FCC adopts Part 100 assembly-line satellite licensing rules

The Federal Communications Commission adopted Part 100 on July 22, 2026, introducing a new regulatory framework for space and earth station licensing that the Commission calls a “licensing assembly line.” The framework replaces the previous Part 25 rules with a structure designed to create a more efficient regulatory process, establishing standardized procedures that aim to reduce uncertainty for satellite operators. The move represents a fundamental shift in how the FCC regulates space and earth stations, moving from a patchwork of legacy requirements toward a more structured, predictable approach.

The FCC’s legacy satellite regulation was governed by Part 25 rules prior to the adoption of Part 100 in July 2026. The new Part 100 framework is organized into four distinct subparts. Subpart A covers definitions, establishing the foundational terminology for the new framework. Subpart B covers workflows, outlining the procedural steps that applicants must follow. Subpart C covers technical requirements, detailing the specifications that spacecraft and earth stations must meet. Subpart D covers compliance and administrative sanctions, setting forth the enforcement mechanisms. The architecture utilizes a modular approach with standardized forms, including a modified FCC Form 312, which streamlines the application process by establishing consistent formatting requirements across all filings. This modular structure allows the Commission to update specific components without overhauling the entire framework.

Kathryne Dickerson of Greenberg Traurig described the new Part 100 process at Silicon Valley Space Week as a “licensing assembly line.” She spoke in Mountain View, California, on Oct. 28, 2026, about the procedural changes in the rules. Dickerson said the approach “really represents a sea change in the way the FCC regulates space stations and Earth stations,” noting that the process allows for faster approval of certain application components, enabling operators to move more quickly through the regulatory process. The “assembly line” metaphor captures the standardized, repeatable nature of the new workflow, where applications move through defined stages with predictable timelines. Dickerson’s description highlights the procedural efficiency that the Commission hopes to achieve through the new framework.

Under Part 100, the FCC has 30 days to verify application completeness and 60 days to issue a decision after the public comment period ends. The new timeline includes a 15-day window for public comments, which is a reduction from the previous 30-day period. The new rule establishes a standardized window for commenters to respond to applications, creating a more predictable schedule for all parties involved. These timelines apply to both space and earth station applications under the new framework, providing operators with a clearer picture of how long the licensing process will take from submission to decision. The standardized timelines are designed to reduce the uncertainty that has historically plagued satellite operators, who often faced unpredictable delays in the licensing process.

FCC Chairman Brendamn Carr stated that Part 100 eliminates guessing games and hidden requirements. He argued the new rules establish clear lines to focus the commission on core duties such as spectrum management and national security. Carr believes the overhaul improves decision quality and predictability by creating those clear regulatory lines. He cited the allowance for multiple satellites at the same orbital slot as an example of how the new regulations improve predictability and quality, giving operators more certainty about where spacecraft may operate. The Chairman emphasized that the new framework allows the FCC to focus on its fundamental regulatory responsibilities rather than getting bogged down in unclear or inconsistent requirements. Carr’s comments reflect a broader push within the Commission to streamline operations and focus on high-priority regulatory tasks.

Part 100 replaces the old Schedule S with two new technical schedules: Schedule F and Schedule O. Schedule F covers frequency and link details, while Schedule O handles orbital parameters and safety. The new modular structure separates technical data into specialized schedules, making it easier for applicants to provide the right information in the right format. The separation of technical data into specialized schedules reflects the Commission’s recognition that different types of technical information require different treatment and review processes.

For earth station operators, Part 100 introduces a two-step Nationwide, Non-Site license option for Immovable Earth Stations. This structure allows operators to secure a broad operational envelope for technical parameters across the United States before registering specific fixed sites, providing flexibility in network planning. The modular architecture relies on standardized forms such as the modified FCC Form 312, which helps ensure consistency in applications and reduces the administrative burden on both applicants and the Commission. The two-step license option is designed to accommodate operators who need to deploy networks across multiple locations without having to secure separate approvals for each site, significantly reducing the regulatory overhead for large-scale earth station deployments.

The most significant changes for satellite operators come in the form of new financial and deployment requirements. Non-geostationary orbit (NGSO) operators who opt into processing rounds must provide a $10 million surety bond within 30 days of receiving a grant. The bond amount decreases linearly as satellites are deployed, reaching zero once 90% of the authorized constellation is in place. This structure incentivizes operators to deploy their constellations promptly while providing a financial safeguard for the Commission. Geostationary (GSO) systems are exempt from the new surety bond requirements, reflecting the different operational characteristics and regulatory history of these systems. The surety bond requirement represents a significant financial commitment for NGSO operators, but the linear decrease provides a clear pathway for reducing this obligation as the constellation is deployed.

Processing round participants must also meet strict deployment milestones: 50% of their constellation within six years and 100% within nine years. These milestones apply to companies that opt into the processing rounds, creating a clear timeline for constellation deployment. Operators who choose not to join a processing round follow a different schedule linked to the International Telecommunication Union (ITU). Non-processing round NGSO systems must follow ITU-aligned deployment schedules of 7, 9, 12, and 14 years, and they do not have to post the $10 million surety bond required of round participants. This two-tiered system gives operators a choice between the faster, more structured processing rounds with higher financial requirements, or the more flexible ITU-aligned schedules with lower upfront costs. The deployment milestones are designed to ensure that operators actually deploy their constellations rather than simply holding licenses without making progress toward deployment.

The first processing round for Ka-, Ku-, Q-, and V-band spectrum is anticipated to start on Jan. 1. Dickerson noted that while this is the expectation, the rules are not yet in effect and the actual start date depends on the FCC issuing a public notice. The anticipated January start date reflects the Commission’s ambition to move quickly with the new framework, but operators should not assume the timeline is fixed until the official public notice is issued.

Katherine Gizinski of River Advisers stated that the predictability of timelines is more critical for businesses than pure speed. She argued that inconsistent timelines between three and 18 months create wildly different financing requirements for comparable companies. Gizinski said companies need to know when a license will arrive so they can structure their funding, and the standardized timelines under Part 100 should help address this. The predictability she emphasized is particularly important for smaller operators who may have limited access to capital and cannot afford to wait indefinitely for licensing decisions. Gizinski’s comments highlight the financing challenges that satellite operators face, particularly when licensing timelines are uncertain, as investors and lenders need to know when a license will be available to structure their investments and loans.

Looking ahead, Kevin Kelly, a partner at Actum, expects the upcoming Congress to increase oversight and engage in significant battles regarding spectrum allocation. He noted that while engineers will resolve technical issues, political conflicts will focus on winners and losers of spectrum access. Kelly referenced Nov. 3 and January as dates tied to the congressional outlook, suggesting that the political environment could shape how the new rules are implemented and potentially amended. The political battles could affect not only the implementation of Part 100 but also the broader spectrum policy landscape that governs how satellite operators access frequency bands. Kelly’s warning about potential political conflicts underscores the importance of monitoring congressional developments as the FCC moves forward with implementing the new framework.