The Digital Networks Act: a reform that requires strategic attention for satellite operators
Satellite operators seeking EU market access may face a fundamental shift in how spectrum is authorized, how services are delivered across borders, and what operational obligations apply.
The Digital Networks Act (DNA) is the European Commission's proposed regulation on digital networks. It would repeal and consolidate the EU's existing electronic communications framework, including the European Electronic Communications Code, the BEREC Regulation and the Radio Spectrum Policy Program. The proposal aims to establish a unified regulatory framework for satellite connectivity across the EU as a single market.
While framed as telecommunications reform, the DNA fundamentally changes how satellite operators access spectrum, deliver pan-European services and manage network resilience. The European Commission describes the DNA as "a critical building block" for the EU space economy, complementing the EU Space Act's safety and sustainability framework with harmonized market access rules.
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The proposal could impact the satellite sector from a practical, technical and strategic perspective, so businesses must consider its implications early. For satellite operators already navigating the Space Act, understanding where the DNA fits will be essential over the next few years.
The DNA proposes to introduce an EU authorization for satellite spectrum, replacing existing national regimes. The regime will be informed by a new European Table of Allocation of Satellite Frequencies to be adopted by the European Commission. There are two layers: a "general authorization" for providing satellite networks and services (notification-based), plus specific spectrum authorization from the European Commission. Both layers are likely to be relevant for most operators.
In practice, the proposed new EU-harmonized model means that a satellite operator wishing to provide services across the EU would no longer need to follow 27 authorization processes, respect 27 sets of authorization conditions or obtain spectrum rights in all member states separately. This is intended to be a material simplification for operators scaling across member states, though the extent to which this is realized will depend on effective implementation and the balance struck between EU‑level harmonization and existing national regulatory responsibilities.
Where spectrum is scarce, competitive selection procedures may apply, though the mechanisms are not detailed yet. For constellation operators and direct-to-device services seeking premium frequencies, this introduces uncertainty - competitive procedures could affect deal structures and deployment timelines.
Both authorizations propose to include EU establishment requirements. This creates strategic choices for non-EU operators: establish an EU subsidiary, partner with an EU-established operator or wait for bilateral arrangements. Unlike the Space Act's registration pathway for third-country service providers, the DNA currently lacks an equivalent mechanism, though that could change as the proposal develops.
Existing national authorizations with at least six months of validity remaining are expected to continue until 36 months after the DNA enters into force, following which, national satellite spectrum authorizations are to be replaced by EU authorizations.
The DNA does not merely reorganize who grants authorizations, it also expands the substantive obligations attached to them. The DNA proposes to introduce several binding operational requirements beyond traditional spectrum licensing, including:
The Space Act governs safety and sustainability (debris mitigation, collision avoidance, end-of-life disposal), as well as licensing of space activities (e.g. launch and spacecraft operations).
The DNA focuses on market access, spectrum rights and operational resilience. In practice, satellite operators are likely to be subject to both regimes, meaning authorisations under each may need to be obtained in parallel.
The DNA's resilience framework includes continuity of emergency communications and public warnings, plus a Union Preparedness Plan addressing integration with satellite networks and system outage threats such as intentional harmful interference. Operators may be required to participate in preparedness exercises, implement business continuity measures and coordinate with national authorities.
Satellite operators designated as critical may face service continuity obligations, priority traffic requirements or capacity allocation mandates during emergencies – a shift from today's contractual commitments to specific customers. Capacity planning, SLA negotiations and revenue models may need to account for emergency requirements, particularly for multi-use constellations.
The proposal was officially published by the European Commission on 21 January 2026 and is now progressing through the EU legislative journey towards potential approval. The European Parliament and Council will develop their positions ahead of trilogue negotiations with the EU and amendments in the course of this process are inevitable.
The space sector's long lead times mean that operators may need to start looking ahead.
Some of the steps operators can take to begin strategically planning and preparing for the DNA include:
Hayley Blyth is an associate in Bird & Bird's London office, specializing in the space and satellite, technology and communications sectors. She co-leads Bird & Bird's global space and satellite practice, advising public and private sector clients on space law, regulation, commercial considerations and policy.
Roxane Olivier is an associate in Bird & Bird's Paris office, specializing in technology, telecommunications and data protection. Roxane advises technology and space businesses on the global challenges they face in the digital and communications sectors, including by ensuring their compliance with French and European regulatory obligations.
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