ICLE Comments to the FCC on Satellite Market Access Reciprocity
I. Introduction and Overview
The International Center for Law & Economics (ICLE) submits these comments in response to the Federal Communications Commission’s (FCC) public notice on satellite market-access reciprocity (“Public Notice”).[1] ICLE is a nonprofit, nonpartisan research center that applies law & economics methodologies to public policy. Its work aims to ensure that competition policy and regulation rest on sound economic analysis and promote consumer welfare, particularly in dynamic, technology-driven markets such as media and telecommunications.
This submission evaluates current market-access frameworks governing the entry of non-U.S.-licensed space stations into the U.S. market, as well as recent foreign regulatory developments that depart from the American—and historically global—approach. Those departures risk disadvantaging U.S. operators. The existing U.S. framework promotes competition, lowering costs and expanding service offerings for American consumers. It also attracts global capital and technological innovation, which are essential to closing the digital divide by extending high-speed broadband to rural and underserved areas where terrestrial deployment remains cost prohibitive. In addition, this open-market approach has supported reciprocal treatment for U.S. operators abroad, enabling the global expansion of American aerospace leadership and reinforcing U.S. participation in the international telecommunications ecosystem.
Recent shifts in reciprocity—particularly under the EU Space Act—threaten both global competitiveness and consumer access to broadband services. As ICLE has previously argued to the World Trade Organization and the European Union, the EU Space Act operates as a nontariff barrier under WTO principles.[2] In both design and effect, it targets large U.S. constellation operators by imposing compliance burdens that are not proportionate to demonstrated safety or sustainability benefits. Key features—including the size-based “giga-constellation” threshold, dual-track registration process, and extraterritorial inspection provisions—create discriminatory market-access barriers. These measures risk reducing economic welfare in both the United States and the European Union, slowing innovation, and shifting market share toward geopolitical competitors whose strategic interests may diverge from transatlantic priorities. The EU Space Act reflects a broader trend toward increased restrictions on U.S. satellite operators, raising the prospect of emerging space-sector protectionism.
As the FCC evaluates its presumption that granting market access to satellites offering WTO-covered services through member jurisdictions serves the public interest, it should closely examine the discriminatory effects of the EU Space Act and similar foreign measures. The United States should continue to prioritize open access, but the benefits of that policy depend in part on reciprocal treatment abroad. If reciprocity erodes, the value of maintaining unilateral openness correspondingly declines.
II. The U.S. Open-Access Framework: Evolution, Benefits, and Limits of Reciprocity
For nearly three decades, the United States has maintained an open-market framework for satellite services grounded in the WTO Basic Telecommunications Agreement (BTA) and implemented through the FCC’s 1997 DISCO II Order and subsequent rulemakings.[3] Under this framework, foreign-licensed satellite systems may serve the U.S. market with minimal regulatory friction, provided their home jurisdiction is a WTO member. The FCC’s approach rested on the premise that WTO commitments established a sufficient baseline of competitive conditions.[4]
The global landscape in 2026 differs markedly from that of 1997. The rapid expansion of non-geostationary orbit (NGSO) constellations, the rise of technological sovereignty policies—particularly in the European Union—and the persistence of nontariff barriers in major markets such as India and Brazil have weakened the effectiveness of a reciprocity-based open-access model.[5]
Before 1997, foreign satellite entry into the U.S. market was significantly more burdensome. Beginning in 1995, applicants were subject to an “effective competitive opportunities” test, which evaluated whether their home markets imposed de jure barriers, de facto restrictions, or competitive distortions that disadvantaged U.S. firms or conferred advantages on foreign providers.[6] This framework placed the burden on applicants to demonstrate that their domestic markets were sufficiently open.
The shift to open access has delivered substantial consumer benefits. Lower entry barriers for firms such as SES, Eutelsat, and Telesat have increased choice, encouraged product differentiation, and intensified price competition. These dynamics have improved both the quality and affordability of broadband services. Satellite connectivity has played a critical role in narrowing the digital divide by extending service to rural and underserved areas where terrestrial infrastructure remains impractical.[7]
Satellite services also support specialized and high-demand use cases. Eutelsat’s OneWeb constellation provides backhaul capacity that enables broadband providers to serve areas where fiber deployment is infeasible. SES delivers high-speed connectivity to the cruise industry, where vessels function as mobile cities with thousands of connected devices.[8] Without satellite infrastructure, these services would be significantly degraded, limiting connectivity in otherwise inaccessible environments. As more international operators deploy low-Earth-orbit (LEO) constellations, these benefits will continue to expand.
In addition, satellite systems provide resilient communications infrastructure during natural disasters.[9] When hurricanes, earthquakes, or wildfires disable terrestrial networks, satellite systems often remain operational. An open-access policy ensures that the United States can leverage the full range of available satellite capacity during emergencies while supporting international disaster-response efforts.
Open access also drives innovation, with spillover effects in adjacent markets. This is particularly evident in emerging direct-to-device services. T-Mobile’s partnership with Starlink enables satellite connectivity for standard LTE and 5G smartphones, expanding coverage without requiring new hardware.[10] As terrestrial providers explore similar offerings, they may turn to international satellite operators that offer lower-cost or higher-quality solutions. Increased competition in this space will reduce prices, improve service quality, and accelerate technological development across both satellite and terrestrial networks.
The central benefit of the BTA framework, however, is the reciprocity it creates. By granting market access to foreign operators on reciprocal terms, the United States enables firms such as SpaceX, Amazon, and Globalstar to expand internationally. Access to larger global markets allows firms to spread high fixed costs across a broader customer base, reducing per-user prices and supporting continued investment in deployment and research. Maintaining global leadership is particularly important as LEO technologies advance. U.S. firms currently account for approximately 78% of the commercial space economy,[11] while North America holds roughly 57.5% of the global satellite-internet market.[12]
Reciprocity also provides leverage. If a foreign jurisdiction restricts access for U.S. operators, the United States can respond by revisiting that country’s access to the U.S. market—the world’s most valuable satellite market. This dynamic reinforces incentives for openness and deters protectionist policies.
Finally, the U.S. approach exports regulatory standards. Foreign operators seeking access to the U.S. market must comply with FCC requirements governing orbital-debris mitigation, interference protection, and operational safety.[13] Once firms design systems to meet these standards, they often apply them globally. In this way, U.S. policy shapes international norms and promotes safe, reliable space operations.
III. The Erosion of Reciprocity in Global Satellite Markets
Despite the benefits of an open-access model, many jurisdictions have shifted toward space-sector protectionism, imposing barriers on U.S. firms while favoring domestic operators. The EU Space Act represents the most prominent example, but other countries—including Canada, Brazil, Japan, India, and China—also maintain restrictions that limit market access. These measures vary in design but collectively undermine reciprocity and reduce competitive entry.
A. The EU Space Act Undermines Reciprocity and Competition
While barriers to entry persist globally, the proposed EU Space Act presents a direct challenge to reciprocity. Its structure both targets U.S. operators and imposes discriminatory burdens that operate as a nontariff barrier.
1. The EU Space Act discriminates against U.S. operators
The EU Space Act introduces a “giga-constellation” category defined as satellite systems with more than 1,000 operational satellites.[14] This threshold does not reflect any evidence-based assessment of orbital risk or debris mitigation. Instead, it appears calibrated to capture large U.S. operators while Orbital risk depends on factors such as operating altitude, satellite design, and debris-mitigation practices—not simply the number of satellites in a constellation. By relying on size alone, the Act uses an arbitrary proxy that functions as a protectionist constraint on American firms.
The practical effect is clear. The EU’s IRIS² constellation is expected to include roughly 264 satellites, well below the threshold.[15] By contrast, U.S. operators dominate the “giga-constellation” category. SpaceX’s Starlink operates more than 10,000 satellites,[16] and Amazon’s planned low-Earth-orbit (LEO) system will include more than 3,000,[17] even if only a portion are currently active.[18] The threshold therefore captures U.S. firms almost exclusively.
For these systems, the Act imposes prescriptive, hard-coded requirements. Operators must, for example, carry additional propellant for maneuvering and end-of-life disposal. Yet fuel requirements depend on altitude, mass, and system design—not fleet size.[19] The rule thus imposes costs untethered to actual safety considerations.
The Act also creates procedural barriers that further disadvantage non-EU operators. It establishes a dual-track registration process. EU-based firms apply through member-state authorities under harmonized national procedures.[20] Non-EU operators must first undergo review by a Compliance Board within the European Union Agency for the Space Programme (EUSPA), followed by a final decision from the European Commission.[21]
This structure is not neutral. EUSPA is expected to oversee EU satellite programs that will compete directly with U.S. operators.[22] The Act therefore places a market participant in a gatekeeping role over its competitors.[23] This arrangement creates delays, increases administrative burdens, and introduces a clear risk of discriminatory outcomes.
The Act further authorizes extraterritorial inspection requirements as a condition of market access.[24] The European Commission may request inspections of non-EU operators’ facilities located outside the Union. These provisions can conflict directly with U.S. export-control laws, including the International Traffic in Arms Regulations (ITAR), which restrict access to sensitive technical data and controlled facilities.[25] Even if nominally voluntary, these inspection powers create coercive pressure. Denial of inspection access could serve as a basis for withholding authorization, effectively forcing firms to choose between violating U.S. law, and exiting the EU market. In practice, this operates as a poison-pill condition that may render compliance impossible.
Finally, the Act defers key technical requirements to future Implementing Acts (IAs).[26] Critical obligations—including debris-mitigation standards, reflectivity limits, and operational protocols—remain undefined and may not be finalized until shortly before implementation. This approach deprives non-EU operators of regulatory certainty and allows for the selective imposition of burdens aligned with evolving EU industrial-policy objectives rather than neutral safety concerns.
2. The EU Space Act functions as a nontariff barrier
The EU Space Act operates as a nontariff barrier that raises costs, distorts resource allocation, and reduces consumer choice. Compliance burdens imposed on non-EU operators will likely translate into higher prices, delayed deployment, or reduced service availability. These effects reduce output and leave mutually beneficial transactions unrealized.
By deterring or excluding large foreign providers, the Act limits the range of services available to EU consumers and governments. It weakens competition on price, quality, and coverage. At the same time, it shields less-efficient EU operators from competitive pressure, allowing capital, talent, and spectrum to remain in lower-value uses. These distortions mirror the well-documented inefficiencies associated with protectionist regulatory regimes.
The dynamic effects are likely to be more significant. Satellite markets are innovation-driven and capital-intensive. Regulatory design directly shapes investment incentives. By deferring key requirements to IAs that may not be issued until 2028 or 2029, the Act introduces substantial regulatory uncertainty into multi-year investment decisions.
Firms undertake satellite deployment based on expected returns. As regulatory risk increases, expected returns decline. Under standard real-options theory, firms will delay or scale back irreversible investments until regulatory obligations become clear.[27] This slows the deployment of new capacity and delays technological advancement.
The Act also departs from established global norms on debris mitigation and operational safety. Rather than reinforcing convergence on best practices, it risks creating a parallel regulatory regime. This fragmentation reduces interoperability, increases compliance costs, and limits the diffusion of innovation across jurisdictions.
B. Other Jurisdictions Impose Barriers to Market Entry
The EU Space Act has drawn significant attention due to its impact on a major market. Other WTO jurisdictions also impose barriers that restrict U.S. firms’ ability to enter and compete, including coordination requirements, ownership limits, and discretionary approval processes. While these measures vary in form, they produce similar effects: delayed entry, higher costs, and reduced competitive pressure.
1. Canada
Canada generally adheres to WTO BTA commitments but imposes several requirements that constrain foreign operators. Most notably, Innovation, Science and Economic Development Canada (ISED) requires new entrants to coordinate with existing Canadian systems before commencing operations.[28] While framed as a measure to prevent harmful interference, this requirement gives incumbents effective veto power. Existing operators can refuse to coordinate or adopt technical positions that delay deployment.
ISED policy RP-008 also requires satellite networks operating in the Canadian arc to provide specified coverage for Canadian territory. Operators must reserve up to 50% of capacity for Canadian users for at least six months after license issuance.[29] This obligation limits the ability of global operators to allocate capacity efficiently across markets. For non-geostationary systems, ISED further requires that primary control facilities and network operations centers be located in Canada, along with a 24/7 domestic point of contact.[30]
2. Brazil
Brazil imposes both structural and procedural constraints on foreign operators. Only Brazilian-owned entities may hold exclusive rights to operate satellites from specific orbital positions. Foreign operators are limited to non-exclusive landing rights granted for fixed terms.[31]
Brazil also requires pre-entry coordination with incumbent operators to mitigate interference.[32] Although ANATEL mandates good-faith negotiation, the burden falls on the entrant to reach agreement.[33] This creates opportunities for delay or obstruction by incumbents.
Additional requirements increase costs for foreign firms. Landing fees for foreign operators tend to exceed those applied to domestic providers. Operators must also conduct all regulatory interactions in Portuguese and retain a local legal representative. These frictions compound entry costs.
Recent policy developments further weaken reciprocity. A 2025 Brazilian law authorizes the executive branch to impose countermeasures, including restrictions on services, investment, and intellectual-property obligations.[34] This authority introduces additional uncertainty for foreign firms and signals a shift away from open-market commitments.
3. Japan
Japan similarly requires pre-coordination with incumbent operators. Under Article 6 of the Radio Act, applicants must demonstrate that they have reached agreements to prevent harmful interference with existing systems.[35] This includes coordination with both satellite and terrestrial licensees.
Because the Ministry of Internal Affairs and Communications (MIC) may withhold licenses until such agreements are secured, incumbents effectively hold a de facto veto over entry. This requirement can delay or block new competition, particularly where negotiations become protracted.
4. India
India has taken steps toward liberalization through the Indian Space Policy 2023 and recent foreign-direct-investment (FDI) reforms.[36] Nonetheless, several restrictions remain.
While reforms permit up to 100% foreign investment in the space sector, automatic approval is limited. Investments in satellite manufacturing and operations qualify for automatic approval only up to 74%, while investments in launch vehicles and spaceports are capped at 49%.[37] Investments exceeding these thresholds require government approval, introducing additional uncertainty and delay.
5. China
China remains the most restrictive major jurisdiction for foreign satellite operators. Market access is not governed by reciprocal WTO-style commitments but instead requires case-by-case approval.
China’s “Negative List” mandates majority Chinese ownership for “basic telecommunications services,” a category that includes certain satellite-based communications.[38] Foreign ownership of “value-added” services is generally capped at 50%, although limited pilot programs in select Free Trade Zones allow higher foreign participation.[39] These programs remain experimental and subject to extensive regulatory oversight.
Recent regulations further restrict access. The 2025 “Regulations on the Administration of Direct Satellite Services for Terminal Devices” require that all satellite services used within China rely on systems authorized by the government.[40] This framework effectively prevents Chinese consumers from accessing foreign constellations such as Starlink and reinforces the country’s broader policy of technological self-reliance.
IV. Preserving Open Access While Addressing Eroding Reciprocity
The FCC should continue to prioritize an open-access framework. That framework, however, depends on reciprocal market access for U.S. firms. As discussed above, multiple jurisdictions have moved away from a presumption of entry or imposed conditions that disadvantage American operators. These shifts threaten the core benefits of the current approach.
Open access enables U.S. firms to expand internationally and export American regulatory standards. This dynamic strengthens U.S. leadership on key issues such as interference management and orbital-debris mitigation. It also reinforces the role of U.S. policy in shaping global best practices. When other jurisdictions fail to reciprocate, these benefits erode.
Adopting a reciprocal-opportunities test would come with significant costs. It would reintroduce barriers to entry, reduce competition, and ultimately harm American consumers. At the same time, some form of conditionality may be necessary to preserve leverage in international negotiations. The FCC should therefore consider targeted, carefully calibrated responses that encourage reciprocity without abandoning the advantages of an open-access regime.
V. Conclusion
The FCC’s longstanding presumption of open access for foreign satellite operators has delivered substantial benefits. It has promoted competition, lowered costs, and expanded service offerings for American consumers. It has also helped establish U.S. leadership in the global space economy, where much of the world’s innovation and deployment now occurs. By maintaining an open-access framework, the FCC has encouraged reciprocal market access abroad and facilitated the global adoption of U.S. regulatory standards, particularly in areas such as interference management and orbital-debris mitigation.
These benefits, however, depend on reciprocity. As discussed above, several jurisdictions have moved away from open-access principles. The EU Space Act represents the most significant example, imposing targeted and discriminatory burdens on U.S. operators that function as a nontariff barrier. Other WTO members likewise maintain barriers—including pre-coordination requirements, ownership restrictions, and discretionary approval processes—that delay or deter entry by American firms. These measures reduce competition, increase costs, and limit the efficient allocation of resources in global satellite markets.
The erosion of reciprocity weakens the foundation of the current framework. Open access enables U.S. firms to scale globally, spread high fixed costs, and reinvest in innovation. It also allows the United States to shape international norms and ensure safe, reliable space operations. When foreign jurisdictions restrict access, these advantages diminish, and the risk of space-sector protectionism increases.
The FCC should continue to prioritize open access and competition by minimizing barriers to deployment, regardless of a firm’s nationality. At the same time, it should recognize that open access is not self-sustaining in the absence of reciprocal treatment. To preserve the benefits of the current system, the FCC should consider targeted and proportionate measures that reinforce incentives for reciprocity, while avoiding the consumer harms associated with broad restrictions on entry.
[1] Space Bureau & Office of International Affairs Seek Comment on Satellite Market Access Reciprocity, Public Notice, GN Docket No. 26-48 (Mar. 2, 2026), https://docs.fcc.gov/public/attachments/DA-26-208A1.pdf (“Public Notice”).
[2] Comments of the Int’l Ctr. for L. & Econ., Dep’t of Com. & Dep’t of State Consultation on the EU Space Act (Aug. 13, 2025), https://laweconcenter.org/wp-content/uploads/2025/08/EU-Space-Act-Comments.pdf; see also Comments of the Int’l Ctr. for L. & Econ., Proposal for Regulation of the European Parliament and of the Council on the Safety, Resilience and Sustainability of Space Activities in the Union, COM(2025) 335 (Nov. 7, 2025), https://laweconcenter.org/wp-content/uploads/2025/11/EU-Space-Act-Comments-to-EC.pdf.
[3] Amendment of the Commission’s Regulatory Policies to Allow Non-U.S. Licensed Satellites Providing Domestic and International Service in the United States, Report and Order, IB Docket No. 96-111, 12 FCC Rcd 24,094 (1997), https://docs.fcc.gov/public/attachments/FCC-99-325A1.pdf (“DISCO II Order”); Amendment of the Commission’s Regulatory Policies to Allow Non-U.S. Licensed Space Stations to Provide Domestic and International Satellite Service in the United States, Order, IB Docket No. 96-111, 15 FCC Rcd 7,207 (1999), https://docs.fcc.gov/public/attachments/FCC-99-325A1.pdf (“DISCO II First Reconsideration Order”).
[4] See DISCO II Order & DISCO II First Reconsideration Order, supra note 3.
[5] Public Notice, supra note 1, at 2–4.
[6] Reform of Rules and Policies on Foreign Carrier Entry into the U.S. Telecommunications Market, Report and Order, IB Docket No. 12-299 ¶ 2 (Apr. 22, 2014), https://docs.fcc.gov/public/attachments/FCC-14-48A1.pdf.
[7] Cellular Backhaul via Satellite, Eutelsat (last visited Mar. 23, 2026), https://www.eutelsat.com/satellite-network/oneweb-leo-constellation.
[8] The Connected Cruise, SES Networks Solution Brief (Feb. 2020), https://www.ses.com/sites/default/files/2020-02/Maritime_Solution_Brief_The-Connected-Cruise.pdf.
[9] How Satellites Play a Role in Disaster Relief, Viasat (Aug. 31, 2023), https://www.viasat.com/perspectives/corporate/2023/how-satellites-play-a-role-in-disaster-relief.
[10] Monica Alleven, Here’s the Skinny on T-Mobile’s Latest Satellite-Powered Offer, Fierce Network (Nov. 5, 2025), https://www.fierce-network.com/wireless/heres-skinny-t-mobiles-latest-t-satellite-offer.
[11] Space Foundation, The Space Report 2025 Q2 Highlights Record $613 Billion Global Space Economy for 2024, Driven by Strong Commercial Sector Growth, Press Release (July 22, 2025), https://www.spacefoundation.org/2025/07/22/the-space-report-2025-q2.
[12] Satellite Internet Market Size, Share & Industry Analysis, Fortune Bus. Insights (last visited Mar. 30, 2026), https://www.fortunebusinessinsights.com/satellite-internet-market-109242.
[13] A level playing field requires the FCC to treat all systems alike. The agency has not always done so. If the FCC aims to make U.S. standards the global norm, it should continue its space-modernization efforts to ensure parity among operators. See Space Modernization for the 21st Century, Notice of Proposed Rulemaking, SB Docket No. 25-306 (Oct. 28, 2025), https://docs.fcc.gov/public/attachments/FCC-25-69A1.pdf.
[14] Proposal for a Regulation of the European Parliament and of the Council on the Safety, Resilience and Sustainability of Space Activities in the Union, 2025/0335 (COD) (June 25, 2025), art. 5 (“EU Space Act”).
[15] Jean-Pierre Diris, IRIS2: Everything You Need to Know About This New European Constellation, Polytechnique Insights (Mar. 11, 2025), https://www.polytechnique-insights.com/en/columns/industry/iris2-everything-you-need-to-know-about-this-neweuropean-constellation.
[16] Tereza Pultarova, Starlink Satellites: Facts, Tracking and Impact on Astronomy, Space.com (Aug. 1, 2025), https://www.space.com/spacex-starlink-satellites.html; Jonathan O’Callaghan, SpaceX Now Has More Than 10,000 Starlink Satellites in Orbit, Scientific American (Mar. 17, 2026), https://www.scientificamerican.com/article/spacex-reaches-milestone-of-10-000-starlink-satellites-in-orbit.
[17] Clara Easterday, Amazon Sets April 9 Launch Date for First Operational Kuiper Satellites, Broadband Breakfast (Apr. 3, 2025), https://broadbandbreakfast.com/amazon-sets-april-9-launch-date-for-first-operational-kuiper-satellites.
[18] Kuiper, SatelliteMap.space (last visited Mar. 30, 2026), https://satellitemap.space/constellation/kuiper.
[19] Comments of the Info. Tech. & Innovation Found., Stakeholder Feedback on the EU Space Act, Off. of Space Com. at 2 (Aug. 4, 2025), https://www2.itif.org/2025-comments-eu-space-act.pdf.
[20] EU Space Act, supra note 14, arts. 6, 7, & 9.
[21] Id. at art. 17.
[22] See IRIS²: The New EU Secure Satellite Constellation, Eur. Comm’n Def. Indus. & Space (last visited Aug. 12, 2025), https://defenceindustry-space.ec.europa.eu/eu-space/iris2-secure-connectivity_en.
[23] For an analogous regulatory structure and its attendant problems, see, e.g., Julian Morris, Central Banks and Real-Time Payments: Lessons from Brazil’s Pix, Int’l Ctr. for L. & Econ. (2022), https://laweconcenter.org/resources/central-banks-and-realtime-payments-lessons-from-brazils-pix (explaining that Brazil’s state-owned real-time payment system both competes with and regulates private firms, creating conflicts of interest).
[24] EU Space Act, supra note 14, arts. 48(4) & 52.
[25] See, e.g., 22 C.F.R. pts. 120(10), 121 cat. IV(h)(3), 124.1, 127.1.
[26] EU Space Act, supra note 14, ch. IV(5).
[27] Scott R. Baker, Nicholas Bloom & Steven J. Davis, Measuring Economic Policy Uncertainty (Nat’l Bureau of Econ. Rsch., Working Paper No. 21633, Oct. 2015), https://www.policyuncertainty.com/media/BakerBloomDavis.pdf (finding that policy uncertainty increases stock-price volatility and reduces investment and employment in policy-sensitive sectors).
[28] Policy Framework for Fixed Satellite Service (FSS) and Broadcasting Satellite Service, RP-008 ¶ 3.2.4 (June 2017), https://publications.gc.ca/collections/collection_2023/isde-ised/iu64/Iu64-138-2017-eng.pdf.
[29] Innovation, Sci. & Econ. Dev. Can., RP-008, Policy Framework for Fixed-Satellite Service (FSS) and Broadcasting-Satellite Service (BSS) § 3.2.3 (June 2017) (Can.), https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/spectrum-allocation/policies/radio-systems-policies-rp/rp-008-policy-framework-fixed-satellite-service-fss-and-broadcasting-satellite-service-bss.
[30] Id.
[31] Satellite Exploitation—Recent Developments, Azevedo Sette Advogados (Mar. 2022), https://www.azevedosette.com.br/news/en/satellite-exploitation-recent-developments/6540.
[32] Process for Granting Satellite Landing Rights, Agência Nacional de Telecomunicações (Anatel), https://www.gov.br/anatel/pt-br/regulado/satellite/process-for-granting-satellite-landing-rights.
[33] Tarcísio Aurélio Bakaus, Brazilian Regulations: Use of Orbit and Space Sustainability, Anatel (May 2025), https://www.unoosa.org/documents/pdf/copuos/lsc/2025/Technical_Presentations/Wednesday7May/4_-_Brazil_1-20250425-64LSC-UNOOSA-Brazils-Law-_no_UNOOSA_logo.pdf.
[34] Brazilian Economic Reciprocity Law Is Published to Safeguard Brazilian Interests Against Unilateral Measures Adopted by Other Countries or Economic Blocs, Baker McKenzie (Apr. 22, 2025), https://sanctionsnews.bakermckenzie.com/brazilian-economic-reciprocity-law-is-published-to-safeguard-brazilian-interests-against-unilateral-measures-adopted-by-other-countries-or-economic-blocs; see also Lei No. 15.122, de 11 de abril de 2025, Diário Oficial da União [D.O.U.] de 14.04.2025 (Braz.), https://www.in.gov.br/en/web/dou/-/lei-n-15.122-de-11-de-abril-de-2025-623734149.
[35] Denpaho [Radio Act], Law No. 131 of 1950, art. 6, § 1(ix) (Japan), https://www.tele.soumu.go.jp/e/adm/proc/manual/index.htm.
[36] Foreign Direct Investment in Space Sector, KPMG (Mar. 2024), https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2024/03/foreign-direct-investment-in-indian-space-sector.pdf.
[37] Press Info. Bureau, Gov’t of India, Cabinet Approves Amendment in the Foreign Direct Investment (FDI) Policy on Space Sector, Release ID No. 2007865 (Feb. 21, 2024), https://www.pib.gov.in/PressReleasePage.aspx?PRID=2007865.
[38] Special Administrative Measures (Negative List) for Foreign Investment Access (2024 Edition) (promulgated by the Nat’l Dev. & Reform Comm’n & Ministry of Com., Sept. 8, 2024, effective Nov. 1, 2024), art. 6, § 11 (China).
[39] China Launches Pilot Program Allowing 100% Foreign Ownership in Telecom and Data Centers, BRICS+ New Economy & Legal Infrastructure Center (Oct. 30, 2024), https://neweconomy.expert/news/255901.
[40] China Calls for Realtime Censorship of Broadband, The Register (Sept. 30, 2024), https://www.theregister.com/2024/09/30/china_satellite_censorship; see also Guanyu Weixing Zhilian Zhongduan Dianxin Yewu Guanli de Zhanxing Guiding (???????????????????) [Interim Provisions on the Administration of Satellite Direct-to-Device Telecommunications Services] (promulgated by the Ministry of Indus. & Info. Tech., Sept. 14, 2024) (China).