Under the proposed changes, satellite operators would need to meet four additional deployment milestones across a seven-year period following an initial regulatory phase.
The regulator would also require operators to submit constellation status reports every four years and promptly notify Ofcom when satellites deviate from their authorised orbits.
Under the new requirements, non-geostationary (NGSO) operators must meet precise deployment milestones, starting with a single satellite at the 7-year limit, ramping up to 10% of the constellation within 2 additional years, 50% within 5 years, and reaching full deployment within 7 years after the initial period.
Operators failing to meet the proposed thresholds must modify their filing to reflect actual deployment levels, potentially resulting in reduced spectrum rights proportional to the satellites actually launched.
“The purpose of these additional milestones is to ensure the deployment of the full non-GSO constellation and, therefore the efficient use of the notified frequency assignments and orbital parameters,” Ofcom’s update document reads.
Ofcom’s proposed new requirements could compel emerging operators like Amazon with its Project Kuiper service to accelerate their constellation deployments or risk losing valuable spectrum rights.
Procedural filing updates: What’s on the table?
The consultation, which runs until 23 May 2025, seeks feedback on the regulator’s proposed changes to its ‘Procedures for the Management of Satellite Filings’ — the rulebook satellite operators must follow when applying for spectrum and orbital resources.
Ofcom said the changes are designed to improve transparency and align with UK space policy priorities, with new players looking to break into the satellite market.
Among the headline proposals:
Mandatory EPFD masks: Operators of NGSO systems will need to submit Equivalent Power Flux Density (EPFD) masks to demonstrate they’re staying within the power limits set to protect geostationary services, a safeguard designed to reduce interference risk without requiring coordination with each GSO operator.
Orbit deviation disclosures: Operators would be forced to state whether their satellites have strayed from the notified orbit.
Post-milestone reporting: Even after deployment milestones are met, operators will need to continue submitting system status updates every four years.
Usage declarations: Geostationary operators must confirm whether a satellite has been used to “bring into use” a filing in the past three years.
Beyond the operator rules, Ofcom is also suggesting several updates to its own practices, including adding clearer descriptions of how it works with government departments as well as improved guidance around leasing satellite capacity for filing purposes.
While a lot of the changes are procedural, the regulator contends that the updates are designed to provide a clearer, more internationally aligned framework — and one that gently pushes the growing number of satellite operators toward greater transparency and responsibility.
“While the overall number of filings that we manage annually has remained broadly static, the number of operators who apply through the UK and the range of services has increased,” the regulator said. “Satellite networks and other space services make use of scarce and finite resources [such as] radio frequencies and orbital positions.
“These need to be carefully planned and coordinated at an international level as satellites provide regional or global services.”
Ofcom plans to publish its final statement on the updated procedures in Autumn 2025.
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