The FCC 5-Year Deorbit Rule: What Every Satellite Operator Needs to Know

In September 2022, the FCC adopted a landmark rule reducing the post-mission orbital lifetime for LEO satellites from 25 years to 5 years. Here's what you need to know.

The Rule

The FCC's Second Report and Order (FCC 22-74) requires satellites that end their missions in, or pass through, LEO (below 2,000 km) and plan disposal by uncontrolled atmospheric reentry to complete disposal as soon as practicable and no later than 5 years after the end of the mission. Key details:

• Applies to: New licensees and existing applicants with authorized satellites to be launched after September 29, 2024
• Retroactive: No. Satellites already in orbit are exempt; already-authorized satellites got a two-year grandfathering period, so those that would exceed the 5-year limit had to launch before September 30, 2024
• International scope: Applies to any satellite serving the US market, regardless of where it's licensed
• Compliance: Operators must demonstrate a specific deorbit plan in their application

Who It Affects

• New constellations: Any new constellation filing with the FCC must include propulsion or design-for-demise ensuring 5-year deorbit
• CubeSats and smallsats: Many CubeSats historically lacked propulsion and relied on natural orbital decay. At altitudes above ~500 km, natural decay exceeds 5 years; these missions now need propulsion or lower orbits
• Modification applications: If an existing constellation files a modification (adding satellites, changing orbits), the new satellites must comply

How to Comply

• Active propulsion: The most reliable approach. Include a propulsion system capable of lowering the perigee to ensure reentry within 5 years. Electric propulsion (Hall-effect or electrospray) is increasingly affordable for smallsats
• Low-altitude deployment: Deploy below ~400 km where natural atmospheric drag ensures deorbit within 5 years without propulsion. Trade-off: more frequent station-keeping burns during mission life
• Drag augmentation: Deployable drag sails or balloon devices that increase cross-sectional area after end-of-mission. Less proven than propulsion but lower cost and mass
• Design for demise: Not part of the 5-year rule, but designing a satellite to burn up completely during reentry lowers the risk to people on the ground

Track compliance requirements at SpaceNexus Compliance Hub.