Has the FCC adopted Part 100?

Yes. The FCC adopted the Space Modernization Report and Order and Further Notice of Proposed Rulemaking (FCC 26-47, SB Docket No. 25-306) on July 22, 2026 and released it July 23, 2026. It replaces 47 CFR Part 25 with a new Part 100 for space station and earth station licensing.

Is Part 100 in effect yet?

Not yet. The Part 100 rules (sections 100.1 through 100.304) take effect only after the Office of Management and Budget completes Paperwork Reduction Act review, and the Space Bureau will announce the Part 100 Effective Date by public notice. Until then, Part 25 remains in effect.

What happens to existing Part 25 licenses?

They stay valid. On the Part 100 Effective Date, licensees must comply with Part 100 subject to their existing license terms and conditions. Existing licenses keep their original terms unless the licensee petitions within one year of the Effective Date to align with a 20-year term measured from grant.

Does Part 100 change the five-year deorbit rule?

No. The five-year post-mission disposal requirement for LEO satellites carries over into section 100.260(d). The order adds a trackability requirement: satellites in or crossing LEO that are 10 cm or larger in their smallest dimension are presumed trackable, applied to new authorizations going forward.

When are FNPRM comments due?

Comments are due 30 days after the order is published in the Federal Register and replies 60 days after. As of October 17, 2026, we could not find a Federal Register publication of FCC 26-47, so those deadlines have not started.

FCC Part 100 Adopted: What Changes for Satellite Operators

The FCC has rewritten its satellite rulebook. On July 22, 2026, the Commission adopted the Space Modernization Report and Order (FCC 26-47, SB Docket No. 25-306), which replaces Part 25 with a new Part 100 for space station and earth station licensing. Chairman Carr’s statement describes it as “scrapping our rules in their entirety and replacing them with better ones.”

It is also not in force yet. Part 100 waits on Paperwork Reduction Act review, and the order had not appeared in the Federal Register as of this writing. Operators filing today still file under Part 25. What follows is what the adopted rules change, what they leave alone, and what to do before the switch.

When Part 100 Takes Effect

Most of the order takes effect 60 days after Federal Register publication. The exception is the part that matters: sections 100.1 through 100.304, effectively all of Part 100, take effect only after the Office of Management and Budget completes its review, on a date the Space Bureau will announce (FCC 26-47 ¶420). The Bureau will publish that “Part 100 Effective Date” by public notice (¶320).

Two signals confirm the current state. The Space Bureau’s October 6, 2026 order granting part of SpaceX’s 15,000-satellite direct-to-device application (DA 26-1078) applies Part 25 and notes that the new rules “are not yet effective and part 25 remains in effect.” And a September 15, 2026 erratum corrected definitions and cross-references in the new rule text.

When the date arrives, Part 25 is removed from the Code of Federal Regulations. The FCC will keep its full text on a transition webpage so that Part 25 references in existing licenses still resolve (¶322), and the Bureau will publish a chart mapping Part 25 sections to their Part 100 counterparts (¶337).

The Licensing Assembly Line

The core change is procedural. The order calls the new process a “licensing assembly line” (¶2, ¶7). Applications that comply with the rules are presumed to serve the public interest under section 100.136, and staff review concentrates on seven targeted categories rather than on every application (¶16).

The forms change with it. Space station applicants file a Form 312 main form with Schedules O and F; earth station applicants file Schedule B. All are built around certifications rather than narrative showings (¶8, ¶10). The order also sets clocks: 30 days to determine whether an application is complete, a 15-day public notice period, and an obligation for the Bureau to explain itself if it has not acted within 60 days after the comment period closes (¶15, ¶16). A separate expedited processing track was proposed and not adopted (¶15).

Part 100 sorts systems into four categories: GSO, NGSO, MOSS, and a new Variable Trajectory Space Station (VTSS) System for spacecraft operating beyond geosynchronous orbit or without fixed or predictable orbital patterns, such as orbital transfer vehicles, in-space servicing, and lunar missions (¶11). Multiple GSO satellites can now share a single orbital slot. VTSS systems carry no deployment milestones (¶246).

The streamlined small satellite and small spacecraft processes in sections 25.122 and 25.123 are eliminated. The order says they are “no longer needed” given the streamlining of space station licensing overall (¶103).

Processing Rounds Become Annual

Under Part 25, the FCC opens NGSO processing rounds when it chooses. Under section 100.140, frequency-specific rounds open automatically every year, with a filing window from January 1 to October 31 (¶19, ¶173). The first bands are Ka, Ku, Q, and V, and the Bureau can add bands but not remove them (¶173). Participation is opt-in. The Commission declined to force large systems of 200 or more satellites into rounds automatically.

First-come, first-served processing stays in place for GSO (¶196) and is dropped for NGSO (¶197).

Milestones and Bonds

For systems authorized through a processing round, the deployment milestones stay at 50 percent within six years and 100 percent within nine. Missing the 50 percent mark now moves the system into a later round instead of capping its authorization (¶22, ¶233). Other NGSO systems follow ITU milestone timelines (¶227). The five-year GSO milestone is retained (¶243).

Surety bonds now apply only to NGSO and MOSS systems authorized through a processing round. The bond starts at $10 million and declines as the constellation deploys, reaching zero at 90 percent deployment, and it must be posted within 30 days (¶21, ¶250, ¶258; section 100.147). GSO licensees post no bond.

License Terms Move to 20 Years

The default license term becomes 20 years from grant for GSO, NGSO, and VTSS space stations, earth stations, and U.S. market access grants (¶263 to ¶266), with DBS and SDARS keeping shorter terms (section 100.148(b)). Applicants can request a shorter term. The 15-year GSO term was not retained (¶265).

For earth stations, the order adds a Nationwide, Non-Site license with site registration, adopted as an interim default across bands (¶112 to ¶115). An applicant with an approved Form 312 and no waiver requests can begin operating on a non-interference, unprotected basis once the application is on public notice (¶13).

What Did Not Change

The five-year deorbit rule survives intact. It moves to section 100.260(d), with the qualifier “barring catastrophic failure” added. The order adds a trackability requirement on top: satellites in or crossing LEO that are 10 cm or larger in their smallest dimension are presumed trackable, applied to new authorizations only (¶292). Operators must also act on conjunction warnings (¶293) and share ephemeris data with a space situational awareness provider (¶24).

Regulatory fees are not addressed and are left to a separate proceeding. Market access reciprocity was deferred to “a later time” (¶14). Streamlined earth station antenna performance standards and off-axis EIRP limits were not adopted (¶303, ¶305), and receive-only earth station registration stays (¶302).

What Happens to Existing Licenses

Nothing is voided. On the Effective Date, licensees must comply with Part 100 subject to their existing license terms and conditions (¶321). Licensees get a window to flag conditions they cannot meet alongside Part 100, and the Bureau will handle those case by case (¶323). A license may be migrated fully to Part 100 when the Bureau next acts on it, such as at modification or renewal (¶325).

Three transition rules are worth calendaring:

License term. Existing licenses keep their original terms unless the licensee petitions “within one year of the Part 100 Effective Date” to align with a 20-year term from grant (¶330).
Bonds. Licensees with a bond on file that are meeting all their obligations and milestones, and that were not authorized through section 25.157 processing rounds, are generally relieved of bond obligations on the Effective Date, as are section 25.122 and 25.123 small satellite licensees. Others may move to the declining-bond formula (¶327).
Milestones. Licensees outside processing rounds that are in compliance may opt into the new section 100.146 timelines. Processing-round licensees keep their existing milestones (¶326).

Pending applications decided before the Effective Date are reviewed under Part 25. After it, the Bureau “will seek to apply the review process of part 100” (¶332). Applicants may supplement during a grace period without triggering a new public notice (¶333), but pending applications do not get the new processing clocks or operate-while-pending authority (¶334). Every application filed after the Effective Date uses Part 100 (¶336).

The Further Notice

The order also opens a Further Notice of Proposed Rulemaking built around “operational envelopes” (¶344). It asks about a new subpart for space-based experimental licensing, hosted payloads, inter-satellite links between U.S. and non-U.S. licensed satellites, ephemeris sharing, secondary markets, renewal expectancies, and orbital debris monitoring through reentry, including a proposed 1 m trackability presumption for MEO and GEO (¶345 to ¶404). Comments are due 30 days after Federal Register publication and replies 60 days after, so the comment clock has not started.

What Operators Should Do Now

File under Part 25. Its rules govern every application decided before the Effective Date, and the SpaceX grant shows the Bureau is still applying them.

Then prepare for the switch:

Pull your license terms and bond obligations. Decide now whether you will petition for a 20-year term, since the one-year window opens on the Effective Date. Check whether your bond falls away automatically under ¶327.
Decide on processing rounds. If you plan Ka, Ku, Q, or V-band NGSO capacity, the first annual window runs January 1 to October 31 once Part 100 is live.
Rework your filing templates. The new Form 312 schedules are certification-based. Teams that built Part 25 narrative exhibits should plan the conversion before their next modification.
Watch for three public notices: the Effective Date, the Part 25 to Part 100 mapping chart, and the transition procedures for earth station market access (¶329).
Decide whether to comment on the Further Notice, especially on experimental licensing, hosted payloads, and debris monitoring.

We track SB Docket No. 25-306 and the filings around it in Orbit Sentinel, so the Effective Date notice and the comment record show up in one place. For the Part 25 process that still applies today, see FCC Satellite Licensing: From Application to Authorization, and for how the FCC fits with the FAA, NOAA, and ITU, see U.S. Space Regulatory Compliance: A Complete Guide.

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