From Part 25 to Part 100: The FCC’s Space Licensing Overhaul Reaches Its Decisive Stage

On 1 July 2026, the Federal Communications Commission (“FCC”) released the tentative agenda for the FCC’s Open Meeting scheduled for 22 July 2026. Among the items is Space Modernization for the 21^st Century (SB Docket No. 25-306), a Report and Order and Further Notice of Proposed Rulemaking (“FNPRM”) that would overhaul how the FCC licenses space and earth stations. The centerpiece is a proposal to sunset Part 25 of the FCC’s rules and replace it with an entirely new rule part, Part 100, built around what the FCC calls a “licensing assembly line.”

This is the resolution stage of a proceeding that opened in October 2025. The FCC adopted the underlying Notice of Proposed Rulemaking (“NPRM”), designated FCC 25,69, on 28 October 2025; comments closed on 20 January 2026 and reply comments on 18 February 2026. The 22 July item would convert those proposals into binding rules, while the accompanying Further Notice seeks comment on additional changes that build on the new Part 100. If adopted, it would represent the most significant restructuring of US commercial space licensing in decades.

The Current Framework: Part 25 Under Strain

Part 25, titled “Satellite Communications,” has governed satellite and earth station licensing for decades. It sits within Subchapter B (Common Carrier Services) and has been revised repeatedly and piecemeal as the industry evolved. Its architecture reflects an earlier era: a small field of largely quasi-governmental, geostationary orbit (“GSO”) operators, reviewed through narrative-heavy, discretionary, case-by-case adjudication.

That model has struggled to scale with the industry. The FCC received circa 290 space station applications and circa 2,680 earth station applications in 2024, compared with 124 and 974 respectively in 2016, tracking a more than ten-fold rise in objects launched into orbit over the past decade. In conjunction, applications have grown more complex and non-traditional, spanning large non-geostationary orbit constellations (“NGSO”), direct-to-device services, Earth observation, in-space servicing, and lunar missions that fit awkwardly within the existing taxonomy.

The strain shows up as delay and unpredictability. Timelines for acting on some applications can run to years and staff spend disproportionate resources sifting through non-standardized materials to establish completeness. The subjective requirements produce inconsistent levels of review and frequent back-and-forth between applicants and the FCC. Given the capital-intensive nature of the industry, where financing depends on speed and demonstrated progress, that uncertainty carries real cost.

The Proposed Overhaul: Part 100 and the “Licensing Assembly Line”

The reform is organized around four statutory review concerns the FCC has identified as the proper focus of its public-interest analysis: harmful interference, spectrum efficiency, space safety, and foreign ownership. Everything else in the process is designed to move applications toward a decision on those questions as efficiently as possible.

A new rule part. Part 100 would be titled “Space and Earth Station Services” and relocated to Subchapter D (Safety and Special Radio Services), reflecting that not all licensees are common carriers but all use radio services. It would be organized into four subparts (General; Applications and Licenses; Operational Rules; and Compliance), separating application requirements from operating obligations and enforcement.

Modular applications and “presumed acceptable” criteria. The assembly line moves applications through three phases: a modular application phase, a processing phase, and a decision phase. Applicants would complete only the modules relevant to their request. For space stations, the FCC proposed condensing requirements into three areas (general applicant information, orbital information, and frequency information) and replacing the current Schedule S with a new Schedule O for orbital data and Schedule F for frequency data on FCC Form 312. The framework shifts from prescriptive design mandates and narrative demonstrations toward standardized, performance-based certifications. Applications certifying compliance with bright-line criteria would be “presumed acceptable,” meaning presumed to serve the public interest, and routed for expedited processing, with defined exceptions reserved for targeted review.

Timelines, conditional grants, and processing rounds. Part 100 would establish review timelines, shorten public notice periods, and permit certain conditional grants so applicants can begin planning earlier. For NGSO systems, the FCC proposed restructuring processing rounds into annual, band-specific rounds in which co-filers share equal spectrum priority (subject to a sunset), and expanding eligibility for first-come, first-served treatment.

Milestones, bonds, and license terms. The proposal would eliminate milestone requirements for GSO systems and align NGSO milestones with International Telecommunication Union benchmarks, including a first-satellite milestone followed by staged deployment obligations. Surety bonds would be removed for GSO stations and certain NGSO stations, and milestones simplified. License terms for most space and earth stations would extend to 20 years, and the list of modifications permitted without prior approval would expand.

Earth stations. The framework would shift predominantly to nationwide, non-site-based blanket licensing and introduce a new “[i]mmovable” earth station category modeled on the 70/80/90 GHz site-registration regime, available to fixed stations that certify compliance with bright-line criteria.

Space safety. In exchange for streamlined entry, operators would take on affirmative safety obligations, including sharing ephemeris data with approved space situational awareness services and filing periodic space safety reports.

Implications for Industry

The FCC has openly positioned the reform as a competitiveness strategy, aiming to make the US the destination of choice for licensing and operating space systems as other nations compete for the same investment. The certification-and-presumption model rewards applicants who can map their systems onto bright-line criteria with fast, predictable grants, an advantage for well-advised operators and a meaningful reduction in regulatory latency across the ecosystem.

With that said, the trade-offs merit close attention. A move from discretionary review to bright-line certification shifts risk onto the applicant: certifications carry compliance and enforcement exposure, and the FCC has signaled a robust back end, including automatic termination for failure to meet operational deadlines or milestones, revocation, forfeitures, and penalties for materially false statements. The reform effectively trades front-loaded scrutiny for back-loaded accountability.

The impact is broad, reaching operators, service providers, and manufacturers, and, because it governs US market access, foreign entities seeking to serve or partner in the US. Several issues remain genuinely contested and will shape how favorable the final rules prove in practice. On transition, the FCC proposed applying Part 100’s procedural rules prospectively to all licensees, including existing ones, while preserving the substantive obligations embedded in current authorizations, and it sought comment on how pending applications would be handled at the effective date. Existing licensees should not assume their current authorizations are fully insulated from the new regime.

What’s Next

The 22 July meeting is a consideration date rather than a foregone conclusion; the draft text remains subject to change, and the Report and Order may adopt the NPRM’s proposals with modifications informed by the comment record. If adopted, the new rules would take effect following Federal Register publication, with the revised Form 312 schedules also subject to Paperwork Reduction Act review before they can be required. The accompanying Further Notice would open a fresh comment cycle on further refinements built on Part 100, so the proceeding will continue well past July.

For anyone active in, or seeking to enter, the US space sector, the practical steps are assessing how current and planned systems would map onto the presumed-acceptable criteria and modular application structure, evaluating the compliance exposure that comes with a certification-based regime, and monitoring the Further Notice for the next round of proposed changes.