The Constellation Gold Rush: FCC Approves 7,500 Starlink Satellites and China Applies for 200,000 Satellites with ITU

The constellation boom is here and it is a regulatory, spectrum, and orbital-capacity land grab that is playing out two venues that matter more than most operators admit: the Federal Communications Commission (market access, spectrum rights, operating conditions) and the International Telecommunications Union (international spectrum filings and priority). Starlink is the proof of concept. China’s latest filings are the proof that the next phase will be geopolitical.

Start with the blunt metric: low Earth orbit is getting crowded fast. A recent analysis cited more than 11,700 active satellites as of May 2025, a multiple-hundreds-percent increase from 2018, and attributes much of the change to megaconstellations. In the United States’ own regulatory record, the scale is even clearer: SpaceX is operating roughly 9,400 Starlink satellites, described as about two-thirds of all active satellites. This is not “growth.” This is a new baseline.

Starlink’s next regulatory phase: authorization at scale, with conditions

On January 9, 2026, the FCC approved SpaceX’s plan to deploy an additional 7,500 second-generation Starlink satellites, taking SpaceX’s authorized total to roughly 15,000 satellites. The Commission did not greenlight the full vision (SpaceX had sought authority tied to nearly 30,000 Gen2 satellites), citing the untested nature of the Gen2 models, and instead issued a partial approval with milestones.

Those milestones matter commercially. The FCC’s decision structure is effectively a gating mechanism: launch and operate 50% by December 2028, complete by December 2031, and complete deployment of the first-generation tranche by November 2027. For investors, suppliers, and competitors, those dates become de facto market timing signals. For downstream customers (governments, carriers, and enterprise buyers), they become service-availability cues.

The details inside the FCC’s order also reveal where the U.S. market is moving: more flexibility on frequencies, and explicit accommodation for direct-to-cell style services (described as direct-to-cell connectivity outside the U.S. alongside higher throughput ambitions). The FCC’s own “partial grant” summary confirms the scope: additional frequencies and new orbital shells as part of the Gen2 upgrade architecture.

For operators and new entrants, the lesson is straightforward. The FCC is still willing to authorize at megascale, but it is pairing that scale with (i) performance and deployment deadlines, (ii) collision-avoidance and debris posture expectations, and (iii) ongoing oversight leverage. You cannot treat licensing as a one-time hurdle. You need to treat it as a lifecycle compliance program.

China and the ITU: filing is strategy, not paperwork

The ITU side is where the constellation boom becomes a strategic contest over priority. In the final week of December 2025, Chinese entities filed submissions covering more than 200,000 satellites with the ITU, according to reporting tied to ITU records.

There are two important nuances here.

First, ITU filings do not equal satellites in orbit. They are claims over spectrum and orbital resources under ITU Radio Regulations, and they can be used to reserve future operating flexibility, establish coordination positions, and shape the negotiation terrain with other administrations. The commercial implication is that spectrum risk is increasingly being “front-loaded” years before launch, and sometimes decades.

Second, the filings are arriving in a context of openly expressed safety and congestion concerns. The same reporting cycle ties China’s actions to broader arguments about Starlink’s collision risk and orbital crowding. That framing matters because it foreshadows the next wave of regulatory tools: more aggressive coordination demands, tougher market-access conditions, and reciprocal restrictions justified by safety or interference concerns.

In other words, the boom is shifting from “who can build and launch” to “who can secure durable rights, protect market access, and survive coordination disputes.”

What this boom is really creating: a full-stack opportunity cycle

A megaconstellation world creates opportunity far beyond manufacturing satellites. If the FCC is willing to authorize scale but only with enforceable milestones and evolving debris expectations, there is immediate demand for counsel that can architect applications, milestones, and operational compliance so the constellation remains financeable. China’s ITU posture signals a coming era of contested filings and coordination leverage. Operators will need serious representation to audit filing strategy, anticipate coordination friction, and defend priority positions before disputes harden into market-access denials.  Even rivals are recapitalizing and replenishing to stay in the game; for example, Eutelsat has placed major orders to expand and maintain OneWeb while governments support European alternatives. That creates a second-order market in ground infrastructure, terminals, gateway licensing, cybersecurity, and government procurement.

The practical takeaway

This boom is not just “more satellites.” It is a race to lock in spectrum rights, regulatory permissions, and operational credibility before orbital carrying capacity becomes a hard constraint. The winners will not be the operators who launch the most spacecraft. They will be the operators who can (i) win approvals, (ii) survive coordination, (iii) maintain safety and disposal performance, and (iv) keep market access open across jurisdictions that are increasingly willing to weaponize spectrum and safety narratives.