FCC Proposes Letting Unlicensed Devices Talk to Satellites for Direct-to-Device Service

Background: Direct-to-device (D2D) service lets ordinary handsets and other consumer devices connect to satellites without special ground terminals. Most D2D activity so far has relied on licensed mobile spectrum, often through partnerships between satellite operators and terrestrial carriers. Investment and market growth in this area have prompted the FCC to look at whether unlicensed spectrum can play a larger role. The proceeding is ET Docket No. 26-169, and the Notice of Proposed Rulemaking (NPRM) was published in the Federal Register on September 8, 2026. Key provisions as described in the notice: First, the FCC proposes to permit certain unlicensed devices to communicate with satellites on a non-interference basis. In plain terms, these devices would have no protection from interference and could not cause harmful interference to licensed services or other authorized users. Second, the NPRM explores adding satellite allocations to the Table of Frequency Allocations in specific unlicensed bands. Today, unlicensed rules (such as Part 15) generally do not contemplate satellite links, and the allocation table does not always provide a satellite service in these bands. Without an allocation, satellite operators have no clear regulatory footing. Third, the FCC seeks to clarify that equipment may operate within spacecraft, which matters for uses such as wireless links on board a vehicle or station. Fourth, the Commission describes a flexible regulatory framework that preserves incumbent operations while allowing innovation. The notice asks for comment on technical, licensing and policy questions. Likely topics include which bands are suitable, power limits and aggregate interference from many devices, how satellite operators would be authorized (for example, whether a space station license or market access grant is needed and what conditions attach), how the devices would be certified, and how to protect existing Wi-Fi, Bluetooth, radio astronomy, and other incumbents. The summary does not specify the exact bands or technical limits, so companies should read the full NPRM for those details. Timeline: The Federal Register entry lists no comment deadline in the data provided. Comment and reply dates are normally set by publication date or by a public notice, so operators should check the docket in the FCC Electronic Comment Filing System (ECFS) right away. Any final rules would come only after the comment cycle and a Commission vote, so this is a multi-month process at minimum, and allocation changes may also require coordination with international rules. Implications: For satellite operators, this could open a new pathway to serve devices without acquiring licensed mobile spectrum, potentially lowering barriers to entry. Because the use would be non-interference, service quality could not be guaranteed, which limits business models to those tolerant of variable performance, such as IoT, messaging, tracking, or supplemental connectivity. Device makers might gain a way to add satellite features to products with simpler authorization. Incumbent unlicensed users, including Wi-Fi and IoT industries, will focus on cumulative interference, particularly if satellite receivers hear many devices from orbit. Licensed incumbents in adjacent bands will look for out-of-band emission protections. Companies building spacecraft that carry internal unlicensed radios should watch the clarification on equipment operating within spacecraft. Because the proposal is only an NPRM, nothing changes today. However, the record built in comments will shape the final rules, and early participants often influence technical parameters.