WASHINGTON — The Federal Communications Commission (FCC) has officially published its “Space Modernization for the 21st Century” Notice of Proposed Rulemaking (NPRM), formally launching a regulatory transition that would replace the agency’s legacy Part 25 satellite rules with a streamlined “Part 100” framework.
Published in the Federal Register on December 5, 2025, the proposal seeks to dismantle the static, one-size-fits-all licensing model in favor of a “licensing assembly line” designed to reduce administrative latency for commercial space operators. The rulemaking introduces specific provisions for emerging sectors, including In-space Servicing, Assembly, and Manufacturing (ISAM) and lunar missions, which have historically struggled to fit within traditional geostationary (GSO) or non-geostationary (NGSO) definitions.
From Part 25 to Part 100
The proposed Part 100 rules aim to shift the FCC’s regulatory posture from prescriptive design requirements to performance-based standards. Under the current Part 25 regime, applicants often face prolonged processing times due to rigid technical constraints that do not account for novel orbital trajectories or rapid spacecraft iteration.
The new framework proposes a modular application system. Operators would be able to submit “base” certifications for standard satellite buses and payloads, allowing for expedited approval of routine operations while reserving in-depth review for complex or non-standard mission elements. This “assembly line” approach is intended to synchronize regulatory approvals with the increasingly rapid pace of commercial satellite manufacturing and deployment.
Key Technical Provisions
The NPRM outlines three primary pillars for the Part 100 regime:
- Variable Trajectory Spacecraft Systems (VTSS): A new licensing category created specifically for spacecraft that do not maintain fixed orbital parameters. This designation targets lunar landers, orbital transfer vehicles (OTVs), and ISAM platforms that require operational flexibility beyond standard GSO/NGSO station-keeping boxes.
- Automated Self-Certification: The rules propose a “bright-line” expedited pathway where applicants meeting specific orbital safety and spectrum interference criteria can leverage automated self-certification to bypass lengthy review cycles.
- Nationwide, Non-Site Licensing: For the ground segment, the FCC proposes a “Nationwide, Non-Site License” for certain earth stations, eliminating the need for site-by-site permitting in favor of a broader authorization model that requires only registration of active terminals.
Regulatory Outlook
The FCC has established a comment deadline of January 20, 2026, with reply comments due by February 18, 2026. If adopted, the Part 100 rules would represent the most significant restructuring of U.S. commercial space regulations in decades, aligning domestic policy with the requirements of a high-frequency launch and on-orbit servicing economy.
