What’s Happening

As of 1 January 2025, the updated edition of the Radio Regulations of the International Telecommunication Union (ITU), resulting from World Radiocommunication Conference 2023 (WRC-23), entered into force globally. These updates were negotiated during the WRC-23 held in Dubai in late 2023 and represent the culmination of multi-year study group work. The revised regulations cover spectrum allocations, notification and coordination obligations, and modernisation of certain radiocommunication treaty parts to support emerging technologies and satellite services. Satellite Markets+1

Key among these updates are changes to how satellite systems—especially non-geostationary satellite systems (NGSOs) and SmallSat/CubeSat constellations—must meet “bringing into use” milestones, how often they must coordinate spectrum usage internationally, and stricter rules on interference protection from both GSO and non-GSO systems. Moreover, new frequency bands have been allocated or made more accessible under conditions conducive to satellite broadband and other services. For example, the updated treaty improves clarity around spectrum sharing, interference limits, and expands certain bands for space services. The Critical Communications Review+2Satellite Markets+2

Why It Matters

For CubeSat and SmallSat operators, these changes shift the regulatory landscape in several material ways. First, the “bringing into use” (BIU) requirements mean that satellite filings are time-sensitive: if you obtain frequency assignments or orbital rights but do not begin operations within the prescribed window—or maintain them for a minimum operational period—you risk losing registered rights. Second, spectrum allocations and interference protection rules (especially the protections from GSO systems via power flux-density (PFD) or equivalent power flux metrics) tighten technical margins for small constellations. Third, because more bands are being opened or clarified under stricter conditions, mission planners will need to do more upfront technical analysis to ensure compliance—before filing.

Operators who are unaware or unprepared risk delays, rejection of filings, or retroactive modifications imposed by administrations or the ITU’s Radiocommunication Bureau. The burden of proof rises: showing actual use, avoiding harmful interference, coordination with administrations whose services may be impacted. Frequency sharing regimes become less forgiving of speculative or passive assignments.

Implications for SmallSat / CubeSat Operators

The updated Radio Regulations force SmallSat operators to integrate several new risk and schedule management practices. Project timelines must accommodate not only manufacturing, launch, and deployment but also the timetable for bringing operations into service under the declared frequencies and orbital slots. This means that component procurement (e.g., antennas, filters, amplifiers) cannot remain open-ended without firm technical verification ahead of filing.

Moreover, link budgets and interference modelling must reflect the more exacting PFD or similar constraints, especially in bands shared with GSO satellites or terrestrial services. The margins for adjacent-band emissions or out-of-band power leakage become critical design parameters. Earth station filings, ground segment planning, and orbit ephemeris data also need to be more precisely documented.

SmallSat operators who operate globally (or plan to sell services or share spectrum in multiple countries) must now consider the cumulative effect of ITU treaty obligations, domestic regulation, and cross-border coordination. Failing to align filings with the updated treaty could mean losing protection or privilege under the ITU’s Master International Frequency Register (MIFR).

Deep Dive Scenarios

Scenario: A CubeSat Internet-of-Things (IoT) constellation
Suppose a startup plans a 200-satellite NGSO constellation for IoT backhaul, using a mid-band frequency loosely allocated one country under older rules. Under the new ITU regulations, they must ensure that: (a) they meet “bringing into use” deadlines, perhaps needing to have at least one or more satellites operational in orbit within a given timeframe; (b) they abide by interference protection criteria relative to GSO satellites or other incumbent services; and (c) any spectrum sharing agreements or bilateral coordination (if needed) are filed and accepted. Delays in launch or failure to meet deployment milestones could risk losing rights.

Scenario: University CubeSat mission using a novel frequency band
A university project which wants to use an experimental payload in a less commonly used band must now do more rigorous coordination to ensure no interference. Also, their “notification” to ITU or their national administration must include precise orbital data and technical characteristics to avoid being challenged. If the project delays more than allowed, they may lose frequency assignment.

Checklist for SmallSat / CubeSat Operators

• Confirm whether your mission’s assigned or desired frequencies are impacted by the WRC-23 / updated Radio Regulations effective Jan 2025.
• Review “bringing into use” / milestone obligations for your filings: ensure your technical and deployment schedule align with them.
• Update interference modelling to match the new protection criteria (including PFD limits, out-of-band emissions) in relevant bands.
• Ensure detailed orbital and space station ephemeris data will be available for filings.
• Maintain robust documentation to demonstrate actual operational use of assigned frequencies.
• If planning global or multi-national operations, engage with administrations early to establish coordination agreements.