Satellite Direct to Device: Ofcom Opens Mobile Spectrum to Space

ByRob Bratby Posted on Telecoms regulation
Satellite Direct to Device Ofcom mobile spectrum Bratby Law telecoms regulation

Rob Bratby, Managing Partner | Last updated: March 2026

Ofcom has authorised satellite direct to device services in UK mobile spectrum bands for the first time. The Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) Regulations 2026, which came into force on 25 February 2026, exempt handsets and SIM-enabled devices from the licensing requirement under section 8(1) of the Wireless Telegraphy Act 2006 when used for D2D satellite connectivity. Virgin Media O2 has received the first licence variation, partnering with SpaceX’s Starlink to deliver mobile coverage in areas where terrestrial networks do not reach. Vodafone (now VodafoneThree) is trialling a competing service with AST SpaceMobile. For MNOs, MVNOs, infrastructure investors and equipment suppliers, this creates both a new coverage tool and a new regulatory compliance layer.

The regulatory framework for satellite direct to device

Ofcom’s authorisation framework for satellite direct to device services rests on two instruments. The first is the WTA 2006 exemption regulation made under section 8(3), which removes the requirement for individual handsets to hold a wireless telegraphy licence when receiving D2D satellite signals. The second is a licence variation mechanism: MNOs that wish to offer D2D must apply to Ofcom to vary their existing Wireless Telegraphy licences, adding a dedicated D2D schedule with conditions on coordination, interference management and the contractual relationship with the satellite operator.

Ofcom’s decision followed a three-stage process. The initial consultation launched in early 2025. A statement and further consultation published on 9 September 2025 set out the core framework. A final statement on 9 December 2025 confirmed the policy decisions. The exemption regulations were made on 16 February 2026 and came into force on 25 February 2026.

D2D is permitted in all frequency division duplex (FDD) and supplementary downlink (SDL) mobile bands below 3 GHz: 700 MHz, 800 MHz, 900 MHz, 1400 MHz, 1800 MHz, 2.1 GHz and 2.6 GHz. Time division duplex (TDD) bands are excluded for the time being. The MNO uses its own licensed spectrum; the satellite operator provides the orbital infrastructure. From the handset’s perspective, the satellite signal looks like a standard mobile cell.

Analysis: what the framework changes and where ambiguity remains

The most important feature of this framework is its use of existing mobile spectrum rights. Ofcom has not allocated new spectrum for satellite services. Instead, it allows MNOs to extend their licensed sub-3 GHz holdings into the orbital domain. This is a spectrum management innovation: the same frequencies serve both terrestrial and non-terrestrial networks, with coordination obligations replacing the traditional separation of satellite and mobile allocations.

The licence variation mechanism gives Ofcom granular control. Each variation includes conditions on power flux density (PFD) limits at the Earth’s surface, cross-border coordination requirements and, for the 2.6 GHz band specifically, protection of air traffic control radars operating between 2.7 and 3.1 GHz. The MNO must demonstrate that combined out-of-band emissions from satellite and terrestrial transmissions do not exceed radar protection limits. This is a shared responsibility: the MNO calculates how to divide the interference budget between its terrestrial and satellite operations.

D2D services operate on a non-interference, non-protection basis. They must not cause harmful interference to other spectrum users and cannot claim protection from interference themselves. This is standard for secondary or exempt use, but it means D2D services could in theory be disrupted by legitimate terrestrial network changes. For operators designing coverage commitments around D2D, this status carries commercial risk.

Cross-border coordination adds further complexity. Ofcom requires the MNO to communicate with co-channel operators in adjacent jurisdictions before activating D2D transmissions, agreeing operational arrangements for reporting and investigating suspected interference. Applicants must provide evidence of this communication as part of the licence variation request. For operators with spectrum holdings near borders, this is a material administrative burden.

One unresolved question is how D2D interacts with MVNO access obligations. If a host MNO varies its licence to enable satellite direct to device, does the MVNO obtain the benefit of that coverage extension? The answer will depend on the terms of the MVNO agreement, not on the regulatory framework. But Ofcom has not addressed whether existing wholesale access obligations (under General Condition B2) extend to D2D-derived coverage. This gap will matter as operators begin to market satellite coverage as a differentiator.

Commercial and operational implications

For MNOs, satellite direct to device is primarily a coverage gap solution. The UK still has areas, particularly in rural Scotland, Wales and Northern Ireland, where terrestrial mobile coverage is absent or unreliable. D2D allows operators to extend coverage without building additional mast infrastructure. The economics are attractive where the alternative is a new rural site with planning permission, power supply and backhaul challenges.

VMO2’s partnership with Starlink is the first live deployment. The service uses O2’s licensed mobile spectrum and Starlink’s Direct-to-Cell satellite constellation. Initial capability is limited to SMS and basic data, though voice and broadband are expected as the satellite constellation matures. VodafoneThree is pursuing an alternative approach with AST SpaceMobile’s BlueBird satellites, which promise higher throughput (up to 120 Mbps) using standard cellular protocols.

For infrastructure investors and PE funds, D2D raises a strategic question about the value of rural tower assets. If satellite can substitute for terrestrial coverage in the most difficult locations, the business case for building new rural masts weakens. Conversely, D2D may increase the value of spectrum holdings, since sub-3 GHz FDD spectrum is now a dual-use asset covering both terrestrial and satellite delivery.

Equipment suppliers and IoT platform operators should note the interaction with connected vehicle regulation. Vehicles operating in rural areas without terrestrial coverage could maintain connectivity via D2D, provided the in-vehicle module uses a SIM profile associated with a D2D-enabled MNO. The regulatory framework does not distinguish between handset and IoT device types for the purposes of the exemption.

Compliance is not optional. Operating D2D services without a valid licence variation is a criminal offence under WTA 2006 section 35. MNOs must ensure that their satellite partner operates within the PFD limits and coordination conditions specified in the licence variation. Breach of licence conditions exposes the MNO to Ofcom enforcement action, including revocation.

Viewpoint

The UK is now among the first jurisdictions to establish a comprehensive regulatory framework for satellite direct to device in mobile spectrum. Ofcom’s approach is pragmatic: rather than creating a new licensing category, it extends existing spectrum rights with additional conditions. From a regulator’s perspective, this preserves the incentive structure of spectrum auctions while enabling a new technology layer. The real test will be whether the coordination and interference conditions prove workable at scale as multiple operators and satellite constellations compete in the same bands. For operators, the immediate priority is to review MVNO and wholesale access agreements to determine whether D2D coverage is included, excluded or undefined.

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Contact

For advice on spectrum licensing, D2D compliance obligations, or the impact of satellite direct to device on MVNO and network-sharing agreements, contact Rob Bratby at Bratby Law.

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