USA: FCC Proposes Unlicensed Spectrum Rule for Direct-to-Device (D2D)

United States (FCC): Proposed Rule Would Open Unlicensed Spectrum for Direct-to-Device Satellite Communications

Regulatory Background

The Federal Communications Commission (FCC) has long permitted direct-to-device (D2D) communication between satellites and terrestrial devices, but only under licensed operation governed by Part 25 of its rules. That framework has supported services such as Supplemental Coverage from Space (SCS), authorized under the FCC's 2024 SCS Order.

Since then, market demand for D2D connectivity has accelerated sharply industry estimates cited by the Commission place the D2D connectivity market at roughly $100 billion in growth potential driven by consumer and enterprise demand for coverage in areas where terrestrial networks (cellular, Wi-Fi) are unavailable or unreliable. Recognizing this gap, the FCC has now proposed to extend D2D capability to a much broader category of equipment: unlicensed devices operating under Part 15 of its rules, which include everyday consumer products such as smartphones, laptops, wearables, and IoT sensors.

Summary of the Proposed Rule

On August 6, 2026, the FCC adopted a Notice of Proposed Rulemaking (NPRM) titled "Unleashing Unlicensed Spectrum for Direct-to-Device" (ET Docket No. 26-169, FCC 26-51). The item was released on August 7, 2026, and formally published in the Federal Register on September 8, 2026 (Document 2026-18282).

Focus keyword in context. What the FCC unlicensed spectrum Direct-to-Device rule proposes

The NPRM proposes to:

• Permit Part 15 unlicensed devices to communicate directly with FCC-authorized satellites on a non-interference basis, without requiring individual device licensing.

• Add satellite allocations in three specific unlicensed bands identified as technically suited to D2D operation because they already support relatively higher unlicensed power levels:

  • 902–928 MHz

  • 2400–2483.5 MHz

  • 5725–5850 MHz

• Clarify that unlicensed equipment may operate within spacecraft as part of a satellite payload, not only on the ground.

• Establish a flexible regulatory framework intended to preserve incumbent operations in these bands while enabling new D2D use cases.

• Retain the core Part 15 obligations: devices must not cause harmful interference to licensed or incumbent services, and must accept any interference received.

  
  

The Commission frames the proposal as expanding connectivity options for consumer devices (smartphones, laptops, wearables) and IoT/sensor applications in regions lacking reliable terrestrial infrastructure without requiring manufacturers or operators to obtain a satellite spectrum license for D2D functionality.

What This Means for Manufacturers

For device makers, chipset suppliers, and satellite operators tracking the US market, this proposal signals a meaningful shift in how D2D functionality could be authorized:

• Lower barrier to market entry. If adopted, manufacturers could integrate satellite D2D functionality into unlicensed consumer devices without pursuing a separate satellite license for that functionality reducing regulatory overhead and time-to-market.

• New design constraints apply. Devices operating in the proposed bands will still need to meet existing Part 15 technical limits (power, emissions) and demonstrate non-interference with incumbent licensed users of those bands.

• Band selection matters for product planning. Companies developing IoT sensors, wearables, or connected devices intended for off-grid or low-coverage use cases should evaluate whether their target hardware already operates in 902–928 MHz, 2.4 GHz, or 5.8 GHz, as these are the bands under consideration.

• This is not yet final. The rule remains a proposal. Manufacturers should not assume authorization to market D2D-capable unlicensed devices under this framework until the FCC issues a Report and Order following the comment period.

• Early engagement is an opportunity. Because this is an NPRM, manufacturers and industry associations can shape the final technical rules by submitting comments particularly on coexistence, power limits, and certification procedures.

  
  

Certification Impact Summary

Area	Current Status	Potential Impact if Adopted
Licensing requirement for D2D	Required under Part 25 for satellite D2D	Would allow Part 15 (unlicensed) equipment authorization for eligible devices
Applicable bands	Not defined for unlicensed D2D	902–928 MHz, 2400–2483.5 MHz, 5725–5850 MHz proposed
Equipment authorization pathway	Satellite licensing / Part 25 processes	Likely continued use of Part 15 certification procedures, with new technical parameters for satellite links
Interference obligations	N/A for unlicensed D2D (not yet permitted)	Standard Part 15 non-interference and interference-acceptance rules would apply
In-orbit equipment operation	Not explicitly addressed	NPRM proposes to clarify that unlicensed equipment may operate within spacecraft
Product scope affected	N/A	Smartphones, laptops, wearables, IoT/sensor devices operating in the proposed bands

Timeline and Required Actions

Date	Milestone	Recommended Action for Stakeholders
August 6, 2026	NPRM adopted by the Commission	Informational proposal formally initiated
August 7, 2026	NPRM released	Full text available for review (FCC 26-51)
September 8, 2026	Published in the Federal Register (Doc. 2026-18282)	Official comment clock begins
November 9, 2026	Deadline for public comments	Manufacturers, industry associations, and affected stakeholders should submit comments on technical parameters, coexistence, and certification concerns
December 7, 2026	Deadline for reply comments	Opportunity to respond to comments filed by other parties
After reply comment period	FCC review and potential Report and Order	Monitor docket for final rule text and effective date before designing or marketing D2D-capable unlicensed products

Recommended actions now:

1. Review whether current or planned product lines operate in the 902–928 MHz, 2.4 GHz, or 5.8 GHz bands.

2. Assess potential product roadmap implications if unlicensed D2D authorization becomes available.

3. Consider submitting or supporting industry comments before November 9, 2026.

4. Track ET Docket No. 26-169 for the eventual Report and Order and final technical/certification requirements.