On July 16, 2026, the Federal Communications Commission (“FCC”) released a draft Notice of Proposed Rulemaking (“NPRM”) seeking comment on proposals to permit direct-to-device (“D2D”) operations from satellites to unlicensed equipment. Currently, D2D devices that communicate with satellites would need to be licensed in one form or another. The NPRM sets out the following bands as eligible for unlicensed devices to communicate with satellites: 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz. These bands were identified since they currently permit unlicensed equipment to operate at relatively higher power levels (which would be necessary for some satellite operations). Per the NPRM, this rule change would give additional connectivity options to consumer equipment makers (from smartphones and laptops to new devices) as well as for Internet of Things (“IoT”) sensors and other technologies where there is no terrestrial coverage.
The FCC is set to vote on the NPRM during its meeting on August 6, 2026, and then after publication in the Federal Register the comment cycle will run (30 days for comments, 60 days for reply comments). Below is a summary of the NPRM’s key proposals.
- Part 15 devices can communicate with satellites. The NPRM seeks comment on permitting D2D services for unlicensed devices operating consistent with the Commission’s existing Part 15 technical rules, which govern equipment like smartphones, laptops, IoT sensors, and other consumer devices. Under Part 15, devices such as baby monitors and garage door openers cannot (a) cause harmful interference to other devices and (b) must accept interference from other services. The NPRM asks whether Part 15 devices intended to communicate with satellites should also require a Part 25 certification. This approach is compatible with the “license by rule” mechanism (discussed below), which the Commission uses periodically to retain some control over devices but also streamline the licensing process.
- Specific bands for Part 15 devices and satellite communications. The NPRM proposes permitting Earth-to-space D2D operations for Part 15 devices in the following bands: 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz. The proposed framework would permit transmissions at existing Part 15 power levels. The NPRM also seeks comment on whether to permit space-to-Earth operations in the 5725-5850 MHz band (and potentially other bands), and on the technical rules needed to facilitate sharing and avoid harmful interference.
- The NPRM generally contemplates that any satellite operations within these bands would occur on an unprotected, non-interference basis, consistent with the existing treatment of Part 15 operations, and seeks comment on the technical measures necessary to protect incumbent services and existing unlicensed users.
- Licensing approach to these Part 15 devices. The NPRM seeks input on the appropriate licensing frameworks. The NPRM asks whether satellite licensing should follow the Supplemental Coverage from Space authorization framework, a “license-by-rule” framework, or other alternatives. The NPRM also seeks comment on the appropriate approach for licensing user devices.
- Miscellaneous other rule changes. The NPRM seeks input on how the proposed changes could be implemented consistent with the U.S.’s international treaty obligations. It also seeks input on rule changes to clarify that Part 15 devices may be used within spacecraft and seeks comment on whether such devices may be used for spacecraft-to-spacecraft communications or extravehicular purposes. Finally, it proposes various technical and service rule amendments to permit D2D operations in the relevant bands.
We will update this blog once the NPRM is adopted to incorporate any significant changes.