On 25 June 2025 the European Commission published its proposal for the EU Space Act, the first bloc-wide regulation designed to harmonize the patchwork of national space laws into a single framework
. The Act is built around three pillars—safety, resilience, and sustainability—and covers everything from debris mitigation and cybersecurity to orbit-traffic management and an EU-wide space label.
Its most contentious feature, however, is the creation of a new regulatory category: the “giga-constellation,” defined as any satellite system with more than 1,000 operational satellites
. Systems of this size face additional compliance obligations that do not apply to smaller networks—obligations that analysts and U.S. officials argue are calibrated to capture operators that currently only exist in America.
In formal comments to the Commission, the United States government objected that the size-based rules “would currently affect only U.S. operators” . The International Center for Law and Economics went further, concluding that the Act functions as “a nontariff barrier under World Trade Organization principles” and that the giga-constellation threshold “is not derived from any established international safety standard or scientific assessment of orbital risk”
. Whether framed as a safety rule or a competitive barrier, the giga-constellation classification has become the central flashpoint in transatlantic space-policy relations.
Alongside the regulatory framework, the EU is building its own hardware. IRIS²—the Infrastructure for Resilience, Interconnectivity and Security by Satellite—is the EU’s third flagship space program after Galileo and Copernicus
. The constellation will consist of approximately 290 satellites in a multi-orbit configuration, blending low Earth orbit and medium Earth orbit to provide both low-latency performance and broad coverage
.
On 16 December 2024, the Commission signed a 12-year concession contract with the SpaceRISE consortium, led by European satellite operators SES, Eutelsat, and Hispasat
. The budget is €10.6 billion, with roughly €6.5 billion in public funding (including €550 million from ESA’s Partnership Projects) and more than €4 billion from private industry
.
IRIS² is not designed to be a direct retail broadband competitor to Starlink. Its primary mission is secure connectivity for European governments, defense agencies, and critical infrastructure
. “When we have IRIS², it will be better than Starlink," EU Defence Commissioner Andrius Kubilius has said, while acknowledging that Europe does not yet have that capability
. First government services are expected in 2030, with initial launches envisioned for 2029
.
The EU’s moves have not gone unanswered in Washington. In March 2026, FCC Chairman Brendan Carr opened a public notice questioning whether the Commission’s “longstanding presumption in favor of granting requests for U.S. market access” to foreign satellite operators remained justified
. The notice explicitly cited the EU Space Act as part of the rationale for reassessing reciprocity
.
SpaceX escalated the pressure in April 2026 with a letter to the FCC urging the agency to “retaliate in kind” against the EU’s regulatory approach and to restrict market access for European satellite operators whose home governments disadvantage U.S. firms
. The letter named Luxembourg-based SES as an example of a European operator that had benefited from American market access while the EU pursued rules that target American systems
.
European operators are pushing back. Eutelsat CEO Eva Berneke said demand for alternative satellite services from U.S. businesses and the Pentagon “is resilient” despite the regulatory friction, and that customer conversations are ongoing
. The FCC’s reciprocity proceeding remains open, and the signals from both sides suggest the dispute is still escalating rather than settling.
The EU Space Act is still making its way through the legislative process, with application dates set to phase in over several years . The proposed “giga-constellation” language remains in the draft, and the final text will be shaped by negotiations between the European Parliament, the Council, and the Commission. In parallel, IRIS² is moving from contract signature to early development phases, with the first launches expected later this decade.
What Europe is attempting is both straightforward and enormously ambitious: a sovereign, secure connectivity layer that no foreign company can switch off. The immediate consequence is a regulatory and industrial contest that stretches from orbit to the WTO—and one that will redefine how nations think about ownership of the infrastructure in the sky.
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