Does SpaceX need the ITU?
The satellite giant could be heading towards a clash with the UN’s telecommunications agency.
Space is getting busy. The European Space Agency (ESA) estimates there are now 16,910 satellites in space. Nearly 65% of these belong to SpaceX, which has been launching satellites at an unprecedented scale.
Last week, SpaceX announced Stargaze to cope with the growing risk of collisions. It’s a Space Situational Awareness (SSA) system that tracks satellites with a network of 30,000 star trackers. Instead of keeping the technology to itself, the company says it will make it available for free to the broader satellite community.
The announcement got me thinking about SpaceX’s relationship with the UN’s telecommunications body, the International Telecommunication Union (ITU). Stargaze seems like something that the ITU should be pioneering. After all, it already keeps track of satellites through its filing system, and is arguably the most authoritative body in the free-for-all that is space. Why not go further and establish a system to prevent collisions?
This isn’t the first time that SpaceX has sped past the ITU, and I suspect it won’t be the last. It’s no secret that SpaceX has fundamentally changed the satellite industry with its LEO megaconstellation. So far, the ITU has done a pretty good job in adapting to this new reality of space. Sure, the body can be slow to act, but this is expected given its consensus-based system. I’d argue it’s by far one of the most effective bodies of the UN.
In 2019, the ITU introduced a new milestone-based “bring into use” approach in response to the rise of large mega-constellations, requiring operators to deploy 10% of their constellation within two years, and 50% within five years. This change was a direct reaction to the rapid increase in filings, in large part from SpaceX, which threatened to overwhelm the existing regulatory process.
However, SpaceX is not getting everything they want out of the ITU. Particularly when it comes to power limit discussions. What appears to be a highly technical discussion about so-called Equivalent Power Flux Density (EPFD) limits can be simplified as follows: The new market players, including SpaceX and Amazon want to change these limits, which they feel are overly restrictive, while the “incumbent” satellite operators generally want to keep things as they are, arguing that any changes could cause interference to their systems.
My understanding of the discussions is that they have been heated and that they are at a stalemate, with the incumbent operators refusing to accept any changes. It’s entirely in their right, of course, to defend technical conditions that they feel protect them.
But if SpaceX feels the technical justifications behind this are weak, I believe there is a risk that the company could decide to ignore the ITU’s regulations. It wouldn’t be the first time it had done so. SpaceX has been illegally operating its Starlink service in Iran for several years now. The ITU has repeatedly sided with Iran, labelling SpaceX’s action as a violation of international regulations.
To be clear, I believe SpaceX has a moral right to continue operating in Iran. Its service has been one of the only ways for citizens to bypass the internet shutdown and expose the brutal repression they have suffered in recent demonstrations.
Yet, I also believe that you can’t pick and choose which international rules to follow. At a time when the international order is less respected than ever, and the UN is increasingly ignored and sidelined, there is a risk that even the ITU’s authority could fall.
SpaceX has always preferred to play by its own rules. It often resolves issues by itself and acts before regulatory intervention becomes necessary. It has, for example, signed agreements with the National Science Foundation (NSF) to mitigate the impact of its Starlink satellites on radio astronomy, successfully pre-empting any regulation that could require them to do so. Now, with its Stargaze system, it has established its own method to prevent international collisions.
Are we heading towards a world where SpaceX becomes its own regulator? It would be deeply troubling if it decided to ignore the ITU’s rules. Doing so would undermine international cooperation, set dangerous precedents for other operators, and risk disrupting critical services worldwide. To avoid this outcome, ITU member states try to keep any discussions grounded in the technical reality and ensure a fair playing field for all.
I really enjoyed this piece. You raise a sharp and necessary question about whether SpaceX actually needs the ITU, and it is exactly the kind of framing that helps bring spectrum governance into wider policy discussions. So I apologise for the long comment, but it comes from the excitement your article provoked. From inside the spectrum and ITU-R world, the answer looks slightly different from the institutional lens through which the question is often asked. The ITU is frequently read as if it were a regulator able to sanction operators. In practice it is not. It has no direct enforcement power over companies and only a limited independent institutional voice. Its authority exists through its member states and through the coordination procedures they agree to follow. Compliance therefore operates horizontally between administrations rather than vertically from institution to operator. This makes the Starlink “unauthorised use” episode interesting but somewhat misleading if treated as evidence of institutional weakness. The ITU could not sanction SpaceX directly, but that reflects how the system is designed. What sustains it is reciprocity among administrations coordinating spectrum use. What your article touches on, but could perhaps foreground more, is the centrality of coordinated spectrum use for LEO constellations. These systems depend on continuous multi-jurisdictional coordination to function well. Their performance relies on other administrations recognising filings, engaging in coordination, and avoiding harmful interference. If a system is perceived as disregarding coordination norms, the consequences are unlikely to come through formal ITU penalties. They tend instead to appear through reduced willingness to coordinate, accommodate, or protect that system’s operations. That matters because the ITU’s influence is systemic rather than punitive. Each ITU-R study cycle involves hundreds of contributions from member states shaping sharing criteria, coordination procedures, and regulatory interpretations that directly affect non-GSO constellations. This technical and political work continues regardless of any formal institutional “position” on a particular operator and gradually defines the environment in which all constellations operate. It is also worth recalling that the ITU does not function like some other UN bodies with a strong independent voice. Its direction emerges from member state negotiation. Compliance incentives are therefore embedded in reciprocity. If coordination norms weaken, the resulting fragmentation can create a more interference-prone and less predictable operating environment for everyone, including the most capable systems. So the question you pose is exactly the right one. The answer may be less about whether SpaceX needs the ITU as an institution and more about whether any large constellation can operate smoothly outside the cooperative spectrum regime that the ITU framework makes possible.
I think it shouldn't be an issue. I have seen many technologies or solutions developed by a third party or company, then later engage the ITU to standardize it and make it available to all as per ITU procedures.