FCC Space Modernization Series (Part 3): FCC Creates 2 Licensing Pathways For NGSO Systems, Eliminates Small Sat Framework

On July 22, 2026, the Federal Communications Commission unanimously adopted its Space Modernization for the 21st Century Report and Order (R&O), continuing its comprehensive modernization of the satellite licensing framework. As discussed in our previous alerts, the Commission overhauled both its licensing procedures and milestone requirements. This GT Alert, the third in our series, examines how the R&O restructures how non-geostationary satellite orbit (NGSO) systems are licensed.

Rather than requiring all NGSO applicants to proceed through the same regulatory process, the R&O establishes two distinct licensing pathways. Operators may elect to participate in an annual, frequency-specific processing round that provides spectrum-sharing priority and regulatory certainty in exchange for more rigorous deployment and financial obligations. Alternatively, operators may seek authority outside a processing round under a more flexible licensing framework that does not provide