EU Space Act & The EU vision for the European Space Economy

The European Commission launched on 25 June 2025 the Proposal for a Regulation of the European Parliament and of the Council on the safety, resilience and sustainability of space activities in the Union (COM(2025) 225 final) (hereinafter ‘EU Space Act’ or ‘Proposal for Regulation’ or ‘Regulation’) which, if approved, is envisaged to apply generally from 01 January 2030.

This much anticipated document comes in a context[1] where the European Union (‘EU’ or ‘Union’) and the European Commission (‘Commission’ or ‘EC’) have identified space as a key strategic sector for the EU and, accordingly, a key priority for the EU and its bodies.

Therefore, the EU Space Act aims to address the perceived need for a uniform, effective and proportional mandatory framework at EU level to ensure proper functioning of the internal market for space in the short-term, considering space is a high growth market sector, encompassing space industry (manufacturing and services) and space services in numerous markets (e.g., climate and environment, agriculture, energy, transport, insurance and banking or security and defence).

Ensuring a coherent and stable regulatory framework for the provision of space-based data and space services by EU space operators is viewed as of essence to foster innovation and create a stable, predictable and competitive business environment. The Commission expects it to provide the legal certainty needed by EU space operators to ensure a level playing field for the industry in a sustainable way.

Accordingly, the EU Space Act is a key piece in the context of a broader, overarching Vision for the European Space Economy (presented together with the Proposed Regulation) to be implemented immediately, whose purpose is to position the EU as a global space economy.

Among others, and in addition to the measures advanced under this proposed Regulation, future initiatives under this Vision include:

• Accelerating research and innovation (R&I), in the context of the next EU R&I framework programme, reinforcing support to Space R&I with a view to strengthening the security and resilience of EU satellite and space infrastructure, systems and services, as well as, reinforcing the dedicated Space R&I Partnership to support the development, procurement and deployment of innovative space technologies across the space value chain.
• Ensuring industrial readiness and technological non-dependence, by ensuring a multi-source supply of critical space technologies, including support to R&I technology maturation, deployment of multi-sourcing value chains and necessary adaptations.
• Supporting Space Commercialisation, by accelerating and expanding access to finance notably through a (CASSINI) Seed Investment Facility, a Growth Investment Facility, and a Debt/ non-dilutive Financing Facilities, while adopting innovative and business friendly procurement methods to encourage more competition and enable the most cost effective and innovative products to scale up on the market.
• Promoting international cooperation and economic diplomacy, proposing capacity building measures to emerging space nations projecting the EU’s technical standards and advancing the interoperability of the EU’s systems globally.
• Fostering the existence of skilled workforce, by promoting cooperation between stakeholders with a view to develop space curricula, exchanges, partnerships and fellowships, and supporting the mobility of researchers for space in the EU.
• Supporting the development of sovereign, competitive, and independent satellite and launch capabilities that respond effectively to current and future market demands, including with a view to ensure access to space by, among others, maintaining, securing and expanding capacities of ground-based infrastructure (including test and launch facilities), while accelerating solutions such as reusability, as well as, supporting the modernization of the ground segments with the continuation of the transitioning to digital, cloud-enabled, and virtualized infrastructures, and the set-up of space data spaces and labs.
• Augmenting defence for space but equally space for defence capacities, notably by fostering public demand in dual-use services and relevant technologies, while strengthening the EU’s security-by-design policy in the development of its space systems and the ensuing provision of services, incorporating dual-use principles.
• Boasting services and simplification, with a view to increase the uptake of space services and data by public authorities and mainstreaming space solutions in various policies.

Harnessing the potential of the in-space economy, including of in-space operations and services, in-space infrastructures, and the mining and resources utilization.

Proposal would apply from 1 January 2030 and includes transitional norms.

Some of the EU Space Act’s key aspects include:

• Applicability of the EU Space Act to both EU and non-EU operators (third country operators and international organisations) providing space-based data and services in the EU (however, non-EU operators are subject only to rules on registration and supervision of their activities);
• Requirement that all EU space operators (which is broadly defined in the Proposed Regulation) obtain an authorization in a Member State prior to carrying out space activities (also broadly defined in the Proposed Resolution) in relation to non-EU-owned assets and Union-owned assets, with each Member State being required to designate or set up a National Competent Authority (‘NCA’ or ‘competent authority’) with supervisory, investigatory, corrective and sanctioning powers over EU Space operators carrying out space activities;
• Rules on the authorisation of EU space operators to carry out space activities;
• Establishment of the Union Register of Space Objects (‘URSO’) for the registration of EU space operators, third-country space operators, as well as for international organizations, where it is also published consolidated lists of all space services providers and all primary providers of space-based data in the EU. URSO shall have a centralised inventory and platform;
• Establishment of an electronic certificate (e-certificate) issued by the EU Agency for the Space Programme (‘EUSPA’ or ‘Agency’) to space service providers (other than collision avoidance space services providers), to ensure e-traceability of the provision of space-based and space services in the EU, which is a prerequisite for the provision of space services and space-based data in the UE for the first time;
• General principle of free movement for the provision of space-based data and space services within the EU registered in the URSO, with the ability of Member states to restrict such free movement for reasons related to safety, resilience and environmental sustainability being heavily limited;
• Rules regarding the provision of space-based data and services in the EU by and the registration of third country space operators and international organisations;
• The Commission and EUSPA are granted new tasks and given new roles and responsibilities to ensure compliance with the Regulation, in particular to have power of investigations, on-site inspections, supervisory powers as well as to impose fines and periodic penalty payments.

The EU Space Act also sets outs a set of technical requirements, with which the different categories of space service providers have to comply with. Those are arranged around the following three key pillars:

• Safety and Sustainability in Space – measures regarding safety and sustainability in space for EU launch operators and spacecraft operators, which must minimise collision risks and the generation of new debris, limit light and radio pollution, and ensure spacecraft are trackable and capable of collision avoidance, thereby enhancing the safety of space activities. Among others, space operators must ensure that suppliers’ manufacturers comply with the design and manufacturing requirements laid down in this regard;
• Resilience of Space Infrastructure - measures to ensure the resilience (both against digital and physical threats) of space infrastructure throughout all phases of design, development and operation of space infrastructures, through risk management, reporting of significant incidents and the establishment of the Union Space Resilience Network (‘EUSRN’) and voluntary information sharing and awareness, creating a regime that is tailored to the specific cybersecurity needs of space infrastructure, thereby enhancing the resilience of space activities;
• Environmental Sustainability of Space Activities - create a common method for calculating the environmental impact assessment of space activities in the EU, by requiring space operators to calculate the environmental footprint (EF) of the space missions, submit an environmental footprint declaration (EFD) verified through an EF certificate and by creating a central EU database that will collect and manage environmental data, thereby enhancing the transparency and sustainability of space activities. To that effect, space operators will be required to implement reporting mechanisms and procedures in their production chains, to ensure that aggregated and disaggregated datasets are available on an up-to-date manner to the EC.

In addition, other technical requirements are imposed contributing to those key pillars, notably:

• In-space operations and services (ISOS) requirements, pursuant to which spacecraft must be fitted with specific interfaces to allow for in-space servicing (design requirements for these interfaces shall be set out by the EC, which may also introduce additional debris removal requirements for objects considered to pose a threat).Such ISOS requirements are to be applied from 1 January 2034, i.e., 4 years after the general entry into force of the EU Space Act;
• Orbital traffic rules, notably rules on the execution of collision avoidance manoeuvres, including a ‘right of way approach’.

International cooperation is not forgotten, with the EU Space Act foreseeing:

• Regarding third countries, the Commission may grant equivalence decisions to ensure the recognition of a level of protection comparable to what is required under the Regulation and EUSPA and the EU may conclude cooperating agreements and international agreements with relevant competent authorities and the third countries themselves, respectively;
• Rules applicable to international organisations, depending on the type of asset, as well as specifically setting out that the EU shall endeavour to conclude an agreement with the European Space Agency to advance the objectives pursued by this Regulation. 

Supporting measures to promote the adherence to the Regulation are foreseen in the Proposal, namely (i) capacity-building measures to mitigate potential costs for the industry, which will in particular support start-ups and SMEs; and (ii) the establishment of a ‘Union Space Label framework’ for awarding a Union space label to space operators that voluntarily intend to meet higher requirements on safety, resilience and environmental sustainability, in addition to those laid down in the Regulation.

The Impact Assessment made by the Commission determined that despite yielding significant advantages which is expected to sustain the EU space industry (calculated at 20% of a projected 700 billion € market by 2031), the EU Space Act entails also several costs:

• For the public sector, (i) Member States with established space programs hosting most of the European space sector already assess many of the requirements being envisaged in the proposed EU Space Act and their rules would only require minor adjustements, resulting in minimal administrative burden, whilst (ii) Member States with no space legislation typically hosting emerging space activities would have limited adjustment costs for new requirements;
• For the private sector, costs vary depending on the company, (i) satellite operators may face an increase of up to 10% in manufacturing costs for satellite plartforms, depending on the space mission requirements, (ii) launch service providers will incur additional expenses, with large-sclae providers potentially paying up to 1.500.000 € for heavy launchers and SMEs up to 200.000 €, (iii) risk management costs for companies are estimated at 10% of their IT budgets and (iv) authorisation requirements per product line will cost approximately 100.000 €; (v) implementing the product environmental footprint category rules (PEFCRs) will cost 4.000-8.000 €.

It bears to be seen how the industry and national authorities with space related responsibilities will view the impacts of the proposed uniformization of rules set out under this Proposed Regulation, notably when:

• Space operations (activities and services) are to be conditioned by a registry with URSO and the obtaining of a prior e-certificate, which may be less competitive with other key international space markets;
• National authorities will have to review procedures, train personnel and adapt legislative procedures to ensure proper coordination (but still retaining final saying on the licensing of space objects and space services, which may continue to fuel cherry-picking of jurisdictions where to operate from by space providers;
• Compliance costs throughout the supply chain of the industry (which is still, at least for the majority of Member States, dominated by SME’s) may be extremely cumbersome on operators and fuel again a less competitive view of the EU space market;
• Centralization on EU bodies and organizations, while worthwhile for uniformization and standardization, may create additional costs or disproportionate (time and financial) costs whenever the relevant operators and providers are located in Member States outside those where key bodies are located and operate;

It is still to be seen how the URSO and the e-certificate can be used as effective tools to mitigate some of difficulties that hinder private and more traditional funding of space activities – e.g., how can the URSO and the e-certificate be assessed/used in the context of granting security over those assets to secure third-party funding and7or to enforce judgments that affect ownership of those assets.

The legislative proposal will be negotiated under the ordinary legislative procedure by the European Parliament and the Council.

The Commission will now proceed to implementing the actions set out in the Vision for the European space Economy, in close cooperation with the EU Member States, EUSPA, ESA, and other space partners, notably space industry.

The Commission will also establish a ‘Space Team Europe', a high-level forum bringing together all European space ecosystem stakeholders, to federate European space-related excellence and capacities in a coherent and efficient manner. In addition, as from 2025, the Commission will develop a dedicated methodology to monitor the EU's competitiveness in the space sector.

At the Member States, national agencies and the industry must also review carefully this proposal and put forward their comments so that this does not become a prime example of having legal instruments act as a deterrent for innovation and effectively impacting negatively the competitiveness of the EU space market and stakeholders.