Other Qualified (employee/independent contractor, education and university copies)

News media qualified circulation

Applicable Rule: C 3.2/C 103.2 Other Qualified

Other qualified nonpaid distribution are copies made readily available for employees/independent contractors or students. Copies may be classified as other qualified if the following requirements are met:

Employee/Independent Contractor

Print or digital newspapers served to employees and independent contractors. These recipients are:

  • Employees on the regular payroll (full or part-time) of the newspaper during the reporting period.
  • Employees of subsidiaries on the regular payroll and are actively engaged in the production or distribution of the newspaper.
  • Independent contractors (agents) currently involved in delivering the newspaper to subscribers.
  • Correspondents contributing at least one article per month that is printed in the newspaper.

There is a limit of one copy per day, per recipient (print or digital, not both), and the copies must be easily accessible to the recipients.

Note: If an employee or contractor works with more than one AAM client newspaper, only one publication may claim that copy for that individual.


Educational Copies

Print or digital newspapers served in a formal program designed to encourage literacy and continuing education of participating students.


  • Used in an accredited classroom setting for grades kindergarten and above as part of the curriculum.
  • There is a limit of one copy per student (print or digital, not both).
  • Affidavits are collected at least annually after distribution, attesting to their use in the classroom as part of the curriculum and confirming delivery and quantity of print and digital editions.

Note: Affidavits minimum requirements:

  • Name and address of school.
  • Statement confirming the print newspapers or digital licenses were ordered, received and used in the classroom as part of the curriculum.
  • Quantity of print copies or number of digital licenses.
  • Number of students in the classroom.
  • Date(s) or date range copies were received or available.
  • 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.

Electronically generated affidavits are acceptable (i.e., email or online). Since a signature is not attainable electronically, the individual completing the form should include a statement confirming the information provided in the affidavit is true and accurate.


University Copies

Print and digital newspapers made available for pickup and use by university and college students.


  • The college or university requests the newspapers.
  • Copies are made available for registered college students and faculty.
  • Print distribution
    • Occurs in limited-access areas on campus restricted for use by students (i.e., dormitories, cafeterias, classroom buildings or via "smart vending machines" operated by a student ID).
    • Quantity claimed is net copies picked up (draw less leftovers) for each issue. Records are maintained to confirm delivery and leftovers for each print pickup location on campus.
  • Digital editions
    • Registration and activation or downloading an application initiates the start of the subscription.
    • Only copies actually accessed by students or faculty are claimed.
    • A unique identifier for each registered student and faculty member must be available.
    • Records are available to support unique student IDs and the number of students (unique IDs) who accessed the digital edition each day.

Note: The total copies per day, print and digital in aggregate, should not exceed the total number of registered college students and faculty.