FCC 5-Year Deorbit Rule: What Satellite Operators Need to Know

In September 2022, the FCC shortened the maximum post-mission orbital lifetime for satellites in low Earth orbit from 25 years to 5 years. This single regulatory change affects every satellite operator who launches through the United States, uses US-licensed frequencies, or wants to serve the US market.

If you operate satellites — or plan to — this rule changes how you design missions, choose orbits, and plan end-of-life disposal. Here's everything you need to know.

What the Rule Actually Says

On September 29, 2022, the FCC adopted a Report and Order (FCC 22-74) that revised Section 25.114 of its rules. The key requirement:

The 5-year rule is not a guideline. It's a binding regulatory requirement for FCC-licensed operators and any operator seeking US market access.

What "Post-Mission Disposal" Means

Post-mission disposal means removing your satellite from orbit after it has completed its operational mission. There are three ways to comply:

1. Controlled deorbit: Use onboard propulsion to lower your perigee into the atmosphere. The satellite burns up on reentry. This is the gold standard.
2. Uncontrolled atmospheric decay: If your satellite is in a low enough orbit, atmospheric drag will naturally deorbit it within 5 years. No propulsion needed — but your orbit must be low enough.
3. Boost to graveyard orbit: For GEO satellites, boosting 300+ km above the geostationary belt. This doesn't apply to most LEO operators.

For LEO satellites, the practical question is: will your satellite naturally decay within 5 years, or do you need propulsion?

The Altitude Threshold: Where Natural Decay Works

Atmospheric drag decreases exponentially with altitude. Below a certain altitude, a satellite will naturally deorbit within 5 years without any propulsion. Above it, you need active disposal.

The exact threshold depends on your satellite's ballistic coefficient (mass, cross-section, drag coefficient) and solar activity (which heats and expands the upper atmosphere). But rough guidelines:

The critical zone is 500-600 km. This is where many CubeSat and small satellite missions operate, and where the 5-year rule creates the most design pressure. At 500 km during solar maximum, natural decay might take 2-3 years. During solar minimum, the same orbit could take 10-15 years.

If your orbit is above ~550 km, assume you need active deorbit capability. Don't gamble on solar activity predictions.

Timeline: When Does This Apply?

The rule's applicability depends on when you file your FCC application:

• Applications filed before September 29, 2024: The previous 25-year guideline applies. You're grandfathered — but the FCC expects "best efforts" toward 5-year compliance even for legacy missions.
• Applications filed after September 29, 2024: The 5-year post-mission disposal rule is mandatory. Your application must include a disposal plan demonstrating compliance.
• Already in orbit: Existing satellites are not retroactively required to comply. But any license renewal or modification may trigger review under the new rule.

If you're planning a launch in 2026 or beyond, the 5-year rule applies to you. Full stop.

Who's Affected?

The rule applies to three categories of operators:

1. US-Licensed Operators

Any satellite licensed by the FCC. This includes most US-based commercial operators, university programs launching through US providers, and government-funded research missions.

2. Non-US Operators Seeking US Market Access

If you're a European, Asian, or other non-US operator who wants to downlink data to US ground stations, sell services to US customers, or operate on frequencies coordinated through the FCC, you must comply with the 5-year rule as a condition of US market access.

This is significant. The US is the largest commercial space market. Many international operators need US market access to close their business case.

3. Satellites Launched from US Territory

Any satellite launched from a US-licensed launch site (Cape Canaveral, Vandenberg, Wallops, etc.) or on a US-licensed launch vehicle falls under FCC jurisdiction for orbital debris purposes.

What You Need in Your FCC Application

Under the revised rules, your FCC application (Part 25 or experimental license) must include:

1. Orbital parameters: Initial orbit, any planned orbit changes, and end-of-life orbit
2. Mission duration: Expected operational lifetime
3. Post-mission disposal plan: How the satellite will be removed from orbit within 5 years of mission end
4. Disposal reliability assessment: Probability that disposal will succeed (the FCC wants to see >90% reliability)
5. Casualty risk assessment: For controlled deorbits, probability of human casualty from surviving debris must be <1:10,000
6. Collision avoidance capabilities: How you'll monitor and avoid conjunctions during the mission
7. Trackability: Ability for Space Surveillance Network to track your satellite

Item 6 is worth emphasizing. The FCC now expects operators to demonstrate collision avoidance capability as part of their licensing application. You need to show how you'll monitor conjunction risks and respond to close approaches throughout your mission.

The DISH Network Precedent: $150,000 Fine

In October 2023, the FCC fined DISH Network $150,000 for failing to properly deorbit the EchoStar-7 satellite. This was the first-ever FCC enforcement action for orbital debris violations.

DISH had committed to boosting EchoStar-7 to a disposal orbit 300 km above GEO. Instead, they left it only 122 km above — less than half the required distance. The FCC found this violated their license conditions.

While $150,000 might seem small for a company like DISH, this precedent matters enormously:

• It proved the FCC will enforce orbital debris rules
• It established that disposal commitments in license applications are legally binding
• Future fines are expected to be significantly larger as the regulatory framework matures
• For a small satellite operator, a $150,000 fine could be existential

Compliance Strategies by Orbit Type

Below 500 km: The Easy Case

If your mission operates below 500 km, you're likely compliant through natural atmospheric decay alone. Your application should include orbital lifetime calculations showing decay within 5 years under conservative atmospheric assumptions (solar minimum conditions).

Use tools like NASA's DAS (Debris Assessment Software) or ESA's DRAMA to model orbital lifetime. Document your assumptions about ballistic coefficient and solar activity.

500-600 km: The Gray Zone

This is where most compliance challenges arise. Options:

• Launch lower: Target 450-500 km instead. You lose some mission lifetime to drag, but you gain compliance without propulsion.
• Add propulsion: Electric propulsion systems for CubeSats now start under $50,000 (e.g., Enpulsion, Phase Four, Accion Systems).
• Drag sail: Deployable drag augmentation devices (e.g., Vestigo Aerospace's Dragsail, Purdue's Spinnaker) increase your cross-sectional area to accelerate natural decay. Lower cost than propulsion.
• Design for drag: Orient your satellite to maximize cross-section during end-of-life. Works for larger platforms but not CubeSats.

600+ km: Propulsion Required

Above 600 km, there's no getting around it — you need active deorbit capability. This means onboard propulsion (chemical or electric) with enough delta-v to lower your perigee below ~200 km, where atmospheric drag completes the job.

The delta-v requirement depends on your starting altitude:

Conjunction Screening: The Overlooked Compliance Requirement

Most operators focus on the deorbit plan when thinking about FCC compliance. But the FCC's revised rules also require demonstrating collision avoidance capability throughout your mission.

This means you need:

• Regular conjunction screening: Checking your satellites against the full space catalog for potential close approaches
• Alert processing: Receiving and acting on Conjunction Data Messages (CDMs) from the 18th Space Defense Squadron
• Maneuver capability: If you have propulsion, the ability to execute collision avoidance maneuvers
• Documentation: Logging conjunction events and your responses for regulatory review

For small operators and university programs, this is often the hardest part. You may have a deorbit plan, but do you have daily conjunction monitoring?

The 18th Space Defense Squadron provides conjunction warnings, but they come via email, can be delayed by hours, and require manual interpretation. For operators managing multiple satellites, this doesn't scale.

International Context: How the FCC Compares

The FCC isn't acting in isolation. Regulatory pressure on orbital debris is increasing globally:

• ESA: The European Space Agency has adopted a Zero Debris Charter with a target of zero debris creation by 2030. ESA member states are developing binding national regulations aligned with this goal.
• UK Space Agency: Requires deorbit plans as part of their orbital license process. Has been aggressive about sustainability requirements for OneWeb and other UK-licensed constellations.
• France (CNES): The French Space Operations Act requires 25-year post-mission disposal but is under review for potential tightening to match the FCC's 5-year standard.
• Japan (JAXA): Has published debris mitigation guidelines and is working on binding regulations.
• UN COPUOS: The UN Committee on the Peaceful Uses of Outer Space has endorsed debris mitigation guidelines but lacks enforcement authority. National regulators like the FCC are where enforcement actually happens.

The trend is clear: every major space-faring nation is tightening orbital debris requirements. The FCC's 5-year rule is the most aggressive timeline currently in force, but others will follow.

Cost Implications for Small Satellite Programs

The 5-year rule adds cost to missions, particularly for satellites operating above 500 km. Here's a realistic breakdown:

CubeSat Missions (1U-6U)

• Drag sail device: $15,000-40,000 (COTS options available)
• Electric propulsion: $40,000-100,000 (includes integration)
• Conjunction monitoring: $200-2,000/month depending on service level
• Regulatory filing support: $5,000-15,000 (consultant/lawyer fees for FCC application)
• Orbit lifetime analysis: $2,000-5,000 (or free with NASA DAS)

For a university CubeSat program with a $200,000-500,000 total budget, compliance costs represent 10-25% of the mission cost. That's significant, but the alternative — launching without compliance — risks fines and reputational damage that could jeopardize the entire program.

Small Constellation Operators (3-50 satellites)

• Per-satellite propulsion cost: Generally included in bus design for modern small satellites
• Constellation-wide conjunction monitoring: Free (open-source self-hosted) to thousands per month for commercial services
• Legal/regulatory: $20,000-100,000 for comprehensive FCC filing with deorbit plan

For constellation operators, the per-satellite marginal cost is lower because propulsion and monitoring systems amortize across the fleet. The bigger cost is the upfront regulatory work.

A Practical Compliance Checklist

Whether you're a university team or a commercial operator, here's what you need to do:

1. Determine your orbit altitude and expected decay time. Use NASA DAS or ESA DRAMA. If decay time exceeds 5 years under conservative assumptions, you need active disposal.
2. Select a disposal method. Drag sail, electric propulsion, or chemical propulsion depending on your altitude and budget.
3. Model disposal reliability. The FCC expects >90% probability of successful disposal. This means your propulsion must be reliable and you need contingency plans.
4. Assess casualty risk. If any components survive reentry, calculate the probability of human casualty. Must be <1:10,000.
5. Establish conjunction screening. Set up daily monitoring of your satellite's orbit against the full catalog. Document your screening process and response procedures.
6. Document everything. Your FCC application needs all of this in writing. Keep records of conjunction events, maneuvers, and disposal planning throughout the mission.
7. File early. FCC review times can be 3-12 months. Don't wait until launch is imminent.

What Happens Next

The regulatory landscape is evolving rapidly. Several developments to watch:

• FCC enforcement escalation: After the DISH precedent, expect more enforcement actions with larger fines. The FCC is building a track record.
• Insurance requirements: Some insurers are starting to require compliance documentation before issuing launch liability policies. Non-compliance could make you uninsurable.
• International harmonization: If ESA and other agencies adopt 5-year rules, the standard becomes universal. Plan for this.
• Active debris removal: Companies like Astroscale and ClearSpace are developing removal services. In the future, operators might pay for removal rather than carry their own propulsion — but the regulatory requirement won't change.
• Stricter collision avoidance requirements: The FCC may eventually require specific conjunction screening thresholds or mandate participation in space traffic coordination services.

The direction is unmistakable: space sustainability requirements will only get stricter. Building compliance into your mission design now saves money, risk, and regulatory headaches later.