A wave of complaints about the volume of television commercials has persisted for years, prompting ongoing scrutiny from the Federal Communications Commission. The CALM Act, mandatory since 2012, requires broadcast, cable, and satellite TV providers to ensure that commercials maintain the same average loudness as the programs they accompany. Yet, new data and industry commentary suggest that the problem has not only persisted but fluctuated, with a notable spike in complaints during 2024. The FCC is reexamining its approach, inviting feedback from consumers and industry stakeholders, and weighing potential actions that could extend the CALM Act’s reach, possibly even to streaming platforms if regulatory frameworks evolve. This evolving situation sits at the intersection of consumer experience, regulatory design, technology standards, and the changing architecture of how audiences access television and video content in the digital age. The discussion below revisits the Act’s core provisions, traces recent complaint trends, analyzes the role of streaming services, explains the FCC’s current stance, and considers the broader implications for viewers, advertisers, and platform ecosystems.
The CALM Act and its enforcement framework
The Commercial Advertisement Loudness Mitigation (CALM) Act was enacted with the explicit purpose of preventing abrupt increases in loudness when advertisements transition from program content to commercials. The central requirement is straightforward in principle: broadcast, cable, and satellite television providers must ensure that commercials have the same average volume as the programs they accompany. This standard is designed to deliver a consistent, predictable listening experience for audiences, reducing the jarring shifts that can occur when an ad begins at a noticeably higher volume than the surrounding content.
Since its effective date in December 2012, the CALM Act has been reinforced by complementary guidance from the Advanced Television Systems Committee (ATSC). The ATSC’s recommendations extend beyond average loudness, addressing a broader framework of production and delivery practices. The ATSC guidance encompasses production standards, post-production workflows, metadata usage, and the management of dynamic range. Collectively, these practices are intended to foster consistency in perceived loudness and to minimize signal clipping as content moves through the production, distribution, and delivery chain.
The essence of the ATSC guidance is that if all programs and commercials were produced to a consistent average loudness, and if that loudness were preserved throughout distribution and delivery, listeners would be shielded from disruptive loudness fluctuations within programs and across program-to-commercial transitions. In practical terms, this means a concerted effort by content creators, distributors, and operators to calibrate audio in a way that maintains a stable listening environment for audiences, avoiding abrupt spikes during commercial breaks.
From a regulatory perspective, the CALM Act imposes a framework in which compliance is evaluated at the level of average loudness, rather than focusing exclusively on peak levels or dynamic range in isolation. This approach acknowledges the realities of modern audio production, in which loudness can vary due to music cues, sound design, dialogue levels, and program genres. The FCC’s enforcement framework, while not described in exhaustive detail in public documents, centers on monitoring and responding to consumer complaints, as well as conducting periodic reviews of industry practices to assess effectiveness and identify potential gaps.
In the broader ecosystem, the CALM Act interacts with theATSC’s recommended practices by providing a regulatory baseline (average loudness parity) while the ATSC offers technical guidance that can help content creators and distributors align their production and delivery processes with best practices. When these elements work in concert, they have the potential to standardize loudness across a wide range of content and delivery channels, helping to reduce listener fatigue and improve overall viewing comfort.
The ongoing challenge, however, lies in translating these standards into consistent practice across a diverse and rapidly evolving media landscape. Traditional broadcast and cable platforms have long relied on established workflows and measurement tools to maintain consistent loudness, while newer distribution channels—such as streaming services and online platforms—present different operational realities. The CALM Act’s intent is clear, but its practical application requires ongoing coordination among regulators, industry groups, and the companies that produce and distribute video content. This coordination becomes even more crucial as the industry explores new delivery models and expands into the web and cloud-based architectures.
Complaints trend and the 2024 spike
Evidence compiled over the past several years indicates that consumer frustration with loud commercials did not disappear after CALM Act implementation. In the years immediately following the Act, early indications suggested a reduction in loud ad incidents, but the trajectory did not remain uniformly downward. The FCC has reported a pattern in which complaints about loud commercials fluctuated, but the year 2024 marked a notable escalation in grievances compared with the two preceding years.
Historical complaint counts provide a useful frame for understanding this trend. In the earlier phase, the FCC documented approximately 750 complaints in 2022 and about 825 in 2023. By 2024, the agency cited a figure approaching 1,700 complaints, signaling a substantial uptick. This shift raises questions about the underlying causes and the effectiveness of existing enforcement and compliance mechanisms.
Several factors may contribute to the observed spike in 2024. First, the media consumption landscape has continued to evolve, with audiences increasingly consuming content across traditional linear platforms and streaming services. If traditional viewing audiences shrink, a paradoxical dynamic can emerge: the remaining viewers may be more vocal about perceived issues, and platforms may prioritize metrics or business models that inadvertently influence loudness patterns during ad bursts. Second, the complaint spike could reflect a broader re-emphasis on consumer rights and quality-of-experience concerns in the digital age, prompting more viewers to report experiences that disrupt their viewing. Third, as programs and ads are produced by a wide array of studios and networks with varying production practices, there could be ongoing drift or lapses in the precise adherence to loudness targets, especially as content becomes more diverse in genre and format.
One notable facet of the 2024 observations is the persistence of “start loud, then settle” ads within some campaigns. Advertisers may attempt to seize viewers’ attention with an initial burst of loudness, then reduce the volume for the remainder of the ad, a practice that can blur the lines of compliance with the CALM Act’s emphasis on consistent average loudness. While such tactics may achieve short-term engagement, they can still contribute to viewer annoyance and to the perception that ads are disproportionately loud at certain moments, thereby influencing complaint behavior. The FCC’s examination of this pattern underscores the need to assess not only average loudness across the ad but also the acoustic envelope and moment-to-moment variations that contribute to perceived loudness.
From a regulatory and enforcement standpoint, the trend underscores both progress and limitations. The CALM Act has achieved measurable improvements in many instances, but its effectiveness depends on sustained adherence by content creators, advertisers, and distribution platforms, as well as on robust measurement and enforcement practices. The FCC’s annual tally of complaints is a key indicator, yet it represents a public-facing lens on a broader system of technical compliance. The agency’s ongoing monitoring and willingness to reexamine the rules reflect a recognition that consumer expectations and industry technologies are continually evolving, requiring adaptive governance that can respond to new patterns of loudness and new distribution modalities.
The 2024 spike also raises questions about whether the reporting mechanisms themselves have changed. As audiences gain access to a wider array of devices and services—ranging from traditional TVs to streaming devices, smart TVs, and connected home ecosystems—the channels through which complaints are submitted may expand, potentially contributing to higher reported figures. The FCC’s role, then, includes not only enforcing loudness norms but also ensuring that complaint pathways are accessible, efficient, and capable of capturing consistent data across platforms and regions.
As the agency contemplates the next steps, the emerging data on 2024 complaints will be a central input for policy discussions. The Commission’s approach to applying the CALM Act more broadly, or extending its reach to non-linear web-based services, will hinge on a careful balance of consumer protection, industry feasibility, and the evolving economics of advertising-supported media. The trend line—rising complaints in 2024 after earlier improvements—acts as a signal that ongoing attention is warranted to maintain public confidence in the fairness and predictability of ad loudness, particularly as audiences navigate an increasingly fragmented media environment.
Streaming services and the CALM Act gap
A central dimension of the CALM Act’s effectiveness is its jurisdictional scope. The Act explicitly covers broadcast, cable, and satellite television providers, ensuring that commercials maintain a consistent average loudness with the programs they accompany on linear television. However, streaming services and online platforms operating on the open web do not fall within the CALM Act’s reach under current interpretation and enforcement.
This regulatory gap has grown in significance as audiences increasingly access video content through streaming services. Services that deliver broadcasts or channels over the internet, such as platforms offering live linear channels or online streaming of televised events, do not automatically inherit CALM Act obligations. Likewise, services that provide access to broadcast channels via the internet—such as certain streaming platforms that aggregate live channels—do not necessarily face the same loudness constraints as traditional linear TV delivery. In practice, this means that streaming services may distribute the same content with similar ads but without the CALM Act’s loudness requirements, creating a discrepancy in how loudness is controlled across different delivery paths.
The divergence between linear and streaming environments has intensified as streaming platforms have grown in popularity and sophistication. In recent years, streaming services have become major hubs for ad-supported revenue models, with many platforms incorporating live events, sports broadcasts, and other high-engagement programming. For some platforms, ads shown to all subscribers—even those on ad-free plans—illustrate cross-subsidization of content costs and the essential role of advertising revenue in sustaining the service’s business model. As a result, the loudness management challenge is not confined to traditional platforms but extends into a broader ecosystem where ads appear in diverse contexts, including on-demand content, live streams, and sports events.
From a policy perspective, the extension of CALM Act principles to web-based and online platforms poses substantial questions. If regulators were to apply similar loudness parity requirements to the online environment, they would need to develop new methodologies for measuring and enforcing compliance in a distributed, multi-platform architecture. Web-based delivery introduces complexities in content delivery networks, encoding profiles, transcoding pipelines, and metadata standards, all of which influence how loudness is measured and controlled. Compliance mechanisms would require consistent measurement standards across devices and platforms, as well as clear accountability for content producers, distributors, and streaming services.
The FCC has acknowledged these potential challenges and has suggested that bringing CALM Act rules to the web would require the creation of new methods for ensuring compliance. The agency’s stance indicates a willingness to explore expansion of the Act’s reach if it can design a practical, enforceable framework for online environments. This possibility resonates with broader debates about how to regulate the digital ecosystem to protect consumers from misleading or disruptive advertising practices, while preserving the innovation and economic viability of streaming platforms.
Beyond regulatory questions, streaming services present a unique set of consumer experience considerations. The rise of ad-supported tiers and the increasing prevalence of live events on streaming platforms have intensified the impact of loudness issues on viewer satisfaction. In some cases, streaming may feature the same ad content across multiple devices or regions, amplifying user frustration if loudness is inconsistent or poorly managed. Conversely, streaming platforms can leverage more granular, data-informed approaches to loudness normalization, using real-time measurement and dynamic range control to deliver a more consistent listening experience across devices. These technical capabilities hint at potential pathways for improved consumer experience even within a regulatory framework that evolves to cover online content.
The evolving landscape also raises questions about how content creators, advertisers, and platforms can align their practices with evolving expectations. If the CALM Act or similar loudness management rules were extended to the web, stakeholders would need to coordinate across production pipelines, digital rights management, delivery networks, and consumer devices to ensure uniform implementation. Such alignment could involve standardized loudness targets, metadata-driven guidance, and cross-platform quality assurance processes that enable consistent loudness regardless of the delivery channel. The result could be a more predictable and comfortable audio experience for viewers who increasingly engage with video content across a spectrum of screens and networks.
In this context, the vibrant growth of streaming and online video audiences presents both a regulatory challenge and an opportunity. While the current CALM Act framework may not apply to the web, the industry’s continued evolution toward loudness-conscious production, metadata usage, and standardized practices could drive improvements in how ads are delivered and perceived on streaming platforms. The FCC’s openness to considering web-based applicability signals a potential shift in policy direction, one that would require careful design to balance consumer protection with the operational realities and innovation dynamics of the online video ecosystem.
FCC’s response: seeking feedback and potential future steps
In the face of persistent complaints and the expanding landscape of video delivery, the FCC has signaled a proactive stance by initiating a process to reexamine its CALM Act rules and their effectiveness. The agency has invited input from both consumers and industry participants on the extent to which CALM Act rules are achieving their intended goals. This approach reflects a recognition that the regulatory framework must adapt to changing technologies, viewing behaviors, and advertising strategies.
The FCC’s engagement process is designed to gather diverse perspectives on several key questions. Among them are: how well do existing rules regulate average loudness across programming and ads in today’s ecosystem? Are there gaps in enforcement or compliance that hinder the Act’s effectiveness? What adjustments or clarifications could improve the clarity and enforceability of the rules? And what possible actions could the FCC and other stakeholders consider to strengthen adherence to loudness norms going forward?
Another focal point of the FCC’s inquiry concerns the potential extension of CALM Act-like controls to digital streams and online platforms. The agency has stated that if it decides to apply these principles to the web, it would require the development of new methods for ensuring compliance. This would involve addressing challenges inherent to web-based delivery, including measurement, metadata, and cross-platform coordination, as well as determining which entities would bear responsibility for ensuring compliance across a distributed delivery chain.
In this process, the FCC is balancing consumer protection goals with the practical realities of a dynamic media ecosystem. The agency must weigh the costs and feasibility of expanding regulatory reach against the potential benefits of more consistent loudness across platforms. The regulatory objective remains to minimize abrupt loudness changes that disrupt the viewing experience while preserving the viability of content creators and distributors who rely on advertising-supported revenue models. The reexamination process also offers an opportunity to refine measurement standards, update metadata practices, and clarify what constitutes compliance in evolving production pipelines.
The FCC’s call for public comment is paired with ongoing industry dialogue. Stakeholders—including broadcasters, cable and satellite operators, streaming platforms, advertisers, and consumer advocacy groups—are expected to contribute insights about practical approaches to compliance, enforcement resources, and the implications of potential policy changes for the ad-supported television economy. The outcome of these discussions could lead to refined rules, revised guidance, or even new regulatory instruments designed to address the cross-platform nature of modern viewing experiences.
Beyond rulemaking considerations, the FCC’s actions may influence the broader conversation about how regulators regulate advertising practices in a digital age. The Commission’s approach could set a precedent for how algorithmic advertising, dynamic ad insertion, and personalized content experiences intersect with public-interest goals, audience rights, and standardization efforts in audio quality. The evolving policy landscape will likely require ongoing collaboration among regulators, standard-setting bodies, and industry players to ensure that consumer listening experiences remain comfortable while maintaining a sustainable ecosystem for content creators and service providers.
In practical terms, the FCC’s current strategy emphasizes listening, analysis, and targeted action. By soliciting feedback from a wide range of stakeholders, the agency aims to identify concrete steps that could enhance the effectiveness of loudness management without imposing undue burdens on industry. The outcome could include clarifications of existing standards, enhancements to measurement and reporting practices, or the development of new technologies and workflows that facilitate consistent loudness across devices and platforms. The agency’s approach recognizes that the regulatory environment must be adaptable to the rapid pace of change in video delivery and advertising models, while staying anchored to the overarching goal of protecting the viewing experience.
Production standards, technical details, and the user experience
The CALM Act sits atop a bedrock of technical standards and industry best practices that address the measurement, production, and delivery of audio content. The interplay between the CALM Act’s regulatory requirements and the ATSC’s recommended practices forms a multi-layered approach to achieving consistent loudness. The underlying philosophy is that coordinated control of loudness across production, post-production, and distribution minimizes disruptions in the listening experience and reduces perceptual loudness differences that viewers notice between different segments of content.
Key elements of this framework include:
- Production and post-production norms: Content creators are encouraged to calibrate the audio loudness during production and to maintain that calibration through post-production workflows. This reduces the likelihood that ad content will diverge substantially from the program’s loudness profile, thereby smoothing the overall acoustic envelope.
- Dynamic range management: The guidance emphasizes controlling the range of loudness within a production, ensuring that transient spikes do not disproportionately impact the perceived volume. Proper dynamic range handling helps maintain a more stable listening experience across scenes, ad breaks, and transitions.
- Metadata systems: Accurate and consistent metadata is essential for informing downstream processing in distribution networks. Metadata can assist in maintaining uniform loudness by enabling compliant equipment to apply appropriate normalization or compression during delivery.
- Signal integrity and clipping avoidance: The recommendations stress maintaining clean signal paths and avoiding clipping, which can distort audio and contribute to perceived loudness fluctuations. A well-managed chain reduces the risk of abrupt loudness changes when ads begin or transition to content.
The practical impact of these technical considerations manifests in several ways. For viewers, better loudness management translates to fewer jarring changes when ads start, end, or interrupt a scene. For broadcasters and operators, adherence to these standards can streamline the production process, reduce the number of viewer complaints, and promote a more consistent brand experience for programming blocks. For advertisers, predictable audio levels help ensure that ad messages are delivered in a way that respects audience comfort while still achieving engagement objectives.
In streaming contexts, the absence of CALM Act enforcement creates both opportunities and challenges. On one hand, platforms can tailor their loudness normalization strategies to specific audiences, devices, and viewing conditions. On the other hand, the lack of uniform regulatory pressure can lead to a wider variance in loudness across streams, devices, and geographies. The industry’s ability to implement robust loudness control on the web hinges on the development and adoption of interoperable standards, cross-platform measurement tools, and transparent reporting practices that enable regulators and consumers to assess compliance.
From a user experience perspective, the overarching goal remains reducing cognitive load and annoyance associated with loud ad bursts. When programs and commercials are aligned in average loudness, and when the loudness envelope is carefully managed, audiences experience a more comfortable and less disruptive viewing environment. This, in turn, can influence viewer satisfaction, platform loyalty, and willingness to engage with sponsored content. The synergy between technical standards and consumer expectations underscores why the CALM Act and its accompanying practices matter beyond regulatory compliance: they shape the quality of everyday media consumption.
The interplay of standards and consumer expectations also has implications for advertisers’ strategies. Advertisers aim to deliver clear, impactful messages while respecting audience comfort. As loudness controls tighten and become more uniform, advertisers may shift toward creative approaches that maximize engagement within the bounds of acceptable loudness. This could involve more nuanced sound design, more precise pacing, and an emphasis on clear, high-quality production values that maintain audience attention without resorting to disruptive volume spikes. In effect, the convergence of technical standards and consumer sentiment can drive higher-quality ad experiences that benefit viewers and the broader advertising ecosystem alike.
Broader implications for audiences, advertisers, and platforms
The persistent focus on loudness and the CALM Act’s governance has sweeping implications for how audiences experience television, how advertisers craft messages, and how platforms design their delivery and measurement systems. The intersection of policy, technology, and consumer behavior shapes a complex ecosystem in which compliance, innovation, and user satisfaction must coexist.
For audiences, the primary benefit of well-managed loudness is a calmer, less intrusive viewing experience. When ads blend more naturally with program audio, viewers can follow content with less distraction and fatigue. This environment supports longer engagement, reduces the likelihood of early channel changes due to irritability, and contributes to a more seamless relationship with the media ecosystem. Moreover, the evolving regulatory conversation about applying CALM Act concepts to streaming and web-based platforms holds the potential to further elevate user experience across a broader range of devices and access points.
For advertisers, consistent loudness presents both a challenge and an opportunity. On the one hand, standardizing average loudness across programs and ads helps ensure that messages are delivered without triggering negative emotional responses associated with sudden loudness. On the other hand, advertisers must craft creative content that respects sound-to-voice relationships, dynamic range, and pacing, all while leveraging the ability to capture attention in a saturated market. The optimization of audio design thus becomes an integral aspect of campaign effectiveness, complementing visual storytelling and targeting strategies.
Platforms, including traditional broadcasters, cable and satellite operators, and streaming services, bear responsibility for implementing loudness controls across diverse delivery paths. The proliferation of live channels, on-demand content, and multi-device consumption requires sophisticated measurement, normalization, and quality assurance systems that can operate across complex delivery networks. The success of these platforms in delivering a consistent audio experience depends on robust collaboration with content producers, advertisers, and measurement providers, as well as ongoing investment in audio engineering capabilities.
From a policy standpoint, the FCC’s ongoing reexamination and openness to potentially extending CALM Act principles to online platforms signal a broader push toward harmonizing consumer protection with the realities of a digital, multi-platform environment. The policy conversation centers on creating a viable framework that can address the technical complexities of the web while preserving the economic incentives that support high-quality programming and advertising-supported business models. The outcome could influence how streaming platforms, distribution networks, and advertisers approach audio production, measurement, and reporting.
Technological developments may also influence the regulatory landscape. As measurement tools become more precise and widely adopted, and as metadata standards evolve, regulators may gain greater visibility into loudness management across platforms. This enhanced visibility can improve enforcement efficiency and enable more targeted interventions where efficacy gaps exist. Conversely, if policy becomes overly prescriptive without accounting for platform-specific realities, it could constrain innovation or impose disproportionate burdens on certain segments of the industry. A balanced approach that emphasizes measurable outcomes and practical enforcement is essential in ensuring that policy remains effective in a rapidly changing media environment.
In the consumer experience, the practical impact of regulatory and industry developments translates into more predictable audio levels, fewer intrusive ad moments, and a smoother transition between program content and advertisements. When implemented effectively, these improvements can enhance overall satisfaction, foster trust in media brands, and encourage continued engagement with a variety of content sources. This cycle of regulatory precision, technical excellence, and user-centric design reinforces the principle that a well-regulated audio environment benefits everyone in the media ecosystem.
The conversation around loudness also intersects with broader questions about how audiences access content in a world of fragmented distribution channels. If regulators decide to apply CALM Act-like controls to streaming and web-based platforms, the scope of control could expand dramatically, requiring careful coordination across production workflows, distribution networks, and device-specific playback environments. This potential expansion underscores the importance of clear standards, interoperable solutions, and transparent measurement practices that can be consistently applied across platforms and geographies. The result would be a more uniform listener experience, even as audiences enjoy a diverse array of content and delivery options.
Finally, it is important to recognize the role of public awareness in shaping policy and practice. As consumers become more attuned to audio quality and more vocal about their experiences with ads, there is greater impetus for platforms and regulators to invest in better loudness management. Public sentiment, informed by accessible information about how loudness is measured and controlled, can influence how resources are allocated for compliance, technology development, and consumer protection initiatives. The ongoing dialogue among regulators, industry players, and the public will help define the future of loudness governance in both traditional and digital media contexts.
Practical takeaways for readers and stakeholders
- For viewers: Expect ongoing improvements in how loudness is managed across ads and programs, particularly as standards, measurement practices, and enforcement evolve. While streaming platforms may introduce new complexities, the overall aim remains to reduce jarring volume changes that disrupt the viewing experience.
- For content creators and advertisers: Embrace consistent loudness targets throughout production and post-production, invest in metadata-driven workflows, and prioritize audio design that serves clear, engaging messaging without relying on volume spikes.
- For broadcasters, operators, and streaming platforms: Prioritize cross-platform loudness normalization, invest in robust measurement infrastructure, and participate in regulatory dialogues to help shape practical, enforceable standards that reflect modern distribution landscapes.
- For policymakers and regulators: Continue evaluating the effectiveness of current rules, consider targeted expansions where feasible, and work with industry to develop practical frameworks that address evolving delivery methods while safeguarding consumer interests.
In sum, the CALM Act remains a central reference point for discussions about audio quality, viewer comfort, and advertising integrity in a media landscape that is increasingly diverse in how content is produced, delivered, and consumed. The FCC’s ongoing reassessment, coupled with industry-wide efforts to standardize loudness and improve measurement, suggests a future in which loudness consistency becomes more deeply embedded in both legacy and new platforms, delivering a smoother and more enjoyable experience for audiences across the spectrum of viewing options.
Conclusion
The conversation around loudness in television advertising centers on balancing regulatory aims with evolving media delivery realities. The CALM Act’s core objective—to ensure that commercials do not play at a louder average volume than the programs they accompany—has driven important improvements in content production, distribution practices, and audience experience since its implementation in 2012. Yet, recent complaint data, especially the surge observed in 2024, highlights that the market remains dynamic and that enforcement and compliance must adapt to changing technologies, advertising strategies, and viewing patterns.
Streaming services, which increasingly dominate the consumption landscape, add layers of complexity to the loudness governance conversation. The CALM Act does not currently apply to the web, and the regulatory framework for online platforms remains unsettled. The FCC’s willingness to solicit input from consumers and industry stakeholders reflects an intention to craft responsive policy that can address gaps while preserving the incentives that support high-quality programming and robust advertising models. The potential expansion of loudness controls to the internet would require careful design to ensure feasible enforcement, scalable measurement, and interoperable standards across devices and platforms.
Ultimately, the goal is a more consistent and comfortable audio experience for audiences, regardless of whether they are watching linear broadcasts, cable channels, or streaming content. Achieving that goal will depend on sustained collaboration among regulators, content creators, distributors, advertisers, and technology developers, as well as clear communication with the public about what constitutes compliant, consumer-friendly loudness practices. As the media landscape continues to shift toward greater integration of streaming and online delivery, the industry’s collective focus on production discipline, technical standards, and customer experience will determine how effectively loudness issues are addressed in the years ahead.
