On July 22, 2026, the Federal Communications Commission unanimously adopted its Space Modernization for the 21st Century Report and Order (R&O), advancing its effort to modernize the regulatory framework governing commercial satellite and earth station licensing. In the R&O, the Commission sets forth a comprehensive restructuring of how satellite applications are prepared, reviewed, and processed. These reforms are intended to replace a licensing process that historically has relied on individualized, case-by-case review, with one built around standardized application requirements, predictable procedures, and targeted regulatory review.
This GT Alert is the second in our series examining the Commission’s Part 100 reforms. The first alert explored the R&O’s changes to satellite milestones and surety bonds. This installment examines a central procedural reform in the R&O: a fundamentally redesigned licensing process that the Commission describes as a “licensing assembly line.”
Part 100 replaces the FCC’s individualized satellite licensing process with a standardized, modular framework designed to make application review faster, more predictable, and more transparent. Applicants will rely more heavily on standardized certifications and reusable filing components, while FCC review will “default to yes” for compliant applications and focus individualized scrutiny only on defined categories — such as waiver requests, market access applications, processing-round elections, and requests requiring federal coordination. The new rules also establish standardized processing deadlines, including a 30 day completeness review, a 15 day public notice period followed by 10 days for oppositions and five days for replies, and a 60 day post-public notice review period during which the Commission will identify for space station applicants any remaining issues requiring further review.
From Bespoke Licensing to Modular, Standardized Review
The Commission’s stated objective in creating a licensing assembly line is a process that is faster, more predictable, and easier to navigate — and, in turn, more consistent and transparent for both applicants and regulators — without sacrificing the Commission’s obligation to ensure that licensed systems serve the public interest.
Satellite licensing under Part 25 developed over decades through successive additions and refinements, resulting in a complex and sometimes duplicative regulatory framework that can be difficult to navigate. As application volumes have grown — driven in part by large non-geostationary orbit (NGSO) constellations and increasingly varied space missions — the Commission determined that a new framework, Part 100, is needed to modernize and improve the application process. The Commission likens the new Part 100 process to an assembly line: applications begin with standardized filing requirements, move through predictable review stages, and are assessed at clearly defined decision points.
A. More Certifications, Fewer Narratives
A central feature of the new Part 100 framework is a modular application structure. Under the current Part 25 rules, applicants must submit an FCC Form 312 Main Form with each application, even where the underlying applicant information — such as ownership details — has not changed since a prior filing. Part 100 separates general applicant information from system-specific technical information and, rather than requiring applicants to resubmit the same information with every application, allows applicants to rely on an existing, previously approved Form 312 Main Form for subsequent applications, amendments, and modifications, provided the underlying information remains accurate.
The Commission also permits entities to submit the Form 312 Main Form independently before filing a license application, allowing certain issues — such as ownership disclosures and foreign ownership review — to be addressed in advance of a specific licensing request.
System-specific technical information, in turn, is collected through a set of standardized schedules:
- Schedule O: submitted by space station applicants to provide orbital information and an end-of-life disposal plan (ODMP) demonstrating compliance with relevant rules and supporting required certifications;
- Schedule F: submitted by space station applicants to provide frequency information (replacing the current Schedule S); and
- Schedule B: submitted by earth station applicants.
Rather than the narrative-heavy submissions common under Part 25, these schedules rely on a certification-based approach. Applicants certify “yes” or “no” as to their compliance with the identified Commission rule or policy. Required narratives would be limited to: a comprehensive statement describing the system, a public interest statement, additional information in the case of a negative certification, and justification for waivers. The Commission characterizes this approach as limiting administrative burdens on applicants and FCC staff alike.
B. The “Default to Yes” Framework and Conditional Grants
One of the central changes adopted in the R&O is the Commission’s new review philosophy, which it describes as a “default to yes” framework.
Under Part 100, the FCC will review an application with a presumption that it is in the public interest. Applications satisfying the Commission’s certification requirements may proceed through the licensing process without extensive individualized analysis.
The Commission has identified several “targeted review categories” to focus scrutiny on situations that may trigger additional requirements to ensure the public interest. Specifically, those categories apply where the applicant:
- Fails to certify compliance with a Commission rule or requirement;
- Seeks waiver of a Commission rule;
- Applies for U.S. market access;
- Elects to seek spectral priority over others through participation in a processing round;
- Seeks access to bands where additional technical requirements have been adopted to address spectral constraints or harmful interference; or
- Seeks access to spectrum that requires federal coordination.
Falling into one of these categories does not necessarily pull an application off the assembly line. Federal coordination is illustrative: rather than holding an entire application until coordination with a federal user is complete, the Order allows the Commission to issue a conditional grant, permitting an applicant to begin operating in bands where coordination is either complete or unnecessary while coordination proceeds in parallel for the remainder. The same conditional-grant approach applies to commercial coordination and to orbital debris mitigation plans, allowing operators to secure a license even while certain workstreams remain unresolved. Only the discrete issue triggering review — not the application as a whole — is set aside for individualized attention.
More Predictable Application Handling
The Order also standardizes the procedural steps that occur after an application is filed. Within 30 days of filing, the Commission must either determine whether the application is sufficiently “complete” to be placed on public notice or identify deficiencies that must be corrected (usually within thirty days) before processing can continue. An application is deemed complete when it includes all required information, forms, certifications, exhibits, and showings and contains no internal inconsistencies. Applicants deemed incomplete that are not amended or otherwise corrected will be dismissed.
Once an application is accepted for filing, the Commission adopts standardized procedures governing public notice, petitions/comments, requests for additional information, and application amendments:
- A 15 day public notice period applies to all earth and space station applications (except where otherwise required by statute). Petitions to deny or comments must be filed within the 15 day public notice period and may be served by email only; informal objections can no longer be filed outside the 15 day period without first obtaining specific leave from the Commission.
- If an application receives any pleadings during the public notice period, there is an additional 10 day period during which the applicant and other interested parties may file oppositions or responses to the pleadings.
- After the 10 day opposition/response window, any party that filed during the initial public notice period has five days to submit a reply to any opposition or response.
For space station applications, within sixty days after the public notice period ends, the Space Bureau must notify the applicant of any specific deficiencies or aspects of the application requiring further review that may prevent Commission action.
For earth station applications associated with a previously approved Form 312 Main Form, non-interference, unprotected operations may begin operations in non-federal bands once the application is placed on public notice.
The Commission may request information from an applicant at any point in the review process, including after an application has been deemed complete and placed on public notice. However, the information requests must be tied to identifiable rule provisions. Requests may not seek information on matters for which no applicable rule or legal authority exists.
Conclusion
As Part 100 is implemented, both new and existing operators will need to adapt their application strategies to take full advantage of the new framework. Applicants that understand and leverage the new modular filing process, standardized certifications, and defined review pathways will be better positioned to obtain timely Commission action and navigate the FCC's evolving satellite licensing regime.