Direct-to-device connectivity in the United States has moved from trial to commercial deployment, and the market is reorganising around it. Satellite networks are extending terrestrial coverage for messaging, voice, data and IoT; a wave of spectrum consolidation has reshaped who is positioned to deliver those services; and mobile operators in the US and elsewhere are testing new partnerships and business models to capture the opportunity. What was framed two years ago as a supplement to terrestrial coverage increasingly looks like a layer of the network in its own right. This session will assess what that shift means for regulation. Panellists will consider whether the supplemental coverage framing still fits the services now being launched, what recent spectrum transactions and operator partnerships mean for market structure and new entry, and which obligations should attach to D2D as it becomes more capable. It will then turn to the framework itself: whether D2D needs a settled regulatory home of its own rather than continuing to be accommodated within regimes designed for satellite and terrestrial services separately, how far licensing reform and legislative proposals can go towards providing it, and what degree of regulatory certainty the sector needs to justify investment at national scale.

 
• Is D2D still fundamentally supplemental coverage, or is it becoming a new layer of the mobile network?
• Does D2D now need a settled regulatory home of its own, rather than being accommodated within separate satellite and terrestrial frameworks? If so, what would this look like?
• What new business models, partnerships and spectrum transactions are emerging? As the ecosystem takes shape, how can competition be protected and room preserved for new entrants, smaller operators and new constellations?
• Operators have signalled a preference for working with multiple constellations. Is that achievable, or does one satellite operator end up owning the D2D layer?
• How far do current licensing reform efforts and the regulatory framework that is emerging for D2D go towards providing the regulatory certainty needed for D2D to scale nationally?
• As deployment accelerates, how can it be ensured that the regulatory framework evolves alongside the market rather than in response to it? Which further licensing reforms would do most to encourage innovation and investment while keeping the field open to new entrants?
• As D2D services become more capable, what regulatory obligations should follow, and how should 911, location accuracy and consumer protection requirements evolve alongside them?
• Which use cases are actually driving adoption beyond emergency messaging, and what does that tell us about where the market is heading?

The FCC’s SCS framework was a world first in opening the door to satellite use of terrestrial mobile spectrum, and the IMT and MSS deployment models that this forum compared a year ago are now both operating at commercial scale in the US market. The next phase will place considerably greater demands on spectrum. Operators are seeking additional capacity across both mobile and MSS bands; incumbents are defending existing allocations, backed by the FCC’s April decision on the Big LEO bands; and the FCC is weighing how much further satellite access should extend. This session will examine where policymakers should look next, and at what cost. Panellists will assess whether SCS remains fit for purpose, how much additional spectrum D2D can realistically justify and where it would come from, and whether the sector ultimately needs an allocation of its own rather than continuing to borrow. The session will also revisit a question this Forum first asked in 2025 and which remains unresolved – whether a dedicated D2D band is viable – and consider what position the US should take into WRC-27.

 
• How much additional spectrum will be required for the next phase of D2D as services move beyond messaging towards voice, data and higher-bandwidth applications? What options are being explored both in the US and elsewhere to deliver this, and which are likely to prove most viable?
• With operators seeking greater access to both mobile and MSS spectrum, how should regulators prioritise these competing demands for additional capacity? Is one becoming the prevailing route in the US market, or will both persist?
• The FCC recently declined to open the Big LEO bands to sharing, weighting incumbents’ investment-backed expectations of exclusive use. Was that the right balance, and if sharing into existing allocations is closed off, where does new capacity come from?
• Should further licensed mobile spectrum be made available for satellite use, and what would that mean for a terrestrial pipeline already under pressure?
• How far can spectrum sharing and coordination models be pushed to increase D2D capacity while protecting incumbent users – and where are the technical limits?
• As D2D services become more capable, does the SCS framework still fit the market it was written for? If it needs revisiting, what would that involve, and is there an argument to rethink the traditional boundaries between terrestrial and satellite spectrum altogether?
• What can the US learn from approaches to D2D spectrum emerging in other markets, and could the US SCS model provide a blueprint for a more globally harmonised framework?
• Is there potential for a dedicated D2D band, and what would the benefits and challenges be? Has the case strengthened or weakened in the 12 months since we last asked this question at last year’s forum?
• What lessons and priorities should the US take into WRC-27 and what would a successful ‘D2D’ outcome look like?
  doption beyond emergency messaging, and what does that tell us about where the market is heading?

In August 2026, the FCC opened a proceeding to explore whether devices operating under its Part 15 unlicensed rules (including Wi-Fi, Bluetooth and IoT equipment) could be used for direct communications with satellites, potentially opening more than 200 MHz across the 2.4 GHz and 5.8 GHz bands to D2D applications. The proposals could bring satellite connectivity into a much broader ecosystem of existing devices, potentially enabling new models and closer integration between satellite and the vast terrestrial unlicensed ecosystem. But extending a framework designed principally for terrestrial, short-range communications into the space environment raises fundamental questions around power levels, link budgets, interference, equipment authorisation and incumbent protection. This session will examine the FCC’s proposals and consider what a satellite-enabled unlicensed ecosystem could look like in practice. Panellists will assess the technical challenges it would present, whether unlicensed spectrum could become a meaningful new pillar of satellite connectivity alongside licensed models, and whether the US approach could provide a template for other markets.

 
• With the comment cycle expected to be closed before the date of the event, where does the FCC proceeding stand?
• Where is it likely consensus will emerge and what may be the main lines of disagreement?
• Given that no changes were proposed to existing Part 15 power, gain and emission limits, can unlicensed spectrum designed primarily for terrestrial use support reliable Earth-to-space links without disrupting the users already sharing these bands?
• What are the biggest technical barriers to this and to scaling unlicensed satellite connectivity? How can these be overcome?
• How significant could this be for D2D? Could unlicensed spectrum become a meaningful third pillar of satellite connectivity alongside mobile and MSS spectrum?
• What would a satellite-enabled Wi-Fi and IoT ecosystem look like in practice?
• The 902–928 MHz band was dropped before adoption because of the complexity of protecting incumbents. Was that the right call, or could there be a path for it to come back into scope?
• Who stands to benefit most from an unlicensed satellite ecosystem – satellite operators, mobile operators, device manufacturers, chipset makers or consumers? Could it fundamentally change the D2D value chain?