Initial Observations on the Draft EU Space Act

Today’s proposed EU Space Act marks a watershed moment in global space governance. While it targets EU internal harmonization, its scope reaches beyond European borders, and U.S. space companies should be paying attention.

Why?

Because the draft regulation requires compliance from "third-country" (non-EU) space operators that provide space-based data or services within the EU. That includes U.S. satellite, launch, and data service companies with ground stations, customers, or operations touching Europe.

🔍 Key Provisions Likely to Affect U.S. Operators:

• Mandatory compliance with EU debris mitigation and end-of-life planning for spacecraft operating in or downlinking to the EU.

• Environmental footprint declarations (Life Cycle Assessment-based) for space missions — including supplier data and third-party verification.

• Cybersecurity and resilience requirements across the mission lifecycle — tailored beyond NIS2 standards.

• Registration and “e-certificate” requirements for space services and data before accessing the EU market.

• Design mandates for in-space services and operations (ISOS) compatibility.

• Obligatory subscription to collision avoidance services and defined orbital traffic “right of way” rules.

💡 What This Signals:

Europe is not just regulating for internal regulatory consistency. It is positioning itself as a global standard setter. U.S. space companies with EU ambitions (or even a single EU customer or ground station) should consider integrating engineering decisions that address known areas of concern under the EU Space Act, such as cybersecurity standards, collision avoidance, environmental impact, and end-of-life management, into their architectures at the earliest feasible stage.

⚖️ The Upshot: The future is one of converging international standards. Companies that anticipate and align early across areas of expected international consensus will lead. Those that wait will scramble to retrofit. But don't panic: the draft EU Space Act does not apply to spacecraft launched before January 1, 2030.