Governance of large-scale LEO satellite constellations: challenges, comparative analysis, and policy recommendations

Large-scale low Earth orbit (LEO) satellite constellations are deploying satellites at a scale not previously attempted, with projections of tens of thousands active by 2030. These mega-constellations introduce tightly coupled governance challenges—orbital congestion, spectrum allocation conflicts, and heightened space-debris risk. This paper compares how the United States, the European Union, and China govern these externalities, and finds divergent strategies. The United States relies on market-driven deployment under sectoral licensing, the EU is advancing binding sustainability norms through a proposed Space Act that has not yet been enacted, and China pursues state-led programmes with centralised oversight; yet each faces limitations, and no binding international regime exists for space traffic management, debris mitigation, or aggregate spectrum-load control. The paper argues that multilaterally agreed interoperability and sustainability standards can most reliably become enforceable when embedded in domestic licensing and market-access regimes that condition operator authorisation on verified compliance—a mechanism this paper terms licensing-linked compliance. The cross-jurisdictional transmission belt is market access. Because a constellation must secure landing rights and spectrum authorisation in dozens of states to deliver global service, each market-access state can condition entry on compliance with agreed standards, creating a distributed enforcement network without a single supranational authority. Two institutional prerequisites determine whether this mechanism scales beyond individual jurisdictions: convergence of national compliance baselines and interoperable technical standards. Without these conditions, licensing-linked compliance operates domestically but does not achieve cross-border accountability.