Status
Regulatory developments are in progress
Name of national regulator
Office of Communications (Ofcom)
What frameworks are currently in place to regulate:
a. D2D in MSS bands
D2D services in MSS bands can be provided in the UK under the existing licence exemptions for mobile-satellite services, provided that the mobile handsets being used to provide the service comply with existing licence exemption conditions for satellite terminals when operating in these frequencies.
The licence exemption and relevant technical requirements are set out in the UK Interface Requirements under the Wireless Telegraphy Act 2006 (see IR 2016 here).
If the equipment does not fall within the minimum technical requirements (or a different exception), then it cannot be installed or used in the UK without a licence. To date, we understand that all current D2D services in MSS bands have fallen within the scope of the exemption, so no separate licence product is available but this is an area that Ofcom is exploring given the growing service offerings (see further on this below).
b.D2D in mobile bands
Ofcom has adopted a new framework for D2D in mobile bands. The new framework was announced in December 2025, following various consultations (see below for further detail).
The prior regulatory framework did not facilitate D2D services in mobile bands because the licences held by MNOs to provide communications services to consumers do not authorise transmissions from space, and the current licence exemptions for mobile handsets (discussed above) do not cover communications directly with satellites in mobile spectrum bands. Therefore, regulatory reform was required for these services to be provided in the UK.
Under the new framework, MNOs can submit variation requests to their wireless telegraphy licences to enable D2D services. The final exemption regulations will be made once the first variation request is approved and will enter into force three weeks later. D2D operation is permitted (with the relevant authorisation) in all Frequency Division Duplex (FDD) and Supplementary Downlink (SDL) mobile spectrum bands below 3 GHz, including 700 MHz, 800 MHz, 900 MHz, 1400 MHz, 1800 MHz, 2.1 GHz, and 2.6 GHz.
Ofcom has indicated it will review the authorisation framework following the World Radiocommunication Conference in 2027, which may result in further refinements to the regulatory approach.
What regulatory or related developments are currently underway?
The authorisation framework for D2D in mobile bands is now in place and MNOs can seek licence variations, as outlined above.
Separately, developments relating to D2D in MSS bands are ongoing and Ofcom has not yet consulted on detailed proposals for D2D services in MSS bands. A separate consultation on those topics is expected to be released in the course of FY 2025/2026, noting Ofcom has indicated that it may consider implementing a new authorisation regime to cover these services or adapting an existing authorisation regime (e.g. the Earth Station Network (ESN) licence regime) accordingly.
Ofcom has undertaken a series of consultations on various aspects of D2D authorisation, we summarise the key developments as follows:
- July 2024: Ofcom Call for Input on Improving Mobile Connectivity from the Sky and Space (available here) - Ofcom sought inputs to inform future regulatory reforms for D2D services and MSS. The call for input closed in September 2024, a range of responses were received and published here and Ofcom published a Summary of Responses in November 2024. Ofcom also sought views on the role that might play in delivering D2D-type mobile services but received limited responses on this topic and is not proposing to develop proposals to authorise D2D-type solutions using HAPS, unless future demand increases in this area.
- March 2025: Ofcom Consultation on Enabling Satellite Services in Mobile Spectrum Bands (available here) - Ofcom outlined three potential approaches to authorisation of D2D services in mobile bands:
- a licence exemption;
- a variation to the MNO’s existing base station licence accompanied by a licence exemption – Ofcom stated that this is its preferred approach; or
- a new licensing regime.
Ofcom stated that it aims to be able to accept requests to offer these services by end 2025. This consultation closed in May 2025 and Ofcom subsequently published a Statement and Further Consultation in September 2025 (see below), which built on the March proposals and included draft exemption regulations.
- July 2025: Ofcom Call for Input on Future Use of the 2GHz MSS band (available here) - In recognition of the upcoming expiry of the existing harmonised licences across the EU and UK in the 2GHz band (see below and the EU profile for further details), Ofcom sought inputs to inform its future proposals for the use of these frequencies after the current licence periods expire. The call for input closed in September 2025, a range of responses were received and published here and Ofcom is expected to consult on proposals in 2026.
- September 2025: Ofcom Statement and Further Consultation on D2D in Mobile Bands (available here) - Ofcom reiterated its intention to begin accepting service requests in early 2026 and consulted on a proposed exemption to permit mobile handsets and other SIM-enabled devices to connect to D2D services, including draft Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) Regulations 2025. This consultation closed in October 2025 and a final decision was published in December 2025 (see below).
- November 2025: UK Government Consultation on Revocation of 2 GHz R2Mobile Satellite Services Regulations (available here) - The UK Government opened a consultation on a proposal to revoke The Authorisation of Frequency Use for the Provision of Mobile Satellite Services (European Union) Regulations 2010, which authorises two MSS operators to use spectrum in the 2 GHz band, aligning with the current EU position (which is also under reconsideration – see the EU profile for further detail). The revocation would allow Ofcom to reassess the future use of the band (consistent with the Call for Input in July 2025) following the expiry of existing licences in 2027. This consultation closed in December 2025 and a summary of responses and the decision is expected in early 2026.
- December 2025: Ofcom Statement on Enabling Satellite D2D Services in Mobile Spectrum Bands (available here) - Ofcom published a statement following its Consultation in September 2025 and announced its final decision to implement a new authorisation framework for D2D services in mobile spectrum bands (see details of new framework above). Ofcom has published a sample licence variation schedule and a draft of the final exemption regulations to support implementation.