The FCC Rewrote the Rules for Space. Here's Where Manifest Shows Up.

Order 26-47 replaces the FCC's satellite licensing framework and makes sharing where your spacecraft is part of holding a license. We filed in the proceeding. Here's what changed, where we're cited, and what comes next.

On July 22, 2026, the Federal Communications Commission adopted its Space Modernization Report and Order and Further Notice of Proposed Rulemaking (FCC 26-47). The order retires Part 25, the rule part the FCC has used to license satellites for decades, and replaces it with a new Part 100 built around what the Commission calls a "licensing assembly line."

Most of the coverage has focused on licensing speed, and reasonably so. For us, the more important changes are in the operational rules, because they describe the behavior a crowded orbit increasingly depends on: knowing where every spacecraft is, and being able to reach the people flying it.

Manifest Space filed comments in the proceeding, and the final order cites those comments four times. Below is what the order does, where we appear, and the one place the Commission went a different direction than we proposed.

WHAT THE ORDER DOES

The order is long, and most of it concerns how applications move through the FCC. A handful of changes matter most for the operators we work with.

A license category for spacecraft that don't hold still. The new Variable Trajectory Space Station (VTSS) category covers systems operating beyond geosynchronous orbit or without fixed or predictable patterns, including orbital transfer vehicles, rendezvous and proximity operations platforms, in-space servicing systems, and lunar missions. These missions previously had to fit into rules written for satellites that stay put. A companion Multi-Orbit Satellite System (MOSS) category covers systems that combine orbit types under one call sign.

Ephemeris sharing becomes a licensing requirement. Space station operators must file their ephemeris data with a space situational awareness provider. The Commission encourages updates every eight hours for satellites in or passing through low Earth orbit (below 2,000 km) and every 24 hours above that, and directed the Space Bureau to develop procedures covering which SSA providers qualify, what gets submitted, and how often.

Every operator names a collision avoidance contact. The point of contact information operators already file must now include a point of contact for collision avoidance, updated within 10 days of any change.

Constellations report on safety. Non-geostationary operators will file semi-annual space system safety reports, including the number of conjunction events.

These rules take effect on a Part 100 Effective Date that the Space Bureau will announce by public notice.

WHERE MANIFEST SHOWS UP

Our comments are cited in four footnotes. Here is each one, including the one that did not go our way.

The VTSS license category (footnote 136). We are cited among the commenters supporting a dedicated category for variable-trajectory missions. The Commission adopted it, with a slightly revised definition. This matters to us because rendezvous, proximity operations, and servicing missions are among the operators with the most to gain from clear identification in orbit.

The ephemeris sharing requirement (footnote 867). We are cited among the commenters supporting a requirement that operators share ephemeris data. The Commission adopted the requirement, noting that no commenter categorically opposed it.

Reporting cadence (footnote 869). We proposed a minimum reporting frequency of once per second for spacecraft below 4,000 km, and no less than once every eight hours above that. The Commission did not adopt this. It noted that once-per-second reporting would be challenging for some systems below 4,000 km and that no other commenter supported the proposal. It chose the eight-hour and 24-hour cadences described above, while noting that its low Earth orbit threshold is conservative and could evolve with further experience.

Future ephemeris requirements (footnote 1030). In the Further Notice of Proposed Rulemaking that accompanies the order, the Commission cites our comments among those largely supportive of ephemeris sharing as it opens the question of what future requirements should look like.

We'd rather be clear about the cadence citation than round it up. Our proposal sat at the ambitious end of the record, and the Commission chose a more conservative starting point. We still believe coordination in congested orbits will need position information much fresher than every eight hours, especially for spacecraft that maneuver. The Commission has now opened that question for further comment.

WHAT COMES NEXT

The Further Notice asks directly about the questions closest to our work:

Should operators share updated ephemeris data more often than every eight hours, and if so, how often? Should operators engaged in rendezvous, proximity operations, or servicing share more frequently than others, and give the Commission advance notice before starting those operations? Are there technical limits that make more frequent sharing harder for some operators, and should requirements phase in over time?

It also asks whether the Space Bureau should certify qualified private ephemeris tracking systems as sufficient for complying with the sharing rules, what criteria that certification should use, and whether certified systems should make ephemeris information freely available to all operators.

Comments on the Further Notice are due 30 days after it is published in the Federal Register, with replies due 30 days after that. We plan to stay in the docket.

WHAT THIS MEANS FOR OPERATORS

For most operators, the practical changes are straightforward: plan to file ephemeris data with an SSA provider, and designate a collision avoidance contact who can make decisions during a high-risk conjunction. If your mission involves rendezvous, proximity operations, or servicing, the Further Notice is worth reading closely, since the Commission is asking whether those missions should face more frequent reporting.

The larger signal is the direction of travel. Being identifiable, locatable, and reachable in orbit is moving from good practice to a condition of operating. That is the problem Manifest Space was founded to work on, starting with an onboard optical beacon that lets a spacecraft announce who it is and where it is from the moment it deploys. We'll keep contributing to the record as the rules take shape.

Read the full order: FCC 26-47

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