Satellite Operations
Ground segment, payload, and constellation compliance
The FCC five-year post-mission disposal rule adopted in the Second Report and Order FCC 22-74 (29 September 2022), which applies to satellites launched after 29 September 2024.
Satellite operations encompass ground segments, space vehicles, and the communications links between them. Thalorin provides compliance infrastructure for the full satellite operations lifecycle, from mission planning through end-of-life, addressing both commercial and government requirements.
On 22 July 2026 the FCC adopted Space Modernization for the 21st Century in SB Docket 25-306 and replaced Part 25, the satellite licensing framework it had used for decades, with a new Part 100. Applications become modular and certification-based, public notice is a uniform fifteen days rather than thirty, and an application that certifies to the requirements carries a presumption of being in the public interest outside targeted review categories such as a failure to certify or a waiver request. The streamlined small satellite process is eliminated.
The same order turned a licence into a set of standing duties. Space station licensees and market access recipients must submit accurate and timely ephemeris — including propagated ephemeris and covariance for planned manoeuvres — to the 18th Space Defense Squadron and to a Commission-identified space situational awareness system, and NGSO operators must file a space system safety report twice a year. On the Part 100 effective date, which the Space Bureau announces, existing authorisation holders must comply with the new rules while Part 25 leaves the Code of Federal Regulations.
The design freeze is what catches operators. A spacecraft cannot be re-imaged: whatever command authentication, key management and software update path launched is what that vehicle has for life, so a gap in the space segment is a permanent condition rather than a remediation item. A six-year-old constellation usually flies two or three bus baselines at once under a single licence, and any fleet-wide control claim is therefore wrong about most of it.
Thalorin models the constellation by baseline rather than as a fleet. Each bus generation carries its own control state and its own dated compensating controls where the space segment cannot change, so the split between what can still be fixed and what was frozen at launch becomes visible rather than assumed. The ground segment is modelled once and shared across baselines, because that is the half of the system where remediation is still possible.
Space operations face unique security challenges
Part 25 became Part 100
Part 25 leaves the Code of Federal Regulations on the Part 100 effective date, and the Space Bureau will post a frozen copy so licence conditions citing it stay enforceable. Internal procedures citing Part 25 rule numbers get no such treatment.
Ephemeris sharing is an operating duty
Submitting timely ephemeris, and propagated ephemeris and covariance for planned manoeuvres, has to be performed and evidenced continuously. It is not a commitment made once in an application and revisited at renewal.
The space segment cannot be patched
Command authentication and key management fly as designed. Where a required control cannot exist on the vehicle, the compensating control lives on the ground, is argued explicitly, and is evidenced for that spacecraft's remaining life.
One licence, several bus generations
A mature constellation flies hardware baselines built years apart. A posture written for the newest bus describes none of the older ones accurately, and an assessment scoped to the operations centre never notices the difference.
How Thalorin helps
Ground segment cybersecurity
Model the ground segment against the profile in NIST IR 8401, covering mission and payload operations centres and terminals as accountable components rather than one undifferentiated network.
Payload security compliance
Separate payload from bus in the control model so hosted and third-party payloads carry their own boundary — the interface problem NIST IR 8441 was written to address for hybrid satellite networks.
Constellation management systems
Hold control state per bus baseline, so a fleet-wide claim resolves to the vehicles that actually hold it and a retiring generation drops out of the posture instead of quietly weakening it.
Telemetry protection
Treat telemetry stores, downlink paths and third-party ground station providers as in-boundary components, with each provider's obligations recorded against the antenna time it sells.
Command authorization controls
Record command authentication and key management as design-frozen facts per vehicle, with ground-side compensating controls dated, using SPARTA techniques as the threat reference rather than a terrestrial catalogue.
Space vehicle software security
Bind flight software build provenance and the update path to the version running on each vehicle, so a defect resolves to the units carrying it rather than to the repository.
Satellite Operations: common questions
What replaced FCC Part 25 for satellite licensing?
Part 100. The FCC adopted Space Modernization for the 21st Century on 22 July 2026, replacing Part 25 with a regime built on modular, certification-based applications, a uniform fifteen-day public notice period and a presumption that a certified application is in the public interest. The streamlined small satellite process was eliminated. The Space Bureau announces the effective date, and applications still pending then will be reviewed under the Part 100 process, with a grace period to supplement them.
Do satellite operators have to share ephemeris data with the FCC's new rules?
Yes. Space station licensees and market access recipients must submit accurate and timely ephemeris for every spacecraft in an authorised system, including propagated ephemeris and covariance for any planned manoeuvre, to the 18th Space Defense Squadron and to one or more US space situational awareness systems the Commission identifies. Cadence is encouraged rather than fixed for now. Variable trajectory satellite system applicants additionally certify that they will register with an approved SSA provider at least thirty days before launch.
Does the FCC five-year deorbit rule apply to satellites already on orbit?
It turns on the launch date, not the filing date. Satellites already in orbit when the rule was adopted on 29 September 2022 are exempt, and already-authorised but unlaunched satellites received a two-year grandfathering period. Satellites launched after 29 September 2024 must comply with the five-year post-mission disposal requirement, replacement spacecraft included. That catches operators who assume an older authorisation carries the older twenty-five-year expectation across a whole constellation.
What space safety reports does an NGSO operator have to file?
A semi-annual report, in the Commission's filing system, beginning after the launch of the first satellite in the system. It is due by 1 January and 1 July each year and covers the preceding six months: the number of conjunction events identified, how many resulted in an action such as a manoeuvre or coordination with another operator, the number of satellites removed from operation or screened from further deployment, and the number that re-entered the atmosphere.
How do I evidence a control my spacecraft cannot implement?
By documenting the compensating control on the ground and tying it to the vehicles it covers. A fielded spacecraft cannot gain command encryption or a new key hierarchy after launch, so the honest position is per-baseline: this control is not implemented on these vehicles, these ground measures compensate, this evidence shows they operate. Assessors accept that far more readily than a fleet-wide claim that quietly excludes older hardware.
Regulatory state described as of August 2026. Requirements change; verify against the current rule before relying on any date above.
Talk to us about Satellite Operations.
See how one evidence artifact satisfies Satellite Operations requirements alongside every other framework you carry.