USA FCC Part 100 Satellite Licensing Overhaul

USA: FCC Overhauls Space and Earth Station Licensing With New Part 100 Framework

On July 22, 2026, the U.S. Federal Communications Commission (FCC) unanimously adopted a Report and Order and Further Notice of Proposed Rulemaking titled Space Modernization for the 21st Century (FCC 26-47, SB Docket No. 25-306), released the following day on July 23, 2026. The decision retires the FCC's legacy Part 25 satellite rules and rebuilds space and earth station authorization from first principles under an entirely new Part 100, codified in 47 CFR Subchapter D as "Space and Earth Station Services."

The Commission frames the action as delivering a faster, more predictable "licensing assembly line" for the U.S. commercial space sector, executed against the backdrop of Executive Order 14369, Ensuring American Space Superiority (December 18, 2025), and the agency's "Build America Agenda" and "Delete, Delete, Delete" deregulatory proceeding. Chairman Carr and Commissioners Gomez and Trusty approved the item, with Chairman Carr and Commissioner Trusty issuing separate statements.

Crucially for compliance planning, the action has two distinct halves. The Report and Order adopts final, binding Part 100 rules. The accompanying Further Notice of Proposed Rulemaking (FNPRM) is the only portion open for public comment, and it proposes further refinements that build on the newly adopted framework.

What the FCC Part 100 satellite licensing framework changes

The Report and Order replaces a decades old, case by case regime with a modular, certification based process. Part 25 will sunset once Part 100 becomes effective, and the Commission has directed its Space Bureau to manage the transition, confirming that Part 25 rule references in existing authorizations remain intelligible and enforceable. The core structural changes are as follows.

A modular "licensing assembly line." Applications are broken into reusable components. All applicants file the FCC Form 312 Main Form, which can now be pre cleared and associated across multiple applications rather than resubmitted each time. Space station applicants file Schedule O (orbital information) and Schedule F (frequency information) replacing the former Schedule S while earth station applicants file Schedule B.

A "presumed acceptable," default to yes review. Applications that certify compliance with bright line rules are presumed to be in the public interest and processed quickly. The Commission focuses scrutiny only on defined targeted review categories: Failure to Certify, Waiver Requests, Market Access, Foreign Ownership, Processing Round, Spectral Constraints, and Federal Coordination. Standardized timelines apply a 30 day completeness review, a 15 day public notice for typical requests, and a requirement that the Commission explain any inaction within 60 days of the close of public comment. The Commission declined to adopt the "expedited processing" track floated in the NPRM.

New and clarified license categories. Part 100 formally recognizes GSO satellite systems (now permitting multiple GSO satellites at a single orbital location under one call sign), NGSO satellite systems, a new Variable Trajectory Space Station (VTSS) category for orbital transfer vehicles, rendezvous and proximity operations, in space servicing, and lunar missions, and a Multi orbit Satellite System (MOSS) license available prospectively to new applications only.

A reformed earth station regime. Earth station applications move to a certification based model, and the Commission introduces a new Nationwide, Non Site license allowing operators to register individual sites over time. Operators holding an approved Form 312 and requesting a license without waivers may begin operating on a non interference, unprotected basis once the application is placed on public notice.

Longer license terms, opt in processing rounds, and recalibrated bonds. Most space and earth station licenses now default to a 20 year term. Frequency specific processing rounds open automatically each year from January 1 to October 31, initially for Ka-, Ku-, Q-, and V-bands. Operators opt in to a processing round; those that do must post a $10 million surety bond that declines to zero at 90% deployment, while all non processing round licensees are relieved of the bond requirement entirely. Processing round systems remain subject to six-year (50%) and nine year (100%) buildout milestones; non processing round systems are held to the less stringent ITU milestones.

Space safety and national security provisions. Operators must share ephemeris data with a recognized Space Situational Awareness (SSA) provider, the GSO two degree spacing rule is affirmed, and satellites must be designed and operated to de orbit within five years of end of mission. Ownership disclosure at the 10% threshold and the Foreign Adversary Control attestation regime (adopted January 30, 2026) are carried into Part 100. Separately, the FCC will now accept ITU filings without an underlying space station application, addressing a competitive disadvantage for U.S. licensed operators.

What this means for manufacturers

A clarification is essential here: this reform governs the licensing of space and earth station systems and their operators it is not a change to the FCC's equipment authorization (device certification) rules. A satellite earth station terminal, user modem, or direct to device module still requires its own FCC equipment authorization through the established Part 2 / Part 15 / Part 25 device pathways and Telecommunication Certification Bodies (TCBs). Those obligations are unchanged by Part 100.

That said, the practical effects reach well beyond satellite operators, because a manufacturer's route to the U.S. market often depends on a U.S. licensed system reaching operational status:

• Constellation and payload suppliers (NGSO, GSO, VTSS servicing/transfer vehicles, lunar hardware) benefit from faster, more predictable system authorization for their customers, compressing the timeline from contract to onorbit revenue.

• Earth station and terminal vendors including ESIM, VSAT, and gateway equipment makers are directly affected by the certification based earth station regime and the new Nationwide, Non-Site license, which changes how large fleets of like terminals are authorized and registered.

• Direct to device and IoT module makers whose go to market rides on an NGSO operator's U.S. authorization gain from the streamlined, milestone driven processing structure.

• Market access applicants (non U.S. systems seeking U.S. access via petition for declaratory ruling) should note that "Market Access" is an explicit targeted review category, and that market access reciprocity was deferred to a later proceeding.

  
  

For type approval and market access teams, the takeaway is to treat Part 100 as the system authorization layer sitting above unchanged equipment certification requirements and to map which of your customers' U.S. filings now move onto the faster assembly line track.

Certification and market access impact summary

Dimension	Under legacy Part 25	Under new Part 100
Regulatory layer affected	Space/earth station licensing	Space/earth station licensing (modular, certification based)
Equipment authorization (device certification)	Separate Part 2/15/25 + TCB process	Unchanged still separate
Core application form	Form 312 + Schedule S	Form 312 (reusable/pre-clearable) + Schedule O, F, B
Review standard	Discretionary public-interest showing	Bright-line "presumed acceptable" + targeted review
Earth station licensing	Site-based	Certification based + Nationwide, Non Site license
License term (most systems)	Typically 15 years	Default 20 years
Surety bond	Broadly applied	$10M only for processing round opt in; none otherwise
New system categories	GSO / NGSO	GSO / NGSO / VTSS / MOSS
ITU filing without application	Not permitted	Permitted
Status of the rules	—	R&O final (effective date pending); FNPRM open for comment

Timeline and required actions

Date / Trigger	Event	Recommended action
Oct 28, 2025	NPRM adopted (Part 100 proposed)	Historical context
Jul 22, 2026	R&O and FNPRM adopted (FCC 26-47), unanimous	Confirm which client filings are in-flight under Part 25
Jul 23, 2026	Item released	Review full R&O text and Appendix A final rules
Federal Register publication of FCC 26-47	Sets effective date of Part 100 rules and opens FNPRM comment window	Diarize the FR date; confirm real comment deadline (30 days after publication) and reply deadline (60 days after)
Effective date of Part 100	Part 25 sunsets; Part 100 governs	Transition existing authorizations; assess opt-in to Part 100 bonds/milestones
Ongoing	Non processing-round licensees relieved of bond requirement	Reassess bond exposure for affected clients
Annual, Jan 1 – Oct 31	Processing-round windows open (Ka, Ku, Q, V bands)	Align NGSO filing strategy to the annual window