FCC Part 15 Direct-to-Device Satellite NPRM (USA)

FCC Proposes Opening Part 15 Unlicensed Bands to Direct-to-Device Satellite Links (USA)

The U.S. Federal Communications Commission (FCC) has circulated a draft Notice of Proposed Rulemaking (NPRM) that would, for the first time, allow equipment operating under the Commission's Part 15 unlicensed rules to communicate directly with satellites. The item ET Docket No. 26-169, "Unleashing Unlicensed Spectrum for Direct-to-Device" was announced by Chairman Brendan Carr on July 15, 2026, and the public draft was released the following day. It is scheduled for a Commission vote at the August 6, 2026 Open Meeting.

This is an early stage, comment phase proceeding, not a rule change. Nothing in the draft alters any current equipment authorization obligation. Its significance for manufacturers, importers, and test labs lies in what it signals about the next regulatory frontier for mass market Wi-Fi, Bluetooth, and IoT devices and in a specific, forward looking question about whether such devices will eventually need a Part 25 satellite earth station certification layered on top of their existing Part 15 approval.

Regulatory context: what the FCC is proposing and why

The proposal extends the Commission's 2024 Supplemental Coverage from Space (SCS) framework, which authorized licensed terrestrial wireless carriers to route service through satellites in their own licensed bands. ET Docket No. 26-169 asks a parallel but distinct question: can the unlicensed Part 15 ecosystem the "permissionless" sandbox behind Wi-Fi, Bluetooth, and most consumer IoT be opened to direct to device (D2D) satellite links without disturbing the non interference bargain that makes Part 15 work?

The Commission frames the move as a response to spectrum demand and investment momentum in the D2D sector. Per the draft, more than $40 billion has moved through the U.S. space economy for D2D since the SCS framework was adopted, including SpaceX's $19.6 billion acquisition of 65 MHz of D2D spectrum from EchoStar, AST's $550 million L-band arrangement tied to Ligado spectrum, and the Amazon Globalstar and Rocket Lab Iridium transactions totaling nearly $20 billion combined. The FCC positions unlicensed spectrum as a complementary capacity source for these services, particularly in rural and unserved areas that lack both terrestrial cellular and Wi-Fi coverage.

Two structural points define the proceeding's scope, and both go beyond a simple "expand D2D" headline:

1. Earth to space and space to Earth links using Part 15 devices in three higher power unlicensed bands.

2. Operation of Part 15 devices inside FCC authorized spacecraft a separate clarification prong plus a request for comment on extravehicular activity (EVA) and inter spacecraft communications.

Technical scope: the three bands and the non-interference floor

The draft proposes adding satellite allocations only in the three Part 15 bands that already permit higher power operation, generally up to 36 dBm (4 watts) EIRP:

• 902-928 MHz

• 2400-2483.5 MHz

• 5725-5850 MHz (U-NII-3)

  
  

These bands were selected because they support enough power to reach a satellite and, unlike other higher power unlicensed bands, carry no existing satellite allocations (with the narrow exception of an amateur satellite downlink in 5830-5850 MHz).

Crucially for equipment makers, the NPRM proposes no increase in permissible power, antenna gain, bandwidth, or out of band emission limits for Earth to space operation. Devices would transmit to satellites under the exact Part 15 technical envelope they already meet. On that basis, the Commission tentatively concludes that permitting uplinks to satellites would not raise the interference risk to authorized services.

Space to Earth operation is treated more cautiously and is left largely at the comment stage. Because a satellite beam illuminates a far larger footprint than a terrestrial transmitter, the FCC seeks comment on power flux density limits, beam and footprint constraints, aggregate emission limits across multiple constellations, out of band emissions, and possible contention based mechanisms. The 5725-5850 MHz band is floated as the leading downlink candidate. The draft also flags radio astronomy protection particularly S/X Celestial Reference Frame observations near the 2400-2483.5 MHz band and asks whether geofencing should be required, along with whether high altitude, aircraft, or drone operation of these uplink devices should be restricted.

Throughout, the governing principle is unchanged from core Part 15: any new satellite operation, whether licensed by rule or blanket-licensed, would be on an unprotected, non-interference basis. Devices may not cause harmful interference to authorized services and must accept interference received.

What this means for manufacturers

For the equipment community, the practical takeaways are about positioning and monitoring, not compliance action there are no new obligations today. The most consequential items:

1. No current device change is required or possible. The NPRM does not amend any Part 15 technical or authorization rule. Products in development or already on the market are unaffected by the draft itself.

2. Existing certifications would be grandfathered for satellite use. The draft's central equipment question is whether Part 15 devices that talk to satellites should also hold a Part 25 (satellite earth-station) certification. Even if the Commission adopts that requirement, the FCC proposes it would apply only to new equipment authorizations or those updated through the permissive-change process. Equipment already certified to Part 15 would be permitted to communicate with satellites under its existing authorization.

3. Any Part 25 layer would likely be a paperwork step, not a retest. The draft proposes that no additional device testing would be needed to obtain the Part 25 certification meeting the Part 15 technical rules would render a device eligible. This mirrors the streamlined "expand an existing certification" mechanism the Commission built for SCS equipment under Parts 22/24/27.

4. The licensing model is still open. The FCC is weighing a license-by-rule approach (a certified Part 15 device is automatically licensed by rule as an earth station, as in SCS) against blanket earth-station licensing under Part 25. The choice affects who holds the authorization and what, if any, application burden attaches to device makers versus satellite operators.

5. Covered List restrictions carry over unchanged. The draft proposes no changes to Secure Networks Act obligations. Equipment on the FCC's Covered List remains ineligible for new certifications or permissive changes and would not gain any pathway to satellite operation.

6. The real deadline is the comment window, not a compliance date. Manufacturers, test labs, and certification bodies with a stake in how the Part 25 certification interaction, licensing model, or downlink technical rules are structured should prepare to file in ET Docket No. 26-169 once comment deadlines are set.

   
   

Certification impact for FCC Part 15 direct-to-device equipment

Aspect	Rule today	What ET Docket 26-169 proposes / asks	Net effect on manufacturers
Part 15 certification	Intentional radiators must be certified (tested at an FCC-recognized lab) before import, marketing, or operation	No change proposed	No impact — existing pathway stands
Part 25 certification for satellite links	Not applicable to Part 15 devices	Seeks comment on whether a Part 25 earth-station certification should also be required for devices intended to reach satellites	Potential future add-on; open question
Additional testing for Part 25	N/A	Proposes no additional testing — Part 15 compliance would suffice for the Part 25 layer	Minimal added burden if adopted
Applicability to existing products	N/A	Any Part 25 requirement would apply only to new authorizations or permissive changes; already-certified gear grandfathered	Installed base and current certs protected
Licensing of user equipment	Part 15 devices operate license-free	License-by-rule vs. blanket Part 25 earth-station license (comment sought)	Model undecided; watch for burden allocation
Covered List / Secure Networks Act	Covered equipment barred from authorization	No change; covered equipment stays ineligible	No new pathway for covered gear
Operating basis	Non-interference (Part 15)	Non-interference preserved for all new satellite operations	Regulatory status unchanged

Timeline and required actions

Date	Milestone	Required action	Status
July 15, 2026	Chairman Carr announces the proposal on the tentative August agenda	Awareness only	Complete
July 16, 2026	Draft NPRM (ET Docket No. 26-169) released on FCC.gov	Review draft text and proposed rules	Complete
August 6, 2026	FCC Open Meeting — Commission votes on whether to adopt the NPRM	Track outcome; confirm final adopted scope and any changes from the draft	Scheduled (adoption not guaranteed)
TBD on publication in the Federal Register	Comment window opens	Confirm docket, prepare position	Not yet open date to be confirmed
FR publication + 30 days	Comment deadline	File comments via ECFS under ET Docket No. 26-169	Not yet set
FR publication + 60 days	Reply comment deadline	File reply comments	Not yet set