Key Takeaways
- • The FCC adopted an NPRM on August 6, 2026, proposing to allow unlicensed Part 15 devices (Wi-Fi, Bluetooth) to communicate directly with satellites, significantly expanding direct-to-device (D2D) connectivity in underserved areas without requiring individual earth station licenses.
- • The proposed framework targets two high-power unlicensed spectrum bands: 2.4 GHz (2400-2483.5 MHz) and 5 GHz (5725-5850 MHz), leveraging existing consumer device infrastructure while maintaining current Part 15 technical rules and power limits to protect incumbent operations and federal radar systems.
- • Satellites would be licensed under existing Part 25/Part 100 rules, while user devices would operate on a "license-by-rule" basis mirroring the FCC's 2024 Supplemental Coverage from Space (SCS) framework, eliminating the need for individual device manufacturer licensing while ensuring compliance with orbital debris and international obligations.
- • The FCC proposed barring entities on its "Covered List" from participating in these unlicensed satellite networks as a national security safeguard, addressing concerns about foreign entities gaining communications service access in the U.S.
- • Public comments are due November 9, 2026, with reply comments due December 7, 2026, establishing a critical timeline for stakeholders to influence the final ruleset.
Summary
On August 6, 2026, the Federal Communications Commission adopted a Notice of Proposed Rulemaking that would permit satellite operators to deliver direct-to-device connectivity using unlicensed spectrum—a regulatory expansion building on the agency's 2024 Supplemental Coverage from Space framework. The proposal allows existing consumer devices operating under Part 15 unlicensed rules (primarily Wi-Fi and Bluetooth equipment) to establish satellite links without requiring individual earth station applications, substantially broadening coverage in rural and remote regions lacking terrestrial infrastructure.
The FCC proposes to open two primary spectrum bands for this purpose: the 2.4 GHz band (2400-2483.5 MHz) and the 5 GHz band (5725-5850 MHz, designated as U-NII-3). Both bands currently host a significant volume of unlicensed terrestrial communications and permit operations at higher power levels than many alternative unlicensed frequencies. Notably, the FCC excluded the 902-928 MHz Industrial, Scientific and Medical band from its final proposal following stakeholder pushback during the open meeting process. The framework deliberately maintains existing Part 15 technical requirements and power limits, avoiding modifications that might materially degrade the radio frequency operating environment for incumbent Wi-Fi, Bluetooth, and other unlicensed devices. The agency explicitly solicited comment on whether satellite space-to-Earth transmissions should be restricted to the 5725-5850 MHz portion alone, preserving lower frequencies for Earth-to-space transmissions, and what additional technical protections are necessary to safeguard federal radar systems and other incumbent operations.
The licensing architecture mirrors the SCS framework, with satellites licensed under Part 25/Part 100 rules (ensuring compliance with orbital debris mitigation and international obligations) and user devices operating under a "license-by-rule" basis that eliminates individual earth station licensing requirements. The FCC proposed authorizing these transmissions on an unprotected, non-interference basis—consistent with unlicensed terrestrial operations—meaning devices must fully protect incumbent operations while receiving no protection rights from one another. Because this framework diverges from international spectrum allocations, the FCC invoked the International Telecommunication Union's Article 4.4 framework for non-conforming uses and requested comment on protections needed to prevent harmful interference with Canadian, Mexican, and other neighboring operations.
The FCC also addressed in-space unlicensed device operations, noting that astronauts have long carried consumer electronics aboard the International Space Station. It proposed permitting Part 15 devices inside spacecraft without additional restrictions, given spacecraft shielding substantially mitigates harmful interference risk, while soliciting broad comment on external unlicensed device applications including sensors, robotic arm controls, and inter-spacecraft communications. The agency additionally sought input on potential unintended radio frequency emissions from satellites themselves and whether regulatory rules on unintended emissions should be adopted.
A critical national security component requires the FCC to address how entities listed on its "Covered List"—designating foreign and higher-risk vendors—are excluded from participating in these unlicensed satellite networks, preventing such entities from offering communications services in the U.S. market. The proceeding establishes December 7, 2026, as the reply comment deadline, providing stakeholders approximately three months to influence the regulatory outcome.
The FCC proposes to open two primary spectrum bands for this purpose: the 2.4 GHz band (2400-2483.5 MHz) and the 5 GHz band (5725-5850 MHz, designated as U-NII-3). Both bands currently host a significant volume of unlicensed terrestrial communications and permit operations at higher power levels than many alternative unlicensed frequencies. Notably, the FCC excluded the 902-928 MHz Industrial, Scientific and Medical band from its final proposal following stakeholder pushback during the open meeting process. The framework deliberately maintains existing Part 15 technical requirements and power limits, avoiding modifications that might materially degrade the radio frequency operating environment for incumbent Wi-Fi, Bluetooth, and other unlicensed devices. The agency explicitly solicited comment on whether satellite space-to-Earth transmissions should be restricted to the 5725-5850 MHz portion alone, preserving lower frequencies for Earth-to-space transmissions, and what additional technical protections are necessary to safeguard federal radar systems and other incumbent operations.
The licensing architecture mirrors the SCS framework, with satellites licensed under Part 25/Part 100 rules (ensuring compliance with orbital debris mitigation and international obligations) and user devices operating under a "license-by-rule" basis that eliminates individual earth station licensing requirements. The FCC proposed authorizing these transmissions on an unprotected, non-interference basis—consistent with unlicensed terrestrial operations—meaning devices must fully protect incumbent operations while receiving no protection rights from one another. Because this framework diverges from international spectrum allocations, the FCC invoked the International Telecommunication Union's Article 4.4 framework for non-conforming uses and requested comment on protections needed to prevent harmful interference with Canadian, Mexican, and other neighboring operations.
The FCC also addressed in-space unlicensed device operations, noting that astronauts have long carried consumer electronics aboard the International Space Station. It proposed permitting Part 15 devices inside spacecraft without additional restrictions, given spacecraft shielding substantially mitigates harmful interference risk, while soliciting broad comment on external unlicensed device applications including sensors, robotic arm controls, and inter-spacecraft communications. The agency additionally sought input on potential unintended radio frequency emissions from satellites themselves and whether regulatory rules on unintended emissions should be adopted.
A critical national security component requires the FCC to address how entities listed on its "Covered List"—designating foreign and higher-risk vendors—are excluded from participating in these unlicensed satellite networks, preventing such entities from offering communications services in the U.S. market. The proceeding establishes December 7, 2026, as the reply comment deadline, providing stakeholders approximately three months to influence the regulatory outcome.
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