Key Takeaways

• Sunset of Part 25: The FCC just approved a historic Report and Order that completely replaces Part 25 of its rules with a new, consolidated Part 100, representing the most significant overhaul of commercial U.S. space licensing in decades.
• The “Licensing Assembly Line”: The new framework shifts from design-based rules requiring detailed showings to certifying compliance with performance-based “bright-line” standards, aiming to dramatically accelerate application processing through modular submissions (Schedule O, for orbital information and Schedule F, for frequency information), conditional grants and less onerous filing requirements.
• Regulatory Relief on Bonds and Milestones: The rules eliminate surety bonds for most licenses and extend the default license term for most space and earth stations to 20 years.
• Earth Station Overhaul: Earth station licensing will shift primarily to nationwide, non-site-based licensing and the FCC will introduce a simplified “Immovable” earth station category.
• Affirmative Space Safety Rules: To support a process for faster regulatory approvals, operators must share orbital ephemeris data with approved SSA services and file periodic space safety reports.
• Further Modernization Incoming: An accompanying Further Notice of Proposed Rulemaking will seek comment on experimental space licensing, ISLs, hosted payloads and streamlined transfers.

On July 22, the Federal Communications Commission (FCC or Commission) adopted a sweeping Report and Order and Further Notice of Proposed Rulemaking addressing Space Modernization for the 21st Century. The key change implemented in the Report and Order is that the FCC’s existing Part 25 rules governing satellite and earth station licensing will be replaced with a new Part 100 that significantly streamlines licensing reviews and relieves licensees of outdated and onerous requirements. The Part 100 regime is intended to help licensees take advantage of momentum in the new space economy. These changes aim to accelerate the deployment of U.S. commercial space systems by creating a predictable “licensing assembly line.” With the new Part 100, the Commission is shifting focus away from rigid design-based rules toward performance-based standards that protect against spectrum interference and minimize the risks from orbital debris while fostering rapid aerospace innovation.

At the outset, it is worth noting just how quickly this has come to pass: this new Part 100 framework was originally proposed in a Notice of Proposed Rulemaking issued by the FCC in October 2025. Such a wholesale reimagining of the rules governing an entire industry normally takes several years, so doing so in less than a year demonstrates that the Space Bureau’s pedal is firmly on the floor.

The Transition from Part 25 to Part 100

To reflect that commercial space has expanded and evolved since Part 25 was initially adopted, the Commission will move space regulations into a newly created Part 100 under Subchapter D (Safety and Special Radio Services) of its rules.

This new rule part is designed to separate the administrative requirements of applying for a license from the ongoing operational obligations of holding one, making the rules far more legible for new entrants and legacy operators alike.

Importantly, the Space Bureau will provide additional information on the transition of Part 25 licenses to the new Part 100 regime, but generally licensees will be expected to comply with the new rules absent a waiver request explaining why that compliance is not possible.

“Bright-Line” Processing and Modular Applications

The centerpiece of the Report and Order is the “licensing assembly line.” Instead of a lengthy case-by-case review, the FCC is establishing “bright-line criteria” that, if met, create a regulatory presumption that the application is in the public interest and expedite the review process significantly. The rules will also now rely predominantly on certifications as to compliance, rather than detailed showings; in other words, applicants will commit to complying with technical rules rather than describing how they comply.

Notably, Part 100 replaces the legacy “Schedule S” filing requirement with a modular application where the spectrum-related information and the information related to the orbits of the space stations are separated. Applications will now be segmented into three discrete, simplified fields on FCC Form 312:

• General Applicant Information (the Form 312 “Main Form,” which licensees will now be able to re-use as long as the information remains current)
• Orbital Information (the new Schedule O)
• Radiofrequency Information (the new Schedule F)
• Earth Station Information (Schedule B).

To get operators up and running faster, the new framework establishes firm review timelines for the Space Bureau, shortens public notice periods and formalizes the issuance of conditional grants—such as on the future filing of orbital debris mitigation plans—so that applicants can begin long-term planning and manufacturing earlier (this had become a common practice for the Space Bureau, but this change clarifies the procedures and requirements).

Narrowing Surety Bonds and Reforming Milestones

To lower financial barriers to entry, the Commission is significantly restructuring its milestone and bond systems, providing significant relief to satellite operators:

GSO Systems: The Report and Order eliminates surety bond requirements for Geostationary Orbit (GSO) space stations, but retains the five-year milestone obligations.

NGSO Systems: The new rules eliminate surety bonds for Non-Geostationary Orbit (NGSO) space stations that are not part of a processing round. Processing round systems will still have to pay a bond, but it will be a deescalating bond rather than an escalating one. Additionally, NGSO milestone compliance is simplified for non-processing round systems and aligned directly with International Telecommunication Union (ITU) benchmarks, beginning with a first-satellite milestone followed by staged deployment requirements.

Changes to Processing Rounds

Processing rounds have long been a critical part of the Commission’s work to ensure efficient use of scarce spectrum resources for NGSO satellites. Because the Commission does not auction spectrum for satellites, it utilizes processing rounds to ensure sharing between applicants for the same frequencies. But processing rounds had become clunky and inefficient and the Commission recognized in the Notice of Proposed Rulemaking that reform was needed.

The new processing round approach will increase predictability through annual, standardized processing rounds for bands defined in advance. Rather than being kicked off with an eligible application, processing rounds will now begin each January 1st and run through October 31st. This new approach comes with new, stricter requirements on amendments (with “major” amendments kicking an application to a later processing round) in order to encourage applicants to apply only when they have a complete proposal ready.

Earth Station Reforms: Shifting to Nationwide Non-Site Based Licensing

The Report and Order shifts earth station licensing to a predominantly nationwide, non-site-based licensing approach. Under this streamlined model, the FCC is introducing a new “Immovable” earth station category.

The “Immovable” pathway will allow fixed earth stations that certify their compliance with clear, bright-line technical criteria to fast-track their authorizations, bypassing the traditional, site-specific public notice and simplifying coordination requirements.

Other Changes

• The Commission will now require operators to take affirmative responsibility for orbital safety by requiring the sharing of high-quality orbital ephemeris data with Space Situational Awareness (SSA) services to mitigate collision risk and to file periodic space safety reports with the Commission.
• The Report and Order also introduces a specialized Variable Trajectory Space Station (VTSS) system license category. This is custom-tailored for emerging non-Keplerian and variable-orbit missions, such as In-Space Servicing, Assembly and Manufacturing (ISAM) or lunar operations.
• Recognizing the increased reliability and longevity of modern spacecraft, the FCC is extending the default license term for most space and earth stations from 15 to 20 years.
• Special Temporary Authorizations (STAs) will now be for either 60 or 180 days and will automatically extend under certain conditions.
• In order to foster the development of the “space station as a service” model, Part 100 includes rules for the hosting of space stations which allow operators to incorporate their host’s Schedule O information.
• Since the new rules enable streamlined review of all applications, the Report and Order eliminates the “small satellite” and “small spacecraft” rules which were previously used by many licensees to reduce regulatory burdens.
• The new “GSO system” application will now allow the collocation of multiple satellites in the same GSO orbital slot, enabling new and innovative uses of geosynchronous orbit.
• The FCC is simplifying modifications, allowing some modifications to occur without notice to the Commission. Certain modifications will require only notice (either before or after the change) and only “major modifications,” such as those that create a change in the interference environment, affect coordination, add authorized frequencies, or change the orbital parameters of a licensed system, will require Commission permission before the change.

Looking Ahead: The Further Notice of Proposed Rulemaking

Recognizing that the commercial space sector is evolving faster than ever, the accompanying Further Notice of Proposed Rulemaking seeks public comment on several additional forward-looking modernization proposals such as:

• Experimental Space Applications: Integrating experimental licenses directly under the Part 100 framework, rather than having experimental licenses under Part 5.
• Call Sign Merging: Simplifying the administrative processes for merging call signs.
• Intersatellite Links (ISLs): Exploring rules for ISLs between U.S. and non-U.S. licensed systems.

Closing Thoughts

With these new rules adopted, focus now shifts to implementation and to whether Congress will move forward with the Satellite and Telecommunications (SAT) Streamlining Act (HR 8255 and S. 3639). These rules accomplish much of what those bills set out to do, but lack the strict “shot clocks” that would “deem grant” applications which lie fallow for too long before the Commission. But those bills might also finally put to rest lingering questions about the Commission’s authority over orbital debris mitigation.

For those interested in learning more about the Space Bureau’s transition, stay tuned for a webinar this September on the new rules and what they mean for the satellite industry. We expect to have an announcement on it soon.