USPS: Digital subscribers pay separate subscription fee for digital product

Q: What is the U.S. Postal Service’s definition of a paid digital subscriber and what are the USPS requirements for reporting paid digital subscribers on postal forms?

A: According to TPA Postal Consultant Joel Allis, the USPS defines a paid digital subscriber as a subscriber that pays a separate subscription fee for a digital product. The newspaper maintains a stated rate for a digital subscription and the digital subscriber pays at least 30% of that rate. Also, discounted rates are allowed for digital subscribers as they are for print subscribers.
And, a subscriber who pays a single package rate for a combined print and digital subscription does not count as a digital subscriber in reporting subscribers to USPS. A print subscriber given free access to a digital edition also does not count as a paid electronic subscriber.
Furthermore, Allis said, reporting digital subscribers to USPS on the annual Statement of Ownership (PS Form 3526) is optional. If you choose to report paid electronic subscribers, they are entered on Page 3, Section 16a of the form, Allis added.
Q: We are updating our front section layout. Can you settle a question in my office about where our newspaper’s masthead box should appear?

A: Most likely, the answer is “on one of the first five pages of the issue” according to the U.S. Postal Service Domestic Mail Manual, Appendix A, Identification Statement Worksheet (DMM E211.10):
All Periodicals publications must contain an identification statement. It must appear in easy-to-read type in one of the locations listed below. Check the box that indicates the location of your identification statement:
One of the first five pages of the issue (count the cover only if it is marked as page 1).
• One of the last three non-advertising pages (bound publications only).
• Masthead on the editorial page if the location of the editorial page is shown on the first page of the publication.
• The first page of the table of contents.
Please check that each of these elements appears in the identification statement and provide an example:
• Publication Title
• International Standard Serial Number (ISSN) or USPS number if ISSN not assigned
• Issue Date (may be on cover)
• Statement of Frequency
• Issue Number (may be on cover)
• Subscription Price (optional)
• Name and Address of Known Office of Publication
• Periodicals Imprint “(Periodicals Postage Pending at ...)”
• Change of Address Information
Issue dates and numbers may appear on the spine edge of perfect-bound publications.
Note: If you don’t have a correct identification statement in your publication at the time you file this application, attach a letter to your application that shows the corrected identification statement as it will appear in the next printed issue of the publication.
Sample Identification Statement (Pending Publication)
THE DAILY TIMES Issue 5 March 2001 (ISSN 7132-698X) is published daily except Sundays and holidays for $28 per year by Wright News Co.,123 Maine Avenue, Washington, DC 20024-0001. Periodicals postage pending at Washington, DC, and additional mailing offices.
POSTMASTER: Send address changes to THE DAILY TIMES, PO Box 4, Boulder, CO 80302-0004.

Q: Why use the word “percent” instead of the percent symbol in the State Capital Highlights column? The AP did away with the word in favor of the symbol ages ago.

A: I confess that I did not know about that change in the AP style ( So thank you. I now use the percent symbol when and where appropriate in weekly State Capital Highlights columns.
Last year, respected sources posted articles alerting the news industry about AP’s decision preferring the use of the percent symbol, including these:
• The Poynter Institute for Media Studies on March 29, 2019:
• Columbia Journalism Review in April 2019:

Q: How and where can I get a copy of the Texas open meetings book? 

A: The Office of the Attorney General of Texas offers the “Open Meetings Act Handbook 2020” in PDF. The new handbook contains changes enacted in 2019 by the 86th Texas Legislature. Make sure to read the “Recent Amendments” section on pp. 4-7. Here is the link:
While you are at it, also make sure to download the “Public Information Handbook 2020” at:
Suggestion: Open PIA handbook and do a find, using “2019” as the term. You should get 24 hits on court cases, attorney general opinions, text added and text repealed in 2019. 

Q: We have a race for a local office in which the non-incumbent wants us to publish political advertising promoting his candidacy. Is there a problem if his ad only contains his name and the name of the office he is running for, like Jones/Sheriff? FYI, the ad copy includes the required disclosure statement in small print at the bottom of the ad, so that is not at issue.
A: It is a problem, according to Election Code Chapter 255.006, entitled “Misleading Use of Office Title.”
Please go to and scroll to the paragraph(c)(2). Here is the whole subsection, for context:
Sec. 255.006.  MISLEADING USE OF OFFICE TITLE.  (a)  A person commits an offense if the person knowingly enters into a contract or other agreement to print, publish, or broadcast political advertising with the intent to represent to an ordinary and prudent person that a candidate holds a public office that the candidate does not hold at the time the agreement is made.
(b)  A person commits an offense if the person knowingly represents in a campaign communication that a candidate holds a public office that the candidate does not hold at the time the representation is made.
(c)  For purposes of this section, a person represents that a candidate holds a public office that the candidate does not hold if:
(1)  the candidate does not hold the office that the candidate seeks;  and
(2)  the political advertising or campaign communication states the public office sought but does not include the word “for” in a type size that is at least one-half the type size used for the name of the office to clarify that the candidate does not hold that office.
(d)  A person other than an officeholder commits an offense if the person knowingly uses a representation of the state seal in political advertising.
(e)  An offense under this section is a Class A misdemeanor.