Behind the ambitions for computing in space lies a less visible contest: access to radio frequencies and the regulatory standing needed to use them. A central record in that contest is the Master International Frequency Register (MIFR). Yet the satellite systems described in regulatory filings can be far larger than the constellations actually operating overhead.
The resulting race is often described as “first come, first served.” That captures the strategic value of filing early, but it needs a qualification: a filing does not confer ownership of an orbit, guarantee authorization or remove the obligation to deploy satellites.
1. Satellites on Paper vs. Satellites in Orbit
The October 2026 figures compiled for this article illustrate the gap between the scale of four major constellation projects and their reported deployment.
The striking feature is the direction of the gap: the scale described in filings and expansion plans substantially exceeds current deployment. Early filings can help establish a regulatory position for future growth, well before an operator has manufactured and launched the full system.
That is the practical basis of the orbital “land rush.” The asset being pursued is a stronger position in future spectrum coordination, rather than ownership of a physical patch of space.
2. The ITU Framework: Filing, Coordination and a Deployment Clock
The International Telecommunication Union (ITU) administers the international framework for radio-frequency use and associated satellite-orbit resources. It does not operate a global enforcement force. Its system relies on treaty obligations, national administrations and procedures for publication, coordination, notification and recording.
For a general introduction, the process can be understood in three stages, although the precise route depends on the frequency bands and services involved.
Filing and Publication
A national administration submits information about a proposed satellite system on an operator’s behalf, including its frequencies and orbital characteristics. Depending on the applicable procedure, this involves advance publication information or a coordination request. The relevant filing date can affect the system’s regulatory position.
Coordination
Where required, the submitting administration coordinates with other affected administrations to resolve potential harmful interference. Operators provide the technical analysis and negotiate operating arrangements. This can be one of the longest and most difficult parts of the process.
Notification and Recording
Frequency assignments are notified to the ITU Radiocommunication Bureau for examination and, where the applicable conditions are met, recording in the MIFR. Their international recognition and protection depend on their regulatory status and compliance with the Radio Regulations.
The central constraint is time. Frequency assignments generally must be brought into use within a seven-year regulatory period. For qualifying non-geostationary-satellite orbit (NGSO) systems, bringing an initial satellite into use does not end the deployment obligations.
The World Radiocommunication Conference 2019 (WRC-19) introduced additional milestones under Resolution 35, subsequently revised at WRC-23. Crucially, the standard milestone clock runs from the end of the seven-year regulatory period, rather than simply from the date the first satellite begins operating.
The objective is to prevent spectrum warehousing: maintaining large regulatory claims without deploying the corresponding systems. Failure to reach a milestone does not automatically eliminate every frequency assignment associated with a constellation. Instead, the notified or recorded system must be reduced in accordance with the applicable deployment threshold.
This is a mechanism for bringing the regulatory record closer to deployment reality, rather than an automatic all-or-nothing cancellation.
3. Why 2026 Matters for Older Systems
Resolution 35 includes transitional provisions for systems whose seven-year regulatory period ended before January 1, 2021. For these systems, the deployment milestones are measured from that date: 10% by January 1, 2023; 50% by January 1, 2026; and full deployment by January 1, 2028, with the corresponding reporting deadlines falling one month later.
A separate provision allowed qualifying assignments whose seven-year regulatory period ended before November 28, 2022 to avoid the reduction associated with missing the first, 10% milestone. This required complete supporting information by March 1, 2023 and a favorable determination by the Radio Regulations Board or WRC-23.
These are distinct arrangements. The first-milestone exemption did not create a blanket exemption from subsequent deployment requirements.
By October 2026, the transitional 50% milestone had passed. For affected systems, the question was therefore concrete: had deployment reached the required level, or did the regulatory record need to be reduced? This makes 2026 an important checkpoint, although it would be misleading to describe it as the first year in which all “paper constellations” faced consequences.
What Does “First Come, First Served” Actually Secure?
Low Earth orbit does not consist of fixed “parking spaces” comparable to geostationary orbital positions. Its operating constraints include radio interference, collision risk and the complexity of coordinating multiple systems.
The ITU framework addresses spectrum use and associated orbital characteristics; it does not allocate exclusive ownership of low Earth orbit or serve as a global collision-control authority.
In spectrum coordination, filing earlier can provide a stronger regulatory position under the applicable rules. Later systems must account for the protection requirements of earlier assignments. But filing priority is conditional, and it remains subject to coordination, deployment obligations and other regulatory requirements.
That distinction also matters when interpreting constellation size. Starlink’s widely cited 42,000-satellite figure should not be described as an approved ceiling. More broadly, large proposed systems can preserve options for expansion, but a proposed satellite count is neither a launch commitment nor proof of authorization.
4. Laser Links Reduce the Spectrum Burden of Computing in Space
Optical inter-satellite links (OISLs) offer an important advantage for orbital computing networks: they transmit data using light rather than the radio-frequency bands used by conventional satellite communications.
Optical wavelengths fall outside the radio-frequency definition used in the ITU Radio Regulations. Their highly directional beams also allow substantial spatial reuse. Consequently, optical links between satellites do not require the same radio-frequency assignments and spectrum-coordination procedures as radio links.
This gives constellation designers more flexibility to move data between spacecraft and distribute computing tasks across an orbital network. Architectures such as the Space Development Agency’s Transport Layer and proposed AI satellite networks illustrate the value of an optical backbone.
That advantage does not make a constellation exempt from regulation. Spacecraft authorization, safety and other applicable obligations still matter. Nor does using lasers between satellites remove the need to plan the system’s connections with Earth.
For systems that use radio links to reach ground infrastructure and customers, three functions remain particularly important:
Feeder links: Connections between satellites and ground gateway stations. These commonly use Ka-band, with Q/V-band also relevant to high-capacity architectures. Their bandwidth requirements can make spectrum sharing and coordination demanding.
User links: Connections between satellites and customer terminals, often in Ku- or Ka-band for broadband systems. Available spectrum directly influences service capacity.
Telemetry, tracking and command (TT&C): Links used to monitor and control spacecraft. Frequencies vary by mission and authorization, with S- and X-band among the options. These links carry less traffic than broadband channels but are essential to spacecraft operations.
Optical ground links are also possible. The distinction is therefore not that every connection to Earth must use radio, but that any radio-based connection remains subject to the relevant spectrum and licensing framework.
For orbital computing, lasers can ease a major internal networking constraint. The system’s gateways to customers and ground inThe Satellite Spectrum Race Why Filing First Mattersfrastructure still require careful technical and regulatory planning.
5. Three Implications for the Industry
Deployment Deadlines Matter Because Administrations Act on Them
The ITU has no global enforcement force, but its Radio Regulations form an international treaty framework. National administrations give that framework practical effect through licensing, reporting and supervision.
In the United States, the Federal Communications Commission (FCC) can attach deployment deadlines and bond requirements to satellite authorizations. China’s constellation programs operate within a different national planning and approval framework. These arrangements should not be treated as interchangeable, but both show why an operator must consider national requirements alongside international coordination.
Filing Scale Represents an Expansion Option
Using a headline figure such as 42,000 or 15,000 as a forecast of how many satellites will inevitably be launched is a common analytical mistake.
A filing describes a proposed system and can help establish its regulatory position. Actual deployment depends on manufacturing capacity, launch availability, financing, technical readiness and authorization. Production output and launch cadence provide a more useful measure of near-term delivery than proposed constellation size alone.
Optical Networking Has a Commercial Advantage as Well as a Technical One
Moving more traffic and computing coordination onto optical inter-satellite links reduces reliance on congested radio-frequency resources within the constellation. That can simplify part of the spectrum challenge while enabling high-capacity networking.
Amazon Leo has designed laser links into its production constellation, following demonstrations of 100 Gbps links between prototype satellites. SpaceX introduced laser-equipped Starlink spacecraft before expanding their use with its v1.5 generation.
The broader lesson is that optical networking is becoming central to constellation architecture. Its attraction combines bandwidth, network reach and reduced dependence on radio spectrum for links between spacecraft.
Outlook: What Could Happen Next?
The following is a scenario, rather than an established outcome.
If substantial numbers of constellations have to reduce their notified scale after missing milestones in 2027–2028, the immediate result may be a redistribution of regulatory opportunities rather than visibly emptier orbits.
Operators able to manufacture and launch satellites consistently could gain a stronger position. Demand could also grow for specialist filing management, coordination and regulatory advisory services. Any arrangement involving filings held or managed on another operator’s behalf would still need to satisfy the relevant national and ITU requirements; a filing should not be assumed to be a freely transferable asset.
No regulatory announcement establishes this scenario as an inevitable outcome. It is a possible consequence of the gap between ambitious filings and the capacity to deliver spacecraft.
For businesses buying satellite services, that gap makes one question especially useful: what can a provider deliver today? STARPATH GLOBAL helps customers turn available satellite resources into practical imagery and monitoring services, matching coverage, revisit frequency and resolution to the task. To explore an option suited to your operations and budget, talk to our team.
