Operating an orbital object in the UK: what operators need to know

Orbital Object Licensing

If you are planning to:

• Procure the launch of a space object into orbit
• Operate a space object in orbit, or
• Conduct other activity in outer space

you will require an orbital operator licence.

This licence covers activities carried out in outer space and, notwithstanding the ‘orbital’ terminology, is not confined to Earth orbit and may extend to cislunar and other beyond Earth orbit operations.

The regime is primarily underpinned by the Space Industry Act 2018 and the Outer Space Act 1986. Together, these establish the legal basis for authorising and supervising orbital activities.

At the centre of the framework is the requirement to obtain an orbital operator licence, issued by the Civil Aviation Authority (CAA), the UK’s spaceflight regulator. 

Licensing regimes and process

The applicable licensing regime depends on where the activity is undertaken:

• Activities conducted from within the UK fall under the Space Industry Act 2018
• Activities conducted outside the UK by UK entities fall under the Outer Space Act 1986

In practice, this distinction is critical for structuring missions, particularly where procurement of launch and operation occur across multiple jurisdictions. Some operators may need to apply for licences under both the Space Industry Act 2018 and the Outer Space Act 1986, for example where a satellite is launched from overseas but operated from the UK.

Processing times for orbital operator licences vary, as mission complexity and the completeness of information provided can significantly affect assessment duration. There is a fee for applications for orbital operator licences which is non‑refundable even if your application is refused. The fee is currently £6,500.

The CAA’s CAP 2210 Guidance for Orbital Operator Licence Applicants and Licensees sets out the requirements for an application, including the pre‑application process and the ‘Traffic Light System’. The Traffic Light System provides an early (but non-binding) indication of whether proposed activities appear to post an acceptable level of risk to safety, security, and sustainability.

Applications will need to include details of the applicant’s legal status, financial and technical resources, proposed space activities, radio‑frequency use, evidence of insurance, and national security considerations. CAP 2210 also sets out security requirements which may include cyber‑security measures depending on the nature of the mission. In exceptional circumstances a safety case may also be required.

Liability and insurance

The UK adopts a risk‑based approach to liability and insurance for orbital operations. Licence holders are required to meet insurance standards and indemnify the Government in respect of damage caused by their space objects, reflecting the UK’s international liability commitments.

Following the entry into force of the Space Industry (Indemnities) Act 2025, all operator licences issued under the Space Industry Act 2018 must include a statutory limit on the operator’s liability to indemnify the Government. The limit on the operator’s liability to indemnify the Government for licences issued under the Outer Space Act 1986 continues to be set through licence conditions, rather than statute.

Given the potentially significant financial exposure involved, early consideration of insurance arrangements and contractual risk allocation remains critical for operators, investors and insurers alike, particularly where activities span both domestic and overseas regulatory frameworks.

Spectrum licensing and Ofcom requirements

In addition to obtaining an orbital operator licence, satellite operators also have to secure appropriate spectrum authorisations.

This involves engaging with Ofcom to coordinate radio frequencies domestically and, where relevant, through international processes, and to obtain any required licences for satellite communications. Operators intending to deploy ground infrastructure in the UK must also consider licensing requirements for Earth stations, which are regulated separately from orbital licences.

Spectrum access is a critical dependency for satellite operations, and early coordination is advisable to avoid delays.

Safety, technical and national security considerations

The licensing process includes detailed technical and regulatory scrutiny. Applicants are required to submit a range of information to the CAA, including:

• technical and radio frequency assessments
• financial information
• national security disclosures 

Operators must also comply with broader health and safety legislation, with oversight from relevant authorities such as the Health and Safety Executive. Depending on the nature of the activities, it may also be necessary to consider whether separate marine licensing requirements apply.

These requirements reflect the UK’s focus on ensuring that space activities are conducted safely and responsibly, with appropriate safeguards in place.

Ongoing Duties

Obligations do not end once a licence is granted. Operators must continue to comply with licence conditions, including maintaining insurance cover at the required level and providing further information to the regulator as it becomes available. Record‑keeping and incident reporting obligations apply throughout the life of the licence, including reporting collisions or events that may generate space debris. Regulatory monitoring continues across the lifespan of the licence, and the regulator may inspect the licence holder.

Conclusion

Obtaining an orbital operator licence is mandatory for procuring the launch of, and operating, a space object. The UK regulator’s approach is multi‑layered, and early engagement and assessment can help ensure missions are designed so that risks are reduced to as low as reasonably practicable, giving the best chance of a successful licence application and, ultimately, a successful mission. As the UK space sector continues to evolve, operators should ensure that regulatory compliance is embedded into mission planning from the outset.

We would also like to acknowledge Jagpal Singh’s contribution and collaboration as a co-author.