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Mega-Constellations and Their Regulatory Challenges

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by Boudour Mefteh (Policy Intern at CELI)

In recent years companies have launched mega-constellations of satellites, vast networks of small spacecraft, into Low Earth Orbit (LEO). A mega-constellation is typically understood as a large-scale network of satellites (often hundreds or thousands) operating together to provide services like global internet and data connectivity.[1] For example, SpaceX’s Starlink system and similar constellations by OneWeb, Amazon (Kuiper), and others are designed to blanket the globe with high-speed, low-latency broadband.[2] In principle, these networks can help “bridge the digital divide by offering high-speed internet access to even the most remote regions”[3], and they promise new services (from Earth observation to IoT support) that could boost economic productivity.

Yet the proliferation of satellites also raises serious new issues. These include questions of orbital congestion, space debris, and interference with astronomy, as well as legal and regulatory gaps in how these systems are overseen. Unlike traditional missions (as a single satellite or a few satellites in geostationary orbit), mega-constellations involve deploying thousands of spacecraft in LEO, where they operate at relatively low altitudes. This density of satellites can generate unprecedented challenges for space traffic management and long-term orbital sustainability.[4] It also poses terrestrial concerns, such as atmospheric pollution from rocket launches and the risk of reentering debris. This article explains what mega-constellations are, surveys the existing legal and regulatory frameworks for space activities, and examines the challenges posed by mega-constellations; especially the environmental, scientific, and governance issues that stretch current law beyond its design. It takes a critical perspective on whether international law, national regulators, and voluntary guidelines are adequate to the task.

Mega-Constellations: Definition and Overview

    The term mega-constellation refers to a collection of satellites operating in concert, usually in Low Earth Orbit (LEO) between roughly 300 and 1200 kilometers altitude. Unlike a traditional geostationary communications satellite, which hovers over one region of the Earth, LEO satellites move quickly across the sky.[5] Mega constellations typically involve “large-scale networks of hundreds or thousands of satellites designed to deliver high-speed, low-latency internet and data services across the globe”.[6] For instance, SpaceX, by October 2025, has reached has launched over 10.000 Starlink satellites (with plans for many thousands more)[7], aiming to provide global broadband coverage. These networks can indeed revolutionize connectivity by linking remote regions to the internet, supporting aviation and maritime communications, disaster relief, and other applications.[8]

    The technical enablers of this revolution include miniaturized electronics, cheap mass-production, reusable rockets, and inter-satellite laser links, which collectively allow firms to build and deploy satellites rapidly.[9] The low-orbit placement yields low communication latency, an advantage over traditional geostationary satellites. In broader terms, analysts note that the current “transformation in [the satellite] sector is driven by the rise of LEO satellite mega-constellations[10], and many private companies around the world (as well as government programs like the EU’s IRIS²) are racing to establish such constellations.

    At the same time, the surge in satellites changes the “spacescape” of Earth orbit. The rapid rise of mega-constellations is literally reshaping how LEO is used. Astronomers and regulators alike worry that these satellites, and the debris they may leave behind, degrade space and sky environments. A recent study notes that constellation satellites “reflect sunlight into astronomical telescopes” and cross fields of view, degrading observations that are crucial for understanding the universe and protecting Earth (for example, early warning of asteroids).[11] Thus, although mega-constellations enable new capabilities (like global broadband and Earth imaging), they also introduce unprecedented environmental and regulatory challenges that the existing space law framework did not anticipate.

    International Legal Frameworks

    Space activities, whether governmental or private, are governed by an international legal framework built around a few core treaties and agreements. The foundational treaty is the 1967 Outer Space Treaty (OST)[12] , which proclaims that outer space shall be the “province of all mankind” [13]and may be used only for peaceful purposes[14]. Under the OST, national governments are responsible for the space activities of their nationals[15] and must avoid harmful contamination of space and Earth.[16] States must register space objects (Registration Convention)[17] and are liable for damage caused by their space objects on Earth or in space (Liability Convention)[18]. These treaties set broad principles: no sovereign claims in space, responsibility and supervision by launching states, and due regard to others’ activities.

    For satellite communications, additional rules emerge from the International Telecommunication Union (ITU), a UN agency. The ITU allocates radio frequencies and satellite orbital slots to avoid interference between systems.[19] Satellite operators must coordinate through ITU filings (and often national filings) to secure spectrum and orbital slots. Thus any mega-constellation must be licensed both by its home country’s regulator and by compliance with ITU frequency coordination. As one recent analysis notes, the existing regulatory framework includes these instruments, “the Outer Space Treaty, ITU spectrum management, and national regulatory regimes”, but it was designed for earlier generations of satellites.[20]

    Beyond treaties, the United Nations Committee on the Peaceful Uses of Outer Space (UNCOPUOS) and related agencies issue guidelines and standards. For example, COPUOS has recommended space debris mitigation guidelines (such as post-mission deorbit or graveyard orbit of defunct satellites), but these guidelines are non-binding. Member states and operators are “invited” to follow them, but no enforcement mechanism exists.[21] Likewise, the ITU’s coordination process relies on consensus; disputes over interference are often settled politically rather than through binding authority. In practice, regulatory bodies have become fragmented: multiple agencies may have some say (for example, the ITU for spectrum, a space traffic coordinator for orbital clearance, and a national launch license authority), but none has a global mandate to manage space traffic or environmental impact.

    Along with the above we have to say that the existing international legal regime, in particular OST, was not drafted with large-scale satellite constellations in mind. As a result, it lacks clear, binding rules on many challenges posed by today’s mega-constellations: orbital crowding, collision avoidance, long-term sustainability of low Earth orbit, space debris mitigation, and interference with astronomy.  Consequently, while general principles remain in force, the legal framework is widely regarded as inadequate; leaving significant regulatory gaps with respect to contemporary satellite mega-constellation deployment.

    Orbital Congestion and Space Debris

    One of the most pressing challenges of mega-constellations is orbital congestion. Each satellite occupies a swath of orbital space and flies in formation with others; many constellations deploy planes of satellites at different inclinations. As more satellites accumulate, the risk of collisions rises. When satellites or debris collide at orbital velocity, they can shatter and create thousands of new pieces of debris, a cascading effect known as the “Kessler Syndrome”, potentially disabling large portions of LEO. Already, space debris is recognized as a “significant global challenge, jeopardizing the sustainability of space activities”[22]. Even tiny fragments, traveling at several kilometers per second, can destroy expensive satellites or threaten the International Space Station.

    Existing estimates predict that by the mid-2030s, active constellations will dominate LEO: dozens of constellations, each with thousands of satellites, could be sharing the environment. A recent report by the FAA estimated that if current trends continue, re-entering debris from just one constellation (Starlink) could cause a casualty on Earth roughly once every two years by 2035.[23] That is because as satellites age or are retired, they burn up in the atmosphere or (rarely) reach the ground, and each breakup adds risk to both space and ground.

    The stakes are high; once LEO becomes cluttered with debris belts and collision risk skyrockets, new satellites and even crewed missions could be jeopardized. Several experts argue that effective space traffic management (STM)[24] rules are urgently needed. Without binding STM rules, operators rely on voluntary maneuvers and data-sharing (for instance through the U.S. Air Force’s space surveillance network), but there is no guarantee of global compliance. In short, mega-constellations amplify a systemic risk in orbit: they fulfill the international rule (OST Art. VI) that states must supervise their nationals, but if each operator does only the minimum required by its home regulator, no one ensures the collective safety of LEO.

    Conclusion

    Taken together, the above challenges reveal a regulatory gap. The space treaties were negotiated in an era of a few government satellites; they impose obligations on states but leave much to national implementation. The ITU coordinates frequencies but cannot enforce debris or brightness limits. Existing guidelines (from the UN or professional bodies) are voluntary. Moreover, the growth of space actors, now including many private companies and even non-state actors, complicates accountability. The Outer Space Treaty makes states responsible for their nationals’ space objects, but in practice mega-constellations involve multiple jurisdictions (manufacturers, launchers, controllers) and cross-border effects (light pollution worldwide). No single international authority can license a mega-constellation or compel an operator to deorbit satellites. Mega-constellations represent one of the most transformative developments in space technology. By deploying thousands of satellites, providers aim to deliver universal connectivity and other services that were previously science fiction. Yet this transformation comes with real costs. The night sky is changing, orbits are getting crowded, and our laws are scrambling to keep up. As one analysis warned, the new “mega-constellations era” introduces unprecedented challenges, for orbital congestion, spectrum management, and even astronomy, that the current legal regime is not fully prepared to handle.


    [1] Haritwal, Sikha. LEO Satellite Mega-Constellations: Market Dynamics, Orbital Mechanics, Policy Challenges, and the Future of Global Connectivity. SSRN, 6 Sept. 2025. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5450454

    [2] Ibid.

    [3] Ibid.

    [4] Abbas, Sheer. “Challenges to Space Activities in the Context of Mega Satellite Constellations: A Focus on Environmental Impacts.” Journal of Astronomy and Space Sciences (JASS), 2025, vol. 42, no. 1, pp. 1–13,

    [5] See, Hui Zhi, Xiaojun Jiang & Jianfeng Wang, “Multicolour photometry of LEO mega-constellations Starlink and OneWeb,” Monthly Notices of the Royal Astronomical Society, 2024. https://academic.oup.com/mnras/article/530/4/5006/7669132

    [6] Haritwal, Sikha. LEO Satellite Mega-Constellations: Market Dynamics, Orbital Mechanics, Ibid.

    [7] Jewett, Rachel. “SpaceX Hits Milestone of More Than 10,000 Starlink Satellites Launched.” Via Satellite, October 20, 2025. https://www.satellitetoday.com/connectivity/2025/10/20/spacex-hits-milestone-of-more-than-10000-starlink-satellites-launched/

    [8] Freeland, Steven R., and Anne-Sophie Martin. “A Sky Full of Stars, Constellations, Satellites and More! Legal Issues for a ‘Dark’ Sky.” Oslo Law Review 10, no. 3 (2024): 1–22. https://www.scup.com/doi/10.18261/olr.10.3.1

    [9] Haritwal, Sikha. LEO Satellite Mega-Constellations: Market Dynamics, Orbital Mechanics, Ibid.

    [10] Ibid.

    [11] Freeland, Steven R., and Anne-Sophie Martin. “A Sky Full of Stars, Constellations, Satellites and More! Legal Issues for a ‘Dark’ Sky.” Ibid.

    [12] United Nations. Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies (Outer Space Treaty), opened for signature January 27, 1967, entered into force October 10, 1967. United Nations Treaty Series, vol. 610, p. 205.

    [13] Article I, paragraph 1, Ibid.

    [14] Article IV, paragraph 1. Ibidd.

    [15] Article VI, Ibid.

    [16] Article IX, Ibid.

    [17] United Nations. Convention on Registration of Objects Launched into Outer Space, adopted November 12, 1974, entered into force September 15, 1976. United Nations Treaty Series, vol. 1023, p. 15.

    [18] United Nations. Convention on Registration of Objects Launched into Outer Space, opened for signature January 14, 1975, entered into force September 15, 1976. United Nations Treaty Series, vol. 1023, p. 15.

    [19] International Telecommunication Union. “WRS‑22: Regulation of satellites in Earth’s orbit.” ITU News, 2 January 2023. https://www.itu.int/hub/2023/01/satellite-regulation-leo-geo-wrs/

    [20] Haritwal, Sikha. LEO Satellite Mega-Constellations: Market Dynamics, Orbital Mechanics, Ibid.

    [21] COPUOS, Space Debris Mitigation Guidelines, adopted by COPUOS in 2007 (General Assembly Resolution 62/217) https://www.unoosa.org/documents/pdf/spacelaw/sd/COPUOS_space_debris_mitigation_guidelines.pdf

    [22] Abbas, Sheer. “Challenges to Space Activities in the Context of Mega Satellite Constellations: A Focus on Environmental Impacts.” Ibid.

    [23] Ibid.

    [24] European Commission, “Space Traffic Management,” Defence Industry & Space – EU Space (web page), https://defence-industry-space.ec.europa.eu/eu-space/space-traffic-management_en

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