – requested circulation?
Q: If someone requests a subscription, but it's for a term of less than 12 weeks is it eligible for verified, home delivery – requested?
A: No. Even though the recipient requested the subscription, the minimum term of 12 consecutive weeks must be met in order to qualify and be classified as verified, home delivery – requested circulation. If a request is made for a term of less than 12 consecutive weeks the copies served are eligible for classification as verified, home delivery – targeted.
Q: If an individual requests a subscription for a term of 12 or more consecutive weeks, but cancels prior to the full 12-week minimum service, are those copies still classified as verified home delivery – requested?
A. No. If an individual orders a term of 12 or more weeks, but cancels delivery before the 12-week term is served, the copies served prior to cancellation are eligible for classification as verified, home delivery – targeted.
Q: Can the subscription be for any frequency?
A: Yes, it can. The request form should identify the frequency of delivery.
Q: What if a business requests a subscription for a term of at least 12 weeks, can this be verified, home delivery – requested?
A: No. Verified, home delivery – requested is intended to be just that—delivered to individuals at their residential homes, not businesses.
Verified, Home Delivery – Targeted
Q: What is verified, home delivery – targeted circulation?
A: Verified, home delivery – targeted circulation represents subscriptions or single issues delivered to individual residences. The copies are distributed to residences targeted by the publication (for any term), requested by a third party (for any term) or requested by an individual recipient for a term of less than 12 weeks. See ABC Rule C 3.3 Other Verified Distribution, section (b).
Q: Do you have a resource that outlines the qualification requirements for verified, home delivery – targeted circulation?
Q: If I solicit a local business to distribute newspapers to homes to promote their sale, grand opening, etc., would this circulation fall under verified, home delivery – targeted?
Follow-up: What if I charge the business for the papers; can the circulation be classified as paid?
A: No. Even though you may decide to charge the business for the papers, advertising or other services, the end recipient (resident) didn't pay for the newspaper, so the copies won't qualify for paid circulation on ABC documents. The copies remain in verified, home delivery – targeted, regardless if payment is obtained from the business.
Follow-up: If I give the business free advertising in the paper on the days of this delivery (ROP, insert, etc.), does the circulation still qualify as verified, home delivery – targeted?
A: Yes. ABC doesn't consider financial, advertising, or other transactions when qualifying verified circulation. The focus of ABC qualification and classification for verified circulation is confirmation of request, distribution location and delivery.
Q: Does a business have to order these verified copies, or can the newspaper just decide to sample households in a specific area and classify them as verified, home delivery – targeted?
A: A business doesn't have to order them. Copies the newspaper chooses to distribute to residential households (often referred to as sampling) are eligible for inclusion in verified, home delivery – targeted.
Q: Is this where intermittent subscriptions (bonus days) to paid subscribers are classified as of April 1, 2011?
A: Yes. As of April 1, 2011, verified, home delivery – targeted circulation will include copies served to paid subscribers on days not noted as included with their subscription at the time of order.
Verified, Retail/Business
Q: What is verified, retail/business circulation?
Follow-up: What if I charge the business for the papers; can the circulation be classified as paid?
A: No. Even though you may decide to charge the business for the papers, advertising or other services, the patrons didn't pay for the newspaper, so the copies won't qualify for paid circulation on ABC documents. The copies remain in verified, retail/business, regardless if payment is obtained from the business.
Follow-up: If I give the business free advertising (ROP, insert, etc.) during the period they distribute newspapers, will the circulation still qualify as verified, retail/business?
A: Yes. ABC doesn't consider financial, advertising, or other transactions when qualifying verified circulation. The focus of ABC qualification and classification for verified circulation is confirmation of request, distribution location and delivery.
Q: What if a business orders copies for reoccurring delivery, but wants them distributed at locations such as sporting events, festivals, trade shows, or theaters?
A: These copies are classified as unpaid circulation as of October 1, 2010.
Q: Do you have a resource that outlines the qualification requirements for verified, retail/business circulation?
Q: Is there a limit on the volume of circulation classified as verified, retail/business on ABC documents?
Verified, Educational Copies
Q: What are verified, educational copies?
A: The verified, educational subclass represents copies requested by and distributed to accredited classroom settings for use by instructors as part of the curriculum. See ABC Rule C 3.2 Educational Programs.
Q: Do you have a resource that outlines the qualification requirements for verified, educational copies?
Q: Are the classroom-setting copies essentially the same as the previous NIE programs?
A: Yes, except ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). The focus of ABC qualification and classification for verified circulation is confirmation of request, distribution location and delivery.
Q: If I charge the school for the papers or collect money from sponsors and fundraisers, can the circulation be classified as paid?
A: No. ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). Fundraising efforts and school payments don't impact the qualification or classification of verified, educational copies.
Q: Does ABC have rules governing how to structure raffles, pet contests, calendar sales, vacation donations, and other fundraising activities for educational copies?
A: No. ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). Fundraising efforts and school payments don't impact the qualification or classification of verified, educational program copies. As a reminder, you may still want to ensure your fundraising efforts comply with local, state and federal laws.
Q: Do copies going to Head Start programs qualify as verified, educational copies?
A: No. Head Start programs are for children not yet in kindergarten. Copies classified as verified, educational copies must be distributed to children in kindergarten and above.
Q: Are affidavits still required?
A: Yes - these affidavits provide ABC with assurance the schools received the copies, the volume received, the number of students in the class and that the copies were used in the classroom.
- Follow-up: What information should be included on an affidavit?
A: Affidavits should attest to the following (See also example affidavits):
- Name and address of school
- Statement to confirm the newspapers were ordered, received and used in the classroom as part of the curriculum
- The quantity of copies and number of students in the classroom
- Date(s) or date range that the copies were received
- Name of teacher(s) who received the distribution (if completed by a principal)
- Printed name, title and phone number of the person signing the affidavit
- Signature and date
- Follow-up: How often do affidavits have to be submitted?
A: At least once annually.
- Follow-up: Can the order form serve as the affidavit?
A: No. An affidavit attests to how the program was actually executed. A teacher or principal can’t attest to receiving or using the paper at the time or order—only after delivery and use of the newspapers.
- Follow-up: Does ABC accept electronically submitted affidavits?
A: Affidavits submitted electronically to the newspaper are acceptable to ABC (i.e., e-mail or online). Since a signature is not attainable electronically, the individual completing the form should include a statement confirming the information provided in the electronic affidavit is true and accurate. For example, “I agree the above information is complete and accurate.” The auditor may deem it necessary to directly contact the teacher or school official to confirm the information contained in the affidavit.
Q: If a school requests digital editions, can I classify these digital copies as verified, educational copies?
A: Yes, provided the qualification requirements for verified, educational copies are met. In addition, the request from the teacher or principal must specify digital delivery and the quantity of licenses wanted (equivalent to copies or subscriptions).
Q: Is there a limit to the volume of circulation classified as verified, educational copies on ABC documents?
A: The total number of copies classified as verified, educational copies (all editions, in aggregate) per day can’t exceed the number of students in the class (one may be added for the teacher). The total number of copies per school per day can’t exceed the number of students enrolled. See also verified circulation limitations.
Verified, University Copies
Q: What are verified, university copies?
Q: Do you have a resource that outlines the qualification requirements for verified, university copies?
Q: Is this essentially the same as the previous registered college student programs?
A: Yes, except ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). The focus of ABC qualification and classification for verified circulation is confirmation of request, distribution location and delivery.
Q: If I charge the school for the papers or collect money from sponsors and fundraisers, can the circulation be classified as paid?
A: No. ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). Fundraising efforts and school payments don't impact the qualification or classification of verified, university copies.
Q: Does ABC have rules governing how to structure raffles, pet contests, calendar sales, vacation donations, and other fundraising activities?
A: No. ABC’s qualification review and audit processes don't govern or consider financial transactions related to verified distribution (invoices, payment, rates charged, etc.). Fundraising efforts and school payments don't impact the qualification or classification of verified, university copies. As a reminder, you may still want to ensure your fundraising efforts comply with local, state and federal laws.
Q: Are affidavits required for university copies?
Q: Is there a limit to the volume of circulation classified as verified, university copies on ABC documents?
A: The total number of copies per school (all editions, in aggregate), per day can’t exceed the number of students enrolled. See also verified circulation limitations.
Verified, Employee Copies
Q: What are verified, employee copies?
Q: Do you have a resource that outlines the qualification requirements for verified, employee copies?
Q: Are the requirements the same for verified, employee copies as they were for other paid, employee copies?
A: Yes. The only difference is that it is classified as verified, employee copies as of October 1, 2010.
Q: Is there a limit on the volume of circulation classified as verified, employee copies on ABC documents?
A: The number of copies classified as employee copies can’t exceed the number of employees, agents or correspondents eligible to receive these copies. See also verified circulation limitations.
Updated 02/14/11
Rules & Resources