• Login
    • Advanced search
    • Title
    • Channel
    • Module
  • Home
  • Client Solutions
    • Digital Transformation
    • Energy Transition
    • Supply Chains
    • Sustainability and ESG
    • Workforce Redesign
  • Sectors
    • Consumer Goods & Retail
    • Energy, Mining & Infrastructure
    • Financial Institutions
    • Healthcare & Life Sciences
    • Industrials, Manufacturing & Transportation
    • Technology
  • Learning Resources
    • Podcasts
    • Video Chats
    • Webinars
  • Area of Law
    • Antitrust & Competition
    • Artificial Intelligence
    • Banking & Finance
    • Capital Markets
    • Cybersecurity & Data Privacy
    • Data & Technology
    • Dispute Resolution
    • Employment & Compensation
    • Environment & Climate Change
    • Financial Services Regulatory
    • Inclusion, Diversity & Equity
    • Intellectual Property
    • International Commercial & Trade
    • Investigations, Compliance & Ethics
    • Mergers & Acquisitions
    • Pensions
    • Private Equity
    • Projects
    • Real Estate
    • Restructuring & Insolvency
    • Tax
  • Location
    • International

    • International
    • Asia Pacific

    • Australia
    • China
    • Hong Kong
    • Indonesia
    • Japan
    • Malaysia
    • South Korea (Korea, Republic of)
    • Singapore
    • Taipei
    • Thailand
    • Philippines
    • Vietnam
    • EMEA

    • Austria
    • Bahrain
    • Belgium
    • Czech Republic
    • Egypt
    • EU
    • France
    • Germany
    • Hungary
    • Italy
    • Kazakhstan
    • Luxembourg
    • Morocco
    • Netherlands
    • Poland
    • Portugal
    • Qatar
    • Russian Federation
    • Saudi Arabia
    • South Africa
    • Spain
    • Sweden
    • Switzerland
    • Türkiye
    • Ukraine
    • United Arab Emirates
    • United Kingdom
    • North America

    • Canada
    • United States
    • Latin America

    • Argentina
    • Brazil
    • Colombia
    • Chile
    • Mexico
    • Peru
    • Venezuela
Baker McKenzie InsightPlus Home
      • Title
      • Channel
      • Module
    • Hit ENTER to search in content
    • Advanced search
    • Login
  • Home
  • Client Solutions
    • Digital Transformation
    • Energy Transition
    • Supply Chains
    • Sustainability and ESG
    • Workforce Redesign
  • Sectors
    • Consumer Goods & Retail
    • Energy, Mining & Infrastructure
    • Financial Institutions
    • Healthcare & Life Sciences
    • Industrials, Manufacturing & Transportation
    • Technology
  • Learning Resources
    • Podcasts
    • Video Chats
    • Webinars
  • Area of Law
    • Antitrust & Competition
    • Artificial Intelligence
    • Banking & Finance
    • Capital Markets
    • Cybersecurity & Data Privacy
    • Data & Technology
    • Dispute Resolution
    • Employment & Compensation
    • Environment & Climate Change
    • Financial Services Regulatory
    • Inclusion, Diversity & Equity
    • Intellectual Property
    • International Commercial & Trade
    • Investigations, Compliance & Ethics
    • Mergers & Acquisitions
    • Pensions
    • Private Equity
    • Projects
    • Real Estate
    • Restructuring & Insolvency
    • Tax
  • Location
    • International

    • International
    • Asia Pacific

    • Australia
    • China
    • Hong Kong
    • Indonesia
    • Japan
    • Malaysia
    • South Korea (Korea, Republic of)
    • Singapore
    • Taipei
    • Thailand
    • Philippines
    • Vietnam
    • EMEA

    • Austria
    • Bahrain
    • Belgium
    • Czech Republic
    • Egypt
    • EU
    • France
    • Germany
    • Hungary
    • Italy
    • Kazakhstan
    • Luxembourg
    • Morocco
    • Netherlands
    • Poland
    • Portugal
    • Qatar
    • Russian Federation
    • Saudi Arabia
    • South Africa
    • Spain
    • Sweden
    • Switzerland
    • Türkiye
    • Ukraine
    • United Arab Emirates
    • United Kingdom
    • North America

    • Canada
    • United States
    • Latin America

    • Argentina
    • Brazil
    • Colombia
    • Chile
    • Mexico
    • Peru
    • Venezuela
  1. Energy, Mining & Infrastructure
  2. European Union: Navigating the new space order — Key takeaways from the proposed EU Space Act

European Union: Navigating the new space order — Key takeaways from the proposed EU Space Act

03 Jul 2025    5 minute read
    • Share by email
    • Share on
    • Twitter
    • LinkedIn
    • Facebook
    • Google plus
    • Get link
    • Get QR Code
    • Download
    • Print
EU Space Act Space Activities Regulation Safety and Resilience Space Sustainability Compliance Obligations

In brief

What has happened? The European Commission has just published its long-awaited proposal for a "Regulation on the safety, resilience and sustainability of space activities in the Union" (COM(2025) 335 final). This so-called "EU Space Act" lays down rules for the establishment and functioning of the internal market of space-based data and space services. This includes (a) rules on the authorization, registration and supervision of space activities, (b) orbit traffic management rules, (c) governance and enforcement aspects as well as (d) the establishment of a Union Space Label and capacity-building measures. Once adopted, the EU Space Act will be directly applicable in all EU Member States from 1 January 2030 onwards. Stakeholders across the space and telecommunications sectors should prepare for extensive new compliance obligations.


Contents

  1. In depth
    1. Context and rationale behind the EU Space Act
    2. What are the new rules?
    3. Who will be affected?
    4. When and how will the EU Space Act take effect?
    5. What to do now?

In depth

Context and rationale behind the EU Space Act

The Commission's initiative is driven by legal, strategic, and economic concerns. Currently, the European space sector operates under a patchwork of national laws. This causes a fragmentation of the internal market and undermines the legal certainty that Union space operators rely on for effective planning and operations.

Furthermore, the EU Commission highlighted in the Proposal's Recitals the increasing congestion of orbital paths, the heightened risk of collisions and cyberattacks on space infrastructure, and the environmental footprint of space operations that raise concerns regarding the safety, resilience, and sustainability of space activities.

What are the new rules?

The proposed EU Space Act is built on three pillars: safety, resilience, and sustainability. It introduces new obligations for tracking space objects, enhancing cybersecurity for space infrastructure, and minimizing environmental impacts of space operations. The rules will apply to both EU and non-EU operators active in the European market, with requirements tailored to company size and risk exposure to support innovation and ensure proportionality.

Overview of the most important rules introduced by the EU Space Act:

  • Safety
    • Collision avoidance: Spacecraft operators must subscribe to collision avoidance services.
    • Trackability and maneuverability: Spacecraft must be trackable and capable of performing avoidance maneuvers.
    • Launch safety: Launch operators must conduct risk assessments, coordinate with air traffic authorities, and implement flight safety systems.
    • Constellation-specific rules: Operators of large constellations face additional obligations, for example concerning intra-constellation collision avoidance.
    • Light and radio pollution mitigation: Operators must limit brightness and radio emissions to protect astronomical observations.
  • Resilience
    • Cybersecurity requirements: Operators must implement mission-specific risk management across all mission phases, including encryption, access control, and incident response.
    • Incident reporting: Significant incidents must be reported within 12–72 hours, depending on severity and asset type.
    • Supply chain security: Operators must assess and manage cybersecurity risks in their supply chains.
    • Testing and business continuity: Threat-led penetration testing (TLPT) and business continuity plans are mandatory.
    • Union Space Resilience Network (EUSRN): A coordination body for national authorities and the EU to manage cyber threats and incident response.
  • Sustainability
    • Debris mitigation plans: Operators must submit and implement detailed plans for debris prevention, end-of-life disposal, and passivation.
    • Environmental Footprint (EF) calculation: Operators must calculate and report the lifecycle environmental footprint of their missions, including data submission to an EU database.
    • Design for demise and re-entry: Launch vehicles and spacecraft must be designed to minimize risk during re-entry and reduce long-term orbital debris.
    • ISOS readiness: Spacecraft must be equipped to receive In-Space Operations and Services (ISOS), e.g., refueling, debris removal, via standardized interfaces.

Who will be affected?

The EU Space Act will significantly reshape compliance expectations across the space and telecommunications sectors, affecting both established players and emerging ventures. Satellite operators providing broadband, earth observation, navigation, or other services will be among the most directly impacted, facing binding obligations on collision avoidance, cybersecurity, and orbital sustainability that surpass current fragmented national rules.

Launch service providers and component suppliers — including those involved in propulsion, avionics, and payload integration — will likewise fall within scope. Their operations must align with EU-level standards on safety, resilience, and liability. Telecom companies operating satellite constellations or relying on satellite infrastructure will also be subject to the new regulatory framework.

Facilities enabling access to space, such as spaceports and launchpads, will face increased scrutiny, particularly regarding safety protocols, data sharing, and environmental controls. The same applies to data providers and space traffic management (STM) firms, which encounter new mandates on coordination, transparency, and incident reporting.

Even for startups and SMEs preparing for market entry, the Act will influence design, funding, and go-to-market strategies. The compliance landscape is no longer a distant consideration but a structural feature of operating in the European space ecosystem.

Importantly, the Act also applies to third-country operators and international organizations providing space-based services in the Union.

When and how will the EU Space Act take effect?

The recent publication of the Proposal for an EU Space Act has set the stage for a comprehensive policy debate. Stakeholder engagement and institutional review will now intensify toward the end of 2025, with the European Parliament and the Council entering into discussions to assess and refine the proposed provisions.

Assuming a smooth legislative process, adoption of the final regulation could be achieved by 2026. However, given the technical complexity and cross-sectoral implications of the Act, some delay in political negotiations cannot be ruled out. If adopted, the EU Space Act is scheduled to apply from 1 January 2030 onwards.

What to do now?

The EU Space Act marks a pivotal moment in the regulation of commercial space activities across Europe. For businesses active in satellite operations, launch services, space infrastructure, or telecommunications, this emerging legal framework will demand not only compliance but strategic foresight. Now is the time for stakeholders to map their exposure to the European space market, assess operational and contractual implications, and begin developing robust compliance strategies. Staying abreast of legislative developments and engaging proactively in consultations will be essential to ensure that voices are heard as the rules take shape. In particular, care should be taken to avoid regulatory asymmetries that could lead to avoidable competitive disadvantages for EU-based operators.

Additionally, companies should review their internal risk management frameworks, including insurance coverage and liability structures, to align with the upcoming harmonized standards under EU law. By acting early, businesses can mitigate disruption, ensure readiness, and even gain a first-mover advantage in a more regulated — but also more predictable — European space environment.

Contact Information
Anahita Thoms LL.M.
Partner
Berlin
Read my Bio
anahita.thoms@bakermckenzie.com
Dr. Andreas Neumann LL.M.
Associate
Frankfurt
Read my Bio
andreas.neumann@bakermckenzie.com

Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.

Delete Comment ?

Are you sure want to delete comment ?

Get link
Embed
Share by email
Get QR Code

Scan this QR Code to share this content

  •  
  •  
  •  
HighQ
Copyright Baker McKenzie 2025 | Disclaimers | Supplemental Privacy Statement