Click here for Adobe Acrobat version
Click here for Microsoft Word version


This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.


Federal Communications Commission
445 12
 St., S.W.
Washington, D.C. 20554
News Media Information 202 / 418-0500
TTY: 1-888-835-5322
DA 18-368
April 12, 2018
Enforcement Advisory No. 2018-01
The Enforcement Bureau, International Bureau, Office of Engineering and Technology, and Wireless 
Telecommunications Bureau of the Federal Communications Commission (FCC or Commission) issue 
this Advisory to remind satellite system operators of the requirement to obtain FCC authorization for 
space station and earth station operations, and to caution satellite operators and their launch service 
providers concerning proceeding with launch arrangements either following a license denial or prior to 
FCC authorization of radio operations. 
The Commission has previously issued guidance on obtaining licenses for small satellites.
Compliance with requirements for licensing of satellite communications is not optional.  Failure to 
comply with FCC requirements can and will result in enforcement action.
Satellite operations, including the launch activities necessary to establish a satellite in orbit, are complex 
technical undertakings in which multiple parties may play a role.  The participants in those activities have 
a shared responsibility to ensure that the activity is consistent with regulatory requirements and must 
ensure, in defining roles and responsibilities related to the activity, that such requirements will be 
adequately addressed.  
This Enforcement Advisory is intended to remind participants of the FCC regulatory requirements 
applicable to satellite operations, and to caution participants in launch activities about actions contrary to 
these requirements.
Why do I need a license?  The International Telecommunication Union (ITU) Radio Regulations are 
treaty provisions binding on the United States, and require that no transmitting station may be established 
or operated by a private person or by any enterprise without a license by or on behalf of the government 
 See Guidance on Obtaining Licenses for Small Satellites, Public Notice, DA 13-445, 28 FCC Rcd 2555 (Mar. 15, 
2013), available at
of the country to which the station in question is subject.
  The Communications Act of 1934, as 
amended, requires the issuance of a license for communications to and from the United States or from any 
U.S. satellite,
  and provides the FCC with authority to take actions to implement the ITU Radio 
  FCC licensing is also an important aspect of ensuring that the United States satisfies the 
treaty obligation for authorization and continuing supervision of the space activities of non-governmental 
  Operations without a license are subject to the full range of FCC enforcement actions. 
What should I do if I don’t have a license, but I am facing a deadline for participating in a launch?  
Satellite operators that have been denied an FCC license, or are seeking but have not been granted an 
FCC license, are cautioned not to provide the satellite to a launch service provider
 for integration into a 
satellite deployment device or launch vehicle if doing so commits the operator in any irreversible manner, 
either practically or legally, to launch of the satellite.  The satellite operator must maintain sufficient 
control over the satellite, through appropriate contractual provisions, to ensure a legal right and a related 
operational capability to remove the satellite from the launch vehicle.  The existence of a pending 
application does not guarantee that a satellite will ultimately be authorized by the Commission, and does 
not justify proceeding beyond a point where the satellite operator no longer has such a right, or where 
such operational capabilities are no longer available.  
U.S. satellite operators should also be aware that, if operations using earth stations outside the United 
States are contemplated, regulatory authorities in other countries may decline to issue an earth station 
authorization until a U.S. space station authorization is issued.  A number of countries also require that 
ITU coordination and/or notification procedures have begun or have been completed before issuing an 
earth station authorization.   
Can I launch my satellite without an authorization if I agree to disable all onboard radio 
transmitters until my authorization is granted?  Even if radio transmitters can be disabled prior to 
launch, launching without those transmitters presents other significant concerns.  Radio transmitters play 
an important role in identifying, cataloging, and controlling a satellite.  A satellite launched without the 
ability to use on-board radio systems, which typically are the primary means of monitoring and 
controlling the spacecraft’s operations, may then pose an unacceptable hazard to other satellites.  As an 
example, the operator may not be able to assist in the event of a potential conjunction with another 
satellite, because tracking information that would otherwise be derived from radio operations is 
unavailable.  Resolution of licensing issues before launch ensures that necessary communications can be 
What if my satellite is authorized by a Federal agency other than the FCC?  A U.S. satellite may 
require more than one U.S. authorization, depending on the proposed operations and launch scenario.  For 
example, in addition to an FCC license, the operator may also need to acquire a remote sensing license or 
 International Telecommunication Union (ITU) Radio Regulations, No. 18.1 (2015).
 47 USC § 301 (d), (f). 
 47 USC § 303(r).
 Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the 
Moon and Other Celestial Bodies art. 6, adopted Oct. 10, 1967, 18 U.S.T. 2410, 610 U.N.T.S. 205.
 As used in this Enforcement Advisory, “launch service provider” refers to launch providers, rideshare 
coordinators, satellite integrators, or other entities that may be involved in the process of preparing the satellite for 
export license.  Authorization under these other legal requirements does not provide or guarantee 
approval of an FCC license.  In addition, funding of a satellite by a Federal agency is not by itself 
sufficient to justify tendering a satellite for launch because the Federal agency presumes the party will 
obtain all necessary approvals.
What if my satellite is authorized by a foreign administration?  Satellites authorized by an 
administration other than the United States do not require any FCC approval if earth station operations are 
exclusively outside the United States.  If earth station operations in the United States are contemplated, 
the applicant for a U.S. earth station should be prepared to identify the administration authorizing the 
space station operations under Article 18.1 of the ITU Radio Regulations, and the country that has 
registered or intends to register the satellite pursuant to the U.N. Outer Space Treaty.
What are the risks for launch service providers?  Launch service providers should be aware that a 
satellite integrated into a launch vehicle or deployment device without a current FCC authorization may 
need to be removed from that vehicle or deployment device if the satellite operator’s application for an 
FCC authorization is not acted upon favorably, or for various reasons cannot be granted within a time 
frame consistent with the launch schedule.  Removal of an unauthorized satellite or its deployment device 
from a launch vehicle may cause disruptions to launch operations and has the potential to impact other 
packages on the launch vehicle, whether primary or secondary.  Satellite operators and launch service 
providers should be aware of the risks of integrating an unauthorized satellite and, if they nonetheless 
choose to proceed with integration of the satellite, provide the legal and practical means for removing the 
satellite from the launch vehicle or deployment device through appropriate contractual and operational 
Launch service providers should exercise particular caution if a satellite operator indicates that it is 
relying on several possible alternative jurisdictions for radio-frequency approval, or is otherwise altering 
its mission to obviate the need for radio-frequency approval, particularly at late stages of launch 
preparations.  While it is common for satellite operators to consider alternative regulatory jurisdictions at 
early stages of a project, a search for an alternative regulatory home during later stages of launch 
preparations can be the result of significant underlying regulatory issues that may not be resolved 
favorably prior to the scheduled launch.  
How can I confirm the status of an FCC authorization?  Information on the status of current or 
pending FCC satellite authorizations can be found in various FCC databases depending on the type of 
authorization.  Authorizations under Part 25 of the Commission’s rules can be found in the International 
Bureau Filing System (IBFS).
  The Office of Engineering and Technology (OET) maintains a list of 
current experimental systems authorized under Part 5 of the Commission’s rules, including experimental 
satellites, in the Experimental Licensing System (ELS).  Information on amateur-satellite authorizations 
operating under Part 97 of the Commission’s rules can be found in the Universal Licensing System 
  See below for links to each of these databases.
 Although the IBFS includes the most current information on authorizations, the Commission also maintains the 
Approved Space Station List as a convenient unofficial list of authorized Part 25 satellites.  See
 Amateur-satellites must be “documented” before they are authorized to operate.  47 CFR § 97.5(a)(3).  To assist in 
determining which space stations are considered “documented” under these rules, staff have begun to provide an e-
mail in the ULS file of the satellite’s amateur control operator once the satellite is considered documented.  This 
occurs upon submission of required and acceptable information, including documents suitable for submission to the 
? ELS:
? ULS:
What if I have additional questions?  For additional information regarding this Advisory, contact:  Neal 
McNeil, Enforcement Bureau (, telephone (202) 418-2408); Karl Kensinger, 
International Bureau (, telephone (202) 418-0773); or Walter Johnston, Office of 
Engineering and Technology (, (202) 418-0807).  For assistance regarding the 
use of FCC databases, including questions regarding the status of a license application, contact 
information is available on the respective websites listed above.
Issued by the Chiefs, Enforcement Bureau, International 
Bureau, Office of Engineering and Technology, and 
Wireless Telecommunications Bureau
ITU.  For a documented satellite, the control operator’s ULS file will also contain a mission description and orbital 
debris mitigation plan.