The U.S. Federal Communications Commission (FCC) has published a Notice of Proposed Rulemaking (NPRM) that would allow devices operating under its Part 15 unlicensed rules, such as Wi-Fi, Bluetooth and IoT devices, to communicate directly with satellites.
The NPRM, Unleashing Unlicensed Spectrum for Direct-to-Device (ET Docket No. 26-169, FCC 26-51), was adopted on 6 August 2026 and published in the Federal Register on 8 September 2026. It focuses on two bands that are already used heavily by unlicensed devices:
- 2400–2483.5 MHz
- 5725–5850 MHz
The FCC says its aim is to expand direct-to-device (D2D) connectivity without changing the interference environment for existing licensed services or terrestrial Part 15 devices.
Key Proposals
Satellite Uplinks in the 2.4 GHz and 5.8 GHz Bands
The FCC proposes adding a new footnote, NG36, to the U.S. Table of Frequency Allocations. It would allow non-Federal mobile-satellite service (Earth-to-space) operations in both bands, on an unprotected, non-interference basis under the Part 25 satellite rules.
These operations currently need a case-by-case waiver. For example, Hubble Network was granted a waiver for satellites receiving Bluetooth Low Energy signals from 100 mW devices, limited to infrequent use from a single U.S. location. The proposed footnote would remove the need for such waivers.
Importantly, the FCC proposes no changes to the existing Part 15 technical limits for devices transmitting to satellites, including:
- maximum power of up to 4 W (36 dBm) EIRP
- antenna gain
- bandwidth
- out-of-band emissions
It does, however, seek comment on whether higher power or satellite-specific antenna requirements could support higher-value services.
Satellite Downlinks Under Consideration
The FCC is not yet proposing rules for satellite-to-device (space-to-Earth) transmissions. It is seeking comment on using the U-NII-3 band (5725–5850 MHz) for downlinks, along with the safeguards that would be needed, such as:
- power flux density (PFD) limits
- beam footprint limits
- aggregate emission limits across multiple constellations
- out-of-band emission limits
- contention-based protocols such as listen-before-talk
The FCC cites Europe’s approach in the 862–870 MHz band, where the ECC has set conditions for short-range devices to communicate with satellites, as a reference point.
Licensing Framework
The FCC is considering two main options for authorising user devices to communicate with satellites:
- License by rule: Similar to its 2024 Supplemental Coverage from Space (SCS) framework, a device operating within its Part 15 equipment authorisation would be licensed as a satellite earth station automatically, with no individual application.
- Blanket earth station licensing: A streamlined “light touch” Part 25 blanket licence covering large numbers of identical devices.
Satellites would be authorised under Part 25, typically as an add-on to operations in traditional satellite bands.
Part 15 Devices Inside Spacecraft
The FCC proposes a new Part 15 section confirming that certified intentional and unintentional radiators, such as laptops, smartphones and smartwatches, may operate within spacecraft. This would replace the current ad hoc process, where devices taken onto the International Space Station are checked by the FCC before each mission.
The FCC is also seeking comment on:
- Part 15 devices used for extravehicular activity and communications between spacecraft
- unintentional emissions from satellites that may be affecting ground-based receivers
What It Means for Equipment Authorisation
The FCC does not propose changing the existing requirement for Part 15 intentional radiators to be certified through an FCC-recognised accredited test laboratory and a Telecommunication Certification Body (TCB).
It is seeking comment on whether devices intended to communicate with satellites should also hold a Part 25 certification. If this is adopted, the FCC proposes that:
- it would apply only to new equipment authorisations or permissive changes
- equipment already certified under Part 15 could communicate with satellites under its existing authorisation
- no additional testing would be needed beyond meeting the Part 15 technical rules
The NPRM also asks whether equipment and entities on the FCC’s Covered List should be excluded from these new satellite pathways.
Comments are due on the 9th November 2026, and Reply Comments are due 7th December 2026.
What This Means for Industry
This is a proposal, not a final rule, so no compliance obligations change yet.
However, manufacturers of Wi-Fi, Bluetooth and IoT products should follow the proceeding closely. It could open a new satellite connectivity pathway for existing device designs without new hardware or spectrum licences.
The outcome on Part 25 certification will determine whether satellite-capable Part 15 devices face any additional equipment authorisation steps. Manufacturers with an interest in D2D services may also wish to submit comments before the November deadline.
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