In recent times, discussions about satellite constellations, frequencies and orbital resources have increased significantly. However, a lot of discussions are actually based on the same misunderstanding – application, deployment, and use are regarded as the same thing. In the rules of the International Telecommunication Union (ITU), “first come, first occupied ≠ permanent possession”, it has a set of clear but not intuitive rules for judging one thing:
Are you actually using resources, or are you only occupying them on paper?
If this set of rules is not explained clearly, many calculations about constellation size, launch rhythm, and market space will actually be untenable.
01
Frequency rail application is not a “business plan”
First we need to clarify a basic fact:
Applying for frequency orbit resources from the International Telecommunication Union (ITU) does not mean that it has been approved, nor does it mean that satellites will be launched soon.
In the ITU system, application for satellite frequency orbit resources is not equivalent to commercial project approval, nor is it a launch license. It essentially only confirms three things: which frequency range you want to use; which orbital space you want to operate in; and your time priority in international coordination. The ITU does not evaluate business models, nor does it judge whether technological routes are advanced. It only cares about one issue: whether these resources are used continuously and truly. This is also the institutional starting point of the ITU’s regulations on “Bringing into Use (BIU)” satellite networks – the “Use it or lose it” principle –
Frequency rail is not an asset, but a right of use that must be maintained through continued performance.
The rights themselves automatically disappear once use ceases.
02
“First come, first served” principle and application process
Frequency rail resources are limited natural resources shared by the world, and are also strategic resources that countries compete for. They need to abide by the relevant rules of the International Telecommunication Union (ITU) to obtain the right to use them. Under normal circumstances, competition is based on the principle of “first come, first served”. However, the ITU satellite network declaration and coordination procedures have a complex set of rules at the regulatory and technical levels. Whether it can be declared in advance reasonably, complete domestic and international coordination, and finally successfully use satellite frequency orbit resources is a long and uncertain process. In the ITU Radio Regulations, applications for satellite frequency orbit resources from various countries are clearly stipulated. The entire process often lasts several months, or even years in the case of complex constellations. The application process includes: 1. Domestic application: The satellite user unit must submit the main technical documents and database of the satellite network frequency orbit to the competent authority of the country where it is located, and apply for the use of frequencies. 2. International declaration: After the competent authorities review and pass the satellite network data (generally advance publication data (Advance Publication, API/A data), coordination data (CR/C data), notification data (Notification, N data)), they submit it to the ITU and wait for publication and solicitation of international coordination opinions in the International Frequency Information Circular (IFIC, referred to as “Weekly Report”). 3. Domestic coordination: After the data is submitted to ITU, the competent authority organizes domestic publicity of satellite network data, collection of coordination opinions, frequency compatibility sharing technical consultation, and domestic coordination work. 4. International coordination: Carry out international coordination based on the coordination list published in the ITU weekly report and international coordination letters. 5. Notification and registration: After international and domestic coordination is completed and the satellite is in orbit for 90 days, the determined technical parameters, coordination results and other materials will be submitted to the ITU through the competent department in accordance with the prescribed procedures. After passing the ITU review, it will be registered in the Master International Frequency Register (MIFR).
03
Deployment “Milestones”
This is the most serious misunderstanding in the current market and online discussions. For non-geostationary orbit (non-GSO) satellite networks (often referred to as “constellations”), the International Telecommunication Union (ITU) has set clear deployment milestones to prevent resources from being idle for a long time: within 7 years: launch at least one satellite and operate continuously in orbit for more than 90 days; within 9 years: complete 10% of the declared quantity; within 12 years: 50% completed; within 14 years: 100% completed. In addition, in response to the problem that after the milestone deployment of large-scale low-orbit constellations, satellites cannot continue to be used due to malfunctions or expiration of service life but still occupy frequency orbit resources, the 2023 World Radiocommunication Conference (WRC-23) formulated post-milestone procedural rules for the constellation: Scale threshold: When the constellation is small (≤340 satellites), at least 50% of the satellites must be maintained in orbit; when the scale is large (about 4410 satellites), the threshold requirement is increased to 95%. Reporting obligations: Operators are required to submit reports to the ITU every four years to prove that they meet the deployment requirements of the above scale thresholds. Penalty measures for non-compliance: If the number of satellites is changed below the threshold, the operator has a grace period. If it cannot be restored, data must be submitted to the ITU, the number of notified or registered satellites must be reduced, and the occupied resources must be released. At the same time, stricter requirements are set for the orbit characteristic parameter tolerance of the constellation. Post-milestone rules will force megaconstellations to maintain high-intensity launch configurations and greatly increase international compliance and operational pressures. But what needs special emphasis is:
Milestones are regulatory tools, not launch plans.
In actual operations, countries and operators have considerable room for institutional maneuvering, such as: applying for an extension on the grounds of force majeure and technical adjustments; splitting large constellations into multiple networks and applying in batches; maintaining “use status” by replacing satellites and changing parameters. This is why almost no mature space country launches in a linear manner according to milestones.
04
ITU significantly increases application fees
The International Telecommunication Union (ITU) satellite frequency and orbit data fees (cost recovery fees) are calculated based on the number, type and work impact of the announced frequency assignment groups, and usually consist of a release fee (such as API/C/N), processing fee and review fee, depending on the stage and complexity of the application. When frequency rail resources are no longer just a “technical issue”, but a test of long-term performance capabilities, the ITU has also simultaneously increased the entry cost at the institutional level. In the past few years, the number of applications for low-orbit constellations has surged, and the processing pressure on the ITU has also increased rapidly. Therefore, starting from January 1, 2026: the cost recovery fees related to constellation declaration will be increased as a whole; the complexity of declaration and management requirements for large-scale NGSO constellations will be increased simultaneously. It should be noted that these fees are not a “price threshold”, but an institutional filtering mechanism – allowing constellations with real long-term operating capabilities to stay. This is why, at the end of 2025, countries’ declaration strategies will be significantly more focused and front-loaded.
05
A common misunderstanding
In many analyses, we can often see such calculation logic:
“According to the requirements of the International Telecommunication Union (ITU), a certain constellation must launch X million satellites in the next X years, so the market size is…”
This method of calculation is not valid at the institutional level. The reason is not complicated: the goal of milestones is to prevent resources from being idle rather than forcing uniform launch; the constellation system itself can adjust the scale, rhythm and structure; the actual deployment rhythm ultimately depends on technology maturity, launch capabilities and application needs. It is a typical over-interpretation to directly equate institutional constraints with business certainty.
Conclusion
What the International Telecommunication Union (ITU) rules really want to solve is not “who applies for more”, but a more realistic issue: who has the ability to use near-Earth space in a long-term, stable and sustainable manner.
From this perspective, the Constellation application is not just a “preemptive opportunity”, but an engineering and operational commitment that spans more than ten years and needs to be continuously fulfilled.
Understanding this, many debates about constellations, launches and scales can naturally return to a more rational starting point.
