How long does a geostationary satellite licensee have to launch?

Five years from the grant of the licence, under 47 CFR 25.164(a), unless the rules or the Commission set a different schedule. In that time the satellite must be launched, positioned at its assigned orbital location and operating as authorised.

What are the milestones for a non-geostationary constellation?

Half of the maximum number of satellites authorised for service must be launched, in their assigned orbits and operating within six years of the grant, and the rest within nine years, under 47 CFR 25.164(b).

Does the FCC tell a licensee when a milestone has passed?

No. The licensee must report within 15 days after the deadline, either certifying that the milestone was met or telling the Commission in writing that it was not (47 CFR 25.164(f)).

Can an FCC Order set a different deadline from the rule?

Yes. Section 25.164 applies 'unless a different schedule is established' by the rules or the Commission, so the Order granting a licence can state its own dates. Where it does, Orbital Docket shows both the rule's date and the Order's.

FCC satellite milestones, in plain English (47 CFR 25.164)

What an FCC milestone is, how the five-, six- and nine-year deadlines work for satellite licences, and what the rules say happens when one is missed.

Published 2 October 2026 · Figures as of 2 October 2026, from the public record

What a milestone is

A satellite licence from the Federal Communications Commission (FCC) is not open-ended permission to use spectrum. It comes with milestones: dates by which the licensee must have actually built, launched and started operating what it was licensed for. The rule is 47 CFR 25.164, and it exists so that spectrum and orbital positions are not held by licences nobody is using.

The clock starts at the grant of the licence, not at the application and not at launch.

Geostationary satellites: five years

Under section 25.164(a), the holder of an initial licence for a geostationary (GSO) space station must, within five years of the grant:

launch the satellite;
position it at its assigned orbital location; and
operate it in accordance with the authorisation.

This applies to licences granted on or after 27 August 2003, other than for satellite digital audio radio service (SDARS).

Non-geostationary constellations: six and nine years

For a non-geostationary (NGSO) system, such as a low-Earth-orbit constellation, section 25.164(b) sets two milestones:

Milestone	Deadline after grant	What must be done
Half the constellation	Six years	Launch 50 percent of the maximum number of space stations authorised for service, place them in their assigned orbits and operate them
The rest	Nine years	Launch the remaining space stations needed to complete the authorised constellation, place them in orbit and operate each one

The six-year milestone does not apply to replacement satellites as defined in section 25.165(e). A system that mixes GSO and NGSO satellites must meet the GSO rule for its geostationary satellites and the NGSO rules for the rest (section 25.164(g)).

Two details that change the date

"Unless a different schedule is established." Both milestone paragraphs say this. The Order that grants a licence can set its own dates, and sometimes does. When an Order's stated deadline differs from the one the rule produces, the difference is itself worth knowing, and Orbital Docket shows both dates rather than choosing one silently.

Staged grants. Where the Commission grants a system in stages, for example a licence for a system using feeder links or inter-satellite links, "the earliest of the milestone schedules will be applied to the entire satellite system" (section 25.164(h)).

Who reports, and when

The licensee does. Within 15 days after a milestone deadline, it must either show that it met the milestone or tell the Commission in writing that it did not (section 25.164(f)). It shows compliance by certifying that the satellites have been launched, placed in their authorised orbit or location, and tested in orbit as consistent with the authorisation.

So a milestone date passing is not, by itself, a record of what happened. The licensee's certification, or its notice, is.

What happens when a milestone is missed

The consequences are in 47 CFR 25.161, which lists what automatically terminates a station authorisation:

Nothing working in orbit. If a milestone in 25.164(a) or (b) is missed and no authorised space station is functional in orbit, the authorisation terminates (25.161(a)(1)).
A constellation partly built. If an NGSO milestone is missed but at least one authorised space station is functional in an authorised orbit, authority terminates for the space stations not in orbit as of the milestone date, while technically identical replacements are allowed (25.161(a)(2)).
After nine years. An NGSO licensee must go on keeping at least half of its maximum authorised constellation functional in authorised orbits, or authority for the missing satellites terminates (25.161(d)).

Most licensees have also posted a surety bond that pays out if they surrender the licence before meeting a milestone or fail to meet one (see 47 CFR 25.165). The bond is how the rule gives a missed deadline a price.

Why these dates are hard to track

None of these deadlines is published as a list. Each one has to be worked out from the grant date of a specific licence, its orbit type, its number of authorised satellites and whatever the granting Order says, across thousands of filings in the FCC's International Communications Filing System (ICFS).

That is the work Orbital Docket does every morning. As of 2 October 2026, it tracks 8 FCC milestones and 21 surety bond deadlines falling due in the next 12 months, each traced to the rule version and the document it came from.

This guide summarises the rule text linked above. It is regulatory research that shows its working, not legal advice. Check anything you intend to rely on against the primary text.