Ofcom D2D Licence Exemption: UK Adds 900 MHz Band

Ofcom Extends UK D2D Licence Exemption to 900 MHz for Satellite Direct-to-Device Services

On 18 June 2026, the Office of Communications (Ofcom) published a statement confirming that it has made the Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) (Amendment) Regulations 2026 (the "Amending Regulations"). The instrument amends the UK's existing direct-to-device (D2D) satellite framework to add specific frequencies in the 900 MHz band, and is intended to come into effect on 10 July 2026.

This is not a new framework. The UK's D2D licence exemption already exists: the base Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) Regulations 2026 (SI 2026/139) were made on 16 February 2026 and came into force on 25 February 2026, initially covering the 1800 MHz band used by Virgin Media O2 (Telefónica UK). The June 2026 statement is an amendment that extends that same exemption to the 900 MHz band, enabling VodafoneThree to launch a competing satellite service in partnership with AST SpaceMobile.

What Ofcom actually changed

The UK authorises D2D through a deliberate two-instrument design:

1. An exemption regulation that removes the individual Wireless Telegraphy Act 2006 licensing requirement for mobile handsets and other SIM enabled devices when they connect to an authorised D2D service. Without it, every smartphone connecting to a satellite in mobile spectrum would, in principle, need its own licence unworkable at consumer scale.

2. A licence variation granted to an individual mobile network operator (MNO), which sets the technical and coordination conditions under which that operator may provide D2D services.

   
   

The exemption regulations are designed to track the approved variations, band by band, rather than pre-authorising every band at once. The June 2026 amendment reflects that sequencing: Ofcom approved a second licence variation for VodafoneThree on 15 April 2026 covering its 900 MHz (Band 8) spectrum, ran a public consultation on the paired handset exemption from 15 April to 18 May 2026, and has now finalised the amending instrument.

Scope of the Ofcom D2D licence exemption after this amendment

The amendment adds the 900 MHz frequencies over which VodafoneThree intends to operate, together with the accompanying technical parameters, to the list of bands covered by the exemption. The underlying framework already permits D2D across FDD and supplementary downlink (SDL) mobile bands below 3 GHz 700, 800, 900, 1400, 1800 MHz, 2.1 GHz and 2.6 GHz with each band becoming operative under the exemption only once a corresponding licence variation is approved. Time division duplex (TDD) bands remain excluded for now.

Key conditions attaching to the exemption are unchanged in substance:

• The exemption applies only to devices connecting to a service provided by an MNO holding a valid D2D licence variation.

• Eligible mobile standards include GSM, UMTS, LTE and 5G NR.

• Airborne use is prohibited.

• Device transmit power limits apply.

• D2D operates on a non-interference, non-protection basis services must not cause harmful interference and cannot claim protection from it.

• The Regulations do not extend to the Channel Islands or the Isle of Man.

  
  

Operating a D2D service without a valid licence variation remains a criminal offence under the Wireless Telegraphy Act 2006.

What this means for manufacturers

For handset and module manufacturers, importers, and regulatory affairs teams, the practical takeaways are narrower than the headline suggests and it is important not to overread them.

The exemption is a spectrum-licensing measure, not a product conformity change. It removes the user-side requirement for an individual Wireless Telegraphy Act licence when a compliant device connects to an authorised D2D service. It does not alter the equipment's own conformity obligations. Radio equipment placed on the UK market must still be UKCA-marked under the Radio Equipment Regulations 2017, demonstrating compliance with health and safety, electromagnetic compatibility, and efficient use of spectrum, typically via the relevant ETSI harmonised standards. Nothing in this amendment displaces that.

Band and air-interface support is the commercial gating factor. A device can only benefit from the VodafoneThree D2D service if its modem supports 900 MHz (Band 8) and AST SpaceMobile's air interface. Manufacturers targeting the UK D2D opportunity should confirm chipset/firmware support rather than assume the regulatory change alone enables a device.

Two live UK D2D paths now exist. Devices intended for the UK non-terrestrial network (NTN) market may need to support both the 1800 MHz path (Virgin Media O2 / SpaceX Starlink) and the 900 MHz path (VodafoneThree / AST SpaceMobile), depending on target operator and coverage strategy.

Emergency-calling expectations persist. Where a device or service is marketed around always-on connectivity, operators remain subject to General Condition A3 for 999/112 access over the satellite path. Manufacturers supporting operator propositions should anticipate testing assurance requests tied to emergency-call handling.

Certification impact summary

Aspect	Position before the amendment	Position from 10 July 2026	Manufacturer / importer action
D2D bands under the licence exemption	1800 MHz only (Virgin Media O2)	1800 MHz and 900 MHz (VodafoneThree added)	Confirm which band(s) your target service uses
Device WT Act licence for D2D use	Exempt on 1800 MHz D2D	Exempt on 900 MHz D2D as well	No individual device licence needed if criteria met
Equipment conformity (UKCA / RER 2017)	Required	Required — unchanged	Maintain UKCA marking and ETSI-based conformity
Eligible standards	GSM, UMTS, LTE, 5G NR	GSM, UMTS, LTE, 5G NR	Verify modem standard/band support
Airborne use	Not permitted	Not permitted	Ensure product documentation reflects restriction
Territorial scope	GB (not CI / IoM)	GB (not CI / IoM)	Note market-access boundary

Timeline and required actions

Date	Event	Required / recommended action
16–25 Feb 2026	Base D2D Exemption Regulations 2026 (SI 2026/139) made and in force (1800 MHz)	Baseline — framework already live
15 Apr 2026	Ofcom approves VodafoneThree's second licence variation (900 MHz) and opens consultation	Reviewed if commenting on the amendment
18 May 2026	Consultation on the Amending Regulations closes	Comment window now closed
18 Jun 2026	Ofcom statement: Amending Regulations made	Confirm 900 MHz D2D scope in product planning
10 Jul 2026	Amending Regulations intended to come into effect	Ensure 900 MHz / AST SpaceMobile-capable devices are conformity-ready for the UK market
Summer 2026	VodafoneThree customer trials expected	Align firmware/OEM rollout with operator timetable
2027 (post-WRC-27)	Ofcom to review the authorisation framework	Monitor for further band additions or condition changes

Bottom line

The Ofcom D2D licence exemption now reaches the 900 MHz band, opening a second authorised UK route for satellite direct to device services. The change is real and imminent effective 10 July 2026, but it is an incremental extension of an existing framework, rather than the creation of one, and it leaves equipment conformity obligations untouched. Manufacturers should treat it as a market-access signal on band support, not a relaxation of UKCA or RED-equivalent requirements.