A surge of complaints about the volume of television commercials has highlighted ongoing concerns about how ads are perceived in relation to the programs they accompany. Despite regulatory rules designed to keep ad loudness in line with program audio, a notable rise in grievances through 2024 underscores lingering consumer frustration and the evolving landscape of broadcast, cable, satellite, and streaming services. Regulators, industry stakeholders, and advertisers are closely watching how compliance is measured, enforced, and potentially extended to newer distribution channels as viewing habits shift toward online platforms and on-demand models. This broader context raises questions about the effectiveness of existing guidelines, opportunities to tighten enforcement, and the balance between advertising revenue and viewer comfort.
Background: CALM Act, loudness standards, and the regulatory framework
The Commercial Advertisement Loudness Mitigation (CALM) Act established a fundamental rule for broadcast, cable, and satellite TV providers: the average loudness of commercials should match the average loudness of the programs they accompany. This principle aims to prevent sudden, jarring surges in sound when a commercial begins, which can disrupt the viewing experience and drive audiences to mute or switch channels. The CALM Act was designed to harmonize audio levels across the entire viewing experience, ensuring a consistent listening environment from program start to commercial end.
Enforcement of CALM Act requirements began in December 2012, setting a baseline expectation for how loudness is managed in linear television. The act directs providers to implement practices that align with industry standards and recommendations for production, post-production, and delivery. In addition to the rule itself, the act calls for adherence to the Advanced Television Systems Committee’s (ATSC) recommended practices, which outline technical guidance for producing content, applying metadata, managing audio dynamics, and controlling loudness throughout the distribution chain. The overarching goal is to achieve uniform loudness across programming and advertisements, thereby minimizing abrupt changes that can annoy or discomfort viewers.
Within these guidelines, the emphasis is not on a single loudness level but on consistency: if programs and commercials are produced to a stable average loudness and that loudness is preserved through the entire production, distribution, and delivery chain, audiences should experience fewer disconcerting shifts in volume. The ATSC guidance suggests that maintaining consistent loudness helps avoid issues such as signal clipping and overly aggressive peaks that distort listening clarity. This approach reflects a broader industry shift toward perceptual loudness normalization rather than relying solely on fixed peak levels, which can still feel uneven to viewers.
Over time, summaries and analyses of these rules have emphasized the practicalities of measurement, calibration, and enforcement. The CALM Act is intended to address a common consumer complaint—loud commercials—by establishing a framework that standardizes average loudness rather than relying on ad hoc adjustments by individual networks or platforms. As broadcast and pay-TV operators implement these standards, the goal is to foster a more predictable audio experience for households with a range of viewing environments and listening equipment.
In addition to the statutory mandate, the regulatory landscape includes the practical implications of how guidelines are translated into operational workflows. For broadcasters and distributors, implementing CALM Act-compliant loudness tracking requires integrated measurement tools, calibration processes, and metadata management to ensure that the advertised content aligns with the program audio throughout the delivery chain. The problem is not only adherence but also the variability of content and delivery formats across multiple platforms, including on-demand streaming effectively integrated into the traditional linear framework.
Trends in complaints and enforcement: rising grievances and interpretation of the CALM Act
Recent reporting has drawn attention to a noticeable uptick in complaints directed at the loudness of television commercials. While the CALM Act initially contributed to a reduction in loud ad grievances, the volume of complaints surged again in 2024. The trend has prompted regulatory bodies to reassess how compliance is achieved across evolving distribution methods and to explore whether existing rules fully address modern viewing patterns. The FCC has publicly indicated that it received a substantial number of complaints related to ad loudness in 2024, with figures showing a marked increase compared to earlier years. This shift has raised questions about whether the original mechanisms for monitoring and enforcement remain sufficient amid changes in audience behavior and technology.
The agency has noted that, in the past, the CALM Act appeared to yield improvements in ad loudness, suggesting an initial effectiveness of the policy. However, the latest data indicate that viewers continue to experience loud introductions or jarring transitions when ads commence, prompting renewed scrutiny of how sound levels are controlled throughout the viewing experience. The reported figures—lower counts in earlier years followed by a higher total in 2024—suggest a dynamic landscape in which ad content, distribution channels, and audience expectations are continually evolving. This evolution invites a deeper examination of whether current measurement methods capture all relevant factors influencing perceived loudness.
Several factors may contribute to the renewed complaints. Advertisers sometimes attempt to grab attention at the very start of a commercial with a bold, loud opening, then reduce intensity as the ad progresses. While such a strategy can be effective for early engagement, it may run counter to the intent of CALM Act compliance if the overall average loudness remains within mandated limits but abrupt increases at the opening create a jarring experience for viewers. The regulatory framework does not necessarily penalize a loud start if the ad’s average loudness over its entire duration complies with the standard; nonetheless, consumer perception often anchors on the first moments of an advertisement, leading to ongoing discontent.
The regulatory response to these complaints involves a combination of measurement precision, enforcement clarity, and transparency about how complaints are assessed and addressed. In practice, this means evaluating whether current tools accurately capture perceived loudness, determining the reliability of automated monitoring systems, and addressing potential gaps in how standards are applied across different platforms and content types. The conversation also touches on whether there should be greater accountability for advertisers who repeatedly push loud surges at the start of spots, possibly requiring new interpretation or adjustments to the rules to close perceived loopholes.
Industry observers have noted that changes in audience behavior—such as increased time spent viewing content online, on mobile devices, or through streaming services—could influence how complaints are interpreted and acted upon. If viewers encounter inconsistent loudness while watching content across devices or in mixed environments (home theater setups, smart TVs, or compact speakers), these experiences may feed into perceptions of non-compliance even when the average loudness remains within permitted ranges. Consequently, the interpretation of CALM Act compliance may need to consider not only average loudness but also perceptual loudness, transition smoothness, and the integrity of the entire audio chain from production to delivery.
The role of production practices, metadata, and the dynamic range
A key aspect of CALM Act compliance centers on production and post-production practices that help normalize loudness before content ever reaches the audience. The ATSC guidance advocates for careful management of dynamic range, consistent application of loudness controls, and the appropriate use of metadata to signal loudness levels across the distribution pathway. When production teams embed accurate loudness metadata and calibrate audio during post-production, broadcasters and distributors can more reliably maintain uniform loudness across programs and commercials. This reduces the likelihood of perceptual loudness spikes that can disrupt the viewing experience.
The recommended practices emphasize harmonizing loudness not only within a single program or ad but across the broader scheduling context, including transitions between content blocks. Properly managed dynamic range helps ensure that ad segments do not require abrupt changes in volume to maintain intelligibility. In practice, this means carefully balancing dialogue, music, and sound effects so that the overall loudness remains within a target range that is comfortable for a typical home listening environment. Tools and workflows that monitor loudness metrics in real time or near real time are increasingly important for maintaining compliance as content moves through the production, distribution, and display chain.
Metadata usage is a critical enabler for maintaining CALM Act standards in the era of multiple delivery channels. When loudness-related metadata is consistently produced and propagated alongside audio streams, downstream platforms can apply appropriate normalization or corrections during playback. This metadata helps ensure that ad content aligns with the corresponding program segments, even as content moves from traditional broadcast to streaming and online delivery. The challenge lies in achieving cross-platform interoperability and ensuring that metadata remains accurate across updates, re-encodes, or platform-specific processing steps.
Beyond metadata, producers and technicians must consider the practicalities of content delivery formats. Television audio can be distributed with varying encoding schemes, compression levels, and channel configurations. The aim is to ensure that these technical differences do not undermine the intended average loudness, which requires careful calibration at multiple points in the distribution chain. The emphasis on end-to-end consistency reflects a broader understanding that effective loudness management is an ecosystem problem, not one isolated component. As the broadcast environment evolves, so too must the tools, metrics, and quality assurance processes used to verify CALM Act compliance.
The streaming challenge: why CALM Act does not yet cover online ads and what could change
A distinguishing feature of the CALM Act is its focus on traditional linear distribution channels—broadcast, cable, and satellite. Streaming services, online platforms, and internet-delivered broadcasts have not historically been subject to the same formal CALM Act requirements. This gap means that ads shown on streaming platforms such as over-the-top services or other internet-based delivery models can diverge in loudness practices from those used in linear broadcasts. For viewers, this discrepancy manifests as ad breaks on streaming services that can feel louder or sharper than what they experience during regular programming, even if those platforms distribute similar content.
While the CALM Act does not automatically apply to streaming, there is growing recognition of the need to address loudness across online channels. Industry stakeholders and regulators have acknowledged the importance of extending consistent loudness standards to the web to create a uniform experience for consumers who switch between broadcast and online viewing. If the regulatory framework were extended to streaming, it would require the development of new enforcement mechanisms, measurement standards, and collaborative industry practices to ensure that ad content on the internet adheres to comparable loudness expectations.
The debate surrounding streaming regulation is complex and multifaceted. On one hand, there is a desire to protect consumers from abrupt ad loudness across all formats, which could improve overall satisfaction and reduce ad fatigue. On the other hand, online platforms operate under different business models, technical architectures, and monetization strategies. Implementing a universal loudness standard would need to account for the diverse nature of streaming services, including live streams, catch-up content, and ad-supported versus subscription-based content. The key challenge is designing a framework that is technically robust, practically enforceable, and economically viable for digital platforms and advertisers alike.
Regulators have signaled openness to exploring how to apply CALM Act principles to the online ecosystem, recognizing that the viewing landscape is increasingly dominated by streaming and online video. Potential approaches could involve standardized loudness measurement metrics suitable for streaming contexts, requirements for consistent loudness across ad breaks, and enhanced collaboration with industry groups to align practices. Any regulatory evolution would need to consider scalability, the variety of streaming delivery methods, and the global nature of many platforms that operate across borders.
FCC actions: seeking input, evaluating effectiveness, and potential future steps
In response to the evolving complaints landscape, the Federal Communications Commission has initiated a process to gather input from consumers and industry stakeholders on the effectiveness of CALM Act rules. The FCC’s outreach seeks to understand how well the current framework achieves its objectives in the face of changing viewing habits, new platforms, and the growing prevalence of streaming. By inviting public comment, the Commission aims to collect diverse perspectives on what works, what doesn’t, and what adjustments might be needed to enhance compliance and consumer satisfaction.
The agency is also assessing potential future actions, which could include refining measurement standards, expanding compliance to additional platforms, or introducing new enforcement mechanisms. The questions under consideration may address how to better quantify perceptual loudness, how to harmonize standards across different distribution channels, and what role metadata and technology can play in ensuring consistent loudness. The FCC’s approach to reform would likely balance the interests of consumers who want a calmer, more uniform listening experience with the interests of broadcasters and advertisers who rely on robust ad revenue to support programming.
Public participation in the process is essential for crafting policies that reflect real-world conditions. Stakeholders from broadcasters, cable operators, satellite providers, streaming services, advertising agencies, equipment manufacturers, and consumer advocacy groups can contribute insights based on experience with compliance challenges, measurement capabilities, and the practicalities of implementing new practices. The FCC’s engagement signals a collaborative approach that seeks to translate policy objectives into operational realities that improve the viewing experience while supporting a viable media ecosystem.
Possible future directions could include more precise measurement protocols, clearer enforcement guidelines, and timelines that accommodate ongoing technological transitions. Such steps might involve pilot programs, industry testing, and phased implementation plans to minimize disruption while advancing consumer protection goals. The scope of potential actions would need to address the realities of content delivery in a converging media environment and recognize the importance of both regulating harmful loudness practices and preserving legitimate advertising strategies that fund high-quality programming.
Production best practices and workflows to support CALM Act compliance
To sustain CALM Act compliance, production teams are increasingly adopting best practices that cover the entire lifecycle of content—from pre-production decisions to post-release monitoring. A core focus is the establishment of robust loudness targets and the consistent application of these targets across all program components, including dialog, music, effects, and any embedded promotional material. By implementing standardized loudness targets at the source, teams reduce the risk of ad breaks deviating from expected levels when the content is delivered to audiences.
One critical area is the calibration of audio processing tools and loudness meters used during production. Engineers and editors set reference levels and monitor perceived loudness to ensure that the average loudness remains within the agreed-upon range. This often involves iterative adjustments during mixing and mastering to achieve a balanced acoustic footprint. The goal is to minimize perceptual discrepancies that viewers might notice during transitions between programming and commercials, thereby supporting a smoother overall listening experience.
Another important aspect is metadata management. When loudness metadata accompanies audio streams, it becomes possible for downstream platforms to apply appropriate normalization during playback. Accurate metadata reduces the likelihood of misalignment between the intended loudness of a program and the measured loudness of an advertisement. It is essential that metadata be consistent across all distribution channels, including content that is re-encoded or repackaged for different platforms. A well-managed metadata strategy helps ensure uniform loudness across devices and environments, reinforcing CALM Act objectives regardless of how viewers access content.
Quality assurance processes are also vital. Regular checks at multiple points in the delivery chain—production, post-production, distribution, and playback—help detect and correct loudness deviations before they reach audiences. This involves testing with a variety of playback devices, environments, and content types to verify that the loudness remains stable and within the target range. The use of redundancy in measurement and cross-verification across tools can improve confidence in compliance and reduce the risk of regulatory exposure or viewer dissatisfaction.
In addition to technical measures, organizational practices matter. Clear accountability for loudness management, defined roles in the production workflow, and ongoing staff training ensure that loudness considerations are integrated into daily operations rather than treated as an afterthought. Cross-functional collaboration among production teams, sound engineers, program directors, and compliance personnel helps align creative goals with regulatory requirements, supporting a consistent and high-quality audio experience for viewers.
The advertiser perspective: balancing attention with compliance
Advertisers are acutely aware of the tension between capturing viewer attention and adhering to loudness guidelines. A loud opening can be an effective tactic to grab attention in a crowded advertising environment, while CALM Act compliance encourages a steadier overall loudness level across the commercial’s duration. The challenge for marketers is to design ads that are compelling without triggering perceived violations of the loudness standard. This entails thoughtful audio design, pacing, and production value that preserve impact while remaining within permitted loudness ranges.
From an operational standpoint, advertisers must work closely with production houses, sound engineers, and broadcasters to ensure that the final ad material meets regulatory requirements. This collaboration often involves pre-approval checks, adjustments to the audio mix, and careful consideration of how the ad will be delivered across different platforms. The potential for strategic differences arises when an ad is run on multiple channels with varying technical specifications, which makes consistent loudness a shared responsibility among advertisers and distribution platforms.
Analytics and audience feedback also play a role in shaping advertising strategies under CALM Act considerations. Insights about viewer reactions to ad loudness can inform future creative decisions, leading to more harmonious integration of ads into the viewing experience. Advertisers may favor approaches that maintain engagement without triggering negative perceptions about loudness, thereby supporting long-term brand sentiment and reducing the likelihood of customer churn associated with unfavorable ad experiences.
As streaming services expand their advertising footprints, advertisers face new opportunities and constraints. Online platforms may use different ad formats, insertion techniques, and targeting capabilities, all of which influence how loudness is applied and measured. The industry’s collective experience in adapting to CALM Act principles across these environments will help determine whether further refinements to guidelines are necessary to maintain consistent consumer experiences across broadcast and online ecosystems.
The regulatory horizon: potential extensions and implementation challenges
Looking ahead, policymakers and industry participants are weighing the feasibility and desirability of extending CALM Act principles to streaming and other online delivery models. The core objective of protecting viewers from abrupt ad loudness is widely supported, but the regulatory approach must account for the technical and business realities of digital platforms. Key challenges include establishing universal measurement standards that work across diverse streaming architectures, ensuring cross-border applicability for global platforms, and balancing regulatory goals with innovation and competition in the digital media space.
Implementation considerations would include defining a clear and enforceable set of loudness targets for streaming, specifying how measurement should be conducted in on-demand and live contexts, and determining which entities are responsible for compliance and enforcement in a multi-actor ecosystem. This could involve collaboration among regulators, industry groups, platform operators, network owners, advertisers, and consumer advocates to develop practical guidelines that can be adopted globally while remaining adaptable to evolving technologies.
A practical path forward might involve phased adoption, starting with streaming environments that mirror traditional broadcast expectations and gradually expanding to broader online contexts. Early pilots and impact assessments could help refine measurement methodologies, verify feasibility, and identify unintended consequences. Success would hinge on transparent reporting, robust technical standards, and a shared commitment among stakeholders to prioritize viewer comfort without unduly limiting advertising revenue streams that fund content production.
Public awareness, consumer education, and the user experience
An informed viewing public is essential for the CALM Act’s continued relevance. Consumers benefit from understanding that a consistent loudness baseline does not require ad breaks to be identically silent but rather to maintain uniformity between program audio and commercials. Education efforts can help viewers recognize that loudness normalization is a technical objective designed to reduce pain points and enhance overall enjoyment of television and streaming experiences.
Media literacy initiatives could emphasize how audio standards affect the home theater experience, the role of metadata in ensuring consistent sound levels, and the importance of calibrated playback systems. Viewers who understand the rationale behind loudness management may be more patient with occasional variations when content is delivered through different devices or platforms, recognizing that industry-wide efforts are aimed at improving the baseline listening environment.
From a user experience perspective, the pursuit of CALM Act compliance should translate into smoother, more predictable audio transitions for most viewers. End-users may notice improvements in consistency as ongoing enforcement and updated practices take effect across networks and platforms. However, continued attention is required to address situations where loudness perception varies with room acoustics, speaker configurations, or individual hearing differences. The goal remains to minimize disruption and maintain engagement by delivering content with controlled and predictable audio levels.
Conclusion
The CALM Act represents a foundational effort to standardize the auditory experience of television by aligning the average loudness of commercials with that of the programs they accompany. Its intent is to reduce abrupt changes in volume that interrupt viewing and erode satisfaction with broadcast, cable, and satellite content. While the act achieved early gains in limiting ad loudness and improving the overall listening environment, evolving viewing habits, the growth of streaming services, and the advent of online delivery models have prompted renewed scrutiny of how effectively the rules operate in a rapidly changing media landscape.
Recent complaints in 2024 underscore that consumer frustration with ad loudness persists, highlighting the need for ongoing assessment, refinement, and potential expansion of regulatory coverage. The FCC’s openness to seeking input from consumers and industry stakeholders reflects a collaborative approach to addressing these challenges, balancing the goals of viewer comfort, regulatory clarity, and the sustainability of advertising-supported content ecosystems. As technology advances and distribution channels converge, the industry faces the task of implementing robust measurement, consistent production practices, and thoughtful policy design that can deliver a coherent and comfortable listening experience across both traditional and online platforms.
Ultimately, achieving true consistency in loudness across programs and advertisements requires coordinated action across multiple domains: standardized measurement practices, reliable metadata, proactive production workflows, cross-platform interoperability, and responsive regulatory frameworks. By continuing to invest in better tools, clearer guidance, and open dialogue among broadcasters, streaming services, advertisers, and regulators, the industry can strive toward a more seamless and viewer-centric audio experience that respects both the integrity of creative content and the comfort of audiences worldwide.
