Joel Allis | TPA Periodicals Consultant
Effective May 9, the U.S. Postal Service will allow electronic paid/requester subscriptions to be included on the Statement of Ownership, Management, and Circulation, PS Form 3526. The deadline to file is Oct. 1.
The updated electronic form on PostalOne! will not be available until 2013. The updated hard copy form is not currently available either, but information will be sent out as soon as this new form is made available.
The final Federal Register rule related to this change is available on Postal Explorer under the Federal Register Notices tab. This change has been in the works for several years and is largely the result of efforts by the National Newspaper Association. Max Heath, NNA’s postal chair, wrote a full-page article describing the changes and requirements related to this topic in NNA’s June 2012 Publisher’s Auxiliary.
Including electronic paid subscribers on the Statement of Ownership is optional. Postal regulations require that more than 50 percent of a newspaper’s total distribution go to paid subscribers. Under this new rule, at least 40 percent of the newspaper’s paid distribution must consist of printed copies. This would allow 10 percent of the paid distribution to be electronic paid subscribers.
Reporting less than 60 percent total paid subscribers on your Statement of Ownership could trigger a USPS circulation audit of your publication. That has been the case for many years. Under the new rule, if you claim less than 60 percent paid circulation and claim electronic subscribers, you will be responsible for obtaining an outside circulation audit to be conducted by a certified audit bureau. This could be a considerable expense.
A print subscriber that is given free access to the electronic version of your newspaper does not count as an electronic paid subscriber. To count as an electronic paid subscriber, the electronic subscriber must pay more than a nominal rate for the electronic subscription. Nominal rate is understood to be at least 30 percent of the basic annual rate. This would require the publication to establish a basic electronic subscriber rate. (For example: $30 a year. Subscribers paying at least $9 a year for an electronic subscription would count as electronic paid subscribers.)
There will likely be some confusion in the first year of filing under these changes, especially since the updated hard copy form may not be available until the last minute. Remember, claiming electronic paid subscribers is voluntary. If you have any questions please contact me at 512-413-4122 or