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The ITU Filing & Coordination Process

Securing satellite spectrum is not like purchasing physical land; you cannot buy a permanent deed to an orbital slot or a frequency band. Instead, acquiring spectrum is more like obtaining a conditional building permit.

To help understand the complex regulatory lifecycle of a satellite filing with the International Telecommunication Union (ITU), we can use the Skyscraper Analogy:

  • Advance Publication (API/A) or Coordination Request (CR/C) is like posting a public notice of your intent to build a skyscraper.
  • Bilateral Coordination & Negotiations are the formal discussions you have with neighbors whose sunlight or views might be blocked by your building (ensuring your satellite signal doesn't cause harmful electromagnetic interference to theirs).
  • Notification & MIFR Recording is getting the building permit officially registered in the city records once the neighbors agree.
  • Bringing Into Use (BIU) is the requirement to actually construct the building, turn on the lights, and move tenants in within 7 years, or the permit expires.
  • NGSO Milestones (Resolution 35) are phased construction milestones for a massive housing development, ensuring a developer doesn't "warehouse" land without actually building.

Coordinated vs. Non-Coordinated Tracks​

Satellite systems follow one of two regulatory tracks depending on their frequency bands, orbit types, and services. The ITU defines separate publication series and distinct coordination mandates for each:

1. The Non-Coordinated Track (API-Only)​

For simpler systems that do not require formal coordination under Article 9 of the ITU Radio Regulations (e.g., short-duration experimental CubeSats, certain earth-exploration satellites, or amateur radio payloads), the filing process is shorter:

  • API/A Special Section: The notifying administration submits the Advance Publication Information. The ITU publishes this to notify the world of the new system, starting the 7-year regulatory clock.
  • API/B Special Section: If other administrations identify potential interference, they submit comments within 4 months. The ITU publishes the compiled list of comments in an API/B special section.
  • Coordination Mandate: Under the non-coordinated track, operators are not required to complete formal bilateral coordination with other countries before submitting a Notification to record their frequency assignments in the Master Register (MIFR).

2. The Coordinated Track (CR/C)​

For standard commercial satellite networks (e.g., geostationary telecommunications satellites, large non-geostationary constellations like SpaceX's Starlink or OneWeb), the process is highly rigorous:

  • CR/C Special Section: The formal Coordination Request is submitted. This contains extremely detailed technical parameters (antenna patterns, power levels, orbital planes). Its publication triggers a mandatory 4-month comment window.
  • CR/D Special Section: After the comment window closes, the ITU Radiocommunication Bureau (BR) examines the submissions and publishes the CR/D section. This is the official list of coordination requirements, legally defining which administrations and satellite networks have coordination rights.
  • CR/E Special Section: If additional networks or administrations are subsequently added to the coordination requirements (often requested under provisions like No. 9.41 or 9.42), the BR publishes these confirmations in a CR/E section.
  • Coordination Mandate: Unlike the API track, operators in the coordinated track are required to successfully complete formal bilateral coordination with all affected administrations listed in the CR/D prior to submitting a Notification to record their assignments in the MIFR.
  • Workarounds: Because resolving coordination with dozens of countries can take years, operators often utilize regulatory workarounds to record their assignments when negotiations are still ongoing (such as submitting under provision No. 11.41, where a filing is recorded provisionally on a non-interference/non-protection basis relative to the outstanding coordinator). These coordination techniques and workarounds are discussed in detail in Chapter 5.
important

Under current Radio Regulations (introduced at WRC-15), for satellite networks subject to coordination, the API is automatically generated upon the ITU's receipt of the CR/C (under No. 9.1A). Operators do not need to file a separate, stand-alone API for coordinated networks.

The Commenting Process & Deadlines​

When an administration publishes an API/A or a CR/C in the bi-weekly BR IFIC (International Frequency Information Circular), the clock starts ticking for all other operators worldwide.

The 4-Month Rule​

Under Radio Regulations No. 9.3 (for APIs) and No. 9.52 (for CR/Cs), administrations have exactly four months from the publication date to submit comments or objections.

What Happens if You Forget to Comment?​

If an operator fails to comment within the 4-month window, the ITU applies the principle of deemed agreement. The silent administration is legally considered to have agreed that the new filing will not cause harmful interference to their existing or planned systems. If the new satellite is launched and causes interference, the silent operator has virtually no regulatory recourse.

Monitoring and Submitting Comments​

  • Commercial Monitoring Tools: Because hundreds of filings are published every month, operators use specialized commercial database tools (such as SpaceTrack or commercial software interfaces interacting with the ITU's SpaceQry database) to monitor the BR IFIC. These tools automatically flag new filings that overlap with the operator's orbital locations, frequency bands, and service areas.
  • The SpaceCom Workflow: Commercial operators cannot submit comments directly to the ITU. Instead, the operator drafts a technical response letter outlining the potential interference. The operator provides this draft to their national administration (e.g., the FCC in the US, Ofcom in the UK). The administration reviews the draft and formally uploads the objection via the ITU's SpaceCom software.
tip

Comment periods are the gatekeepers of spectrum priority. A robust regulatory strategy requires bi-weekly screening of the BR IFIC to protect active assets from being boxed in by new filings.

ITU Cost Recovery Fees​

Processing satellite filings requires significant administrative and technical work by the ITU Radiocommunication Bureau. Under Council Decision 482, the ITU operates a cost-recovery system where administrations are billed for each filing.

Fee Structure Table​

Filings are charged based on their complexity (measured in "units" of frequency ranges, classes of station, and emissions). The latest fee schedule (see ITU Circular Letter C-0125 for details) is structured as follows:

TypeCategoryFlat Fee (CHF)
(>= 100 units, if applicable)		Start Fee (CHF)
(< 100 units)		Fee Per Unit (CHF)
(< 100 units)		Cost-Recovery Unit Definition & Notes
1. Advance Publication (A)A15,70030054Product of the number of frequency ranges, classes of station, emissions, and multiplier footnote, summed for all frequency assignment groups. Includes No. 9.5 (API/B) processing.
2. Coordination (C)C1*20,5605,560150Product of frequency assignments, classes of station, emissions, and multiplier footnote, summed for all frequency assignment groups. Includes Nos. 9.1A, 9.53A (CR/D), and 9.41/9.42 processing.
C2*24,6209,620150
C3*33,46718,467150
3. Notification (N)N1*37,09219,092180Includes Resolutions 4 & 49, Nos. 11.32A, 11.41, 11.47, 11.49, Sub-section IID of Article 9, Article 13, and Article 14. First resubmission under No. 11.46 costs an additional CHF 18,540.
N2*69,50451,504180First resubmission under No. 11.46 costs an additional CHF 34,750.
N3*69,50451,504180First resubmission under No. 11.46 costs an additional CHF 34,750.
N412,3006,30060Notification for satellite networks not subject to Section II of Article 9.
N517,6009,00086Notification for non-geostationary satellite systems subject to No. 9.21 only.

Budgeting and Tools​

  • SPACECAP Cost Analysis: To avoid unexpected bills, operators use the Cost Recovery Analysis feature inside the ITU's SPACECAP software. By loading their filing database, they can compute the exact number of units and estimate the fee before submission.
  • The Free Entitlement: Every ITU Member State is entitled to submit one satellite filing per year completely free of charge (usually designated for the country's national space agency or university CubeSat).
  • Payment Deadlines: Invoices are sent by the ITU to the notifying administration and must be paid within 6 months. If an operator fails to pay their administration, and the administration fails to pay the ITU, the filing is cancelled.

Modifications & Protecting Priority​

During the 7-year planning phase, operators frequently need to tweak their satellite networks. These updates are submitted to the ITU database as modifications using three primary actions:

  1. ADD: Submitting a brand-new frequency band or orbital characteristic.
  2. MODIFY: Adjusting existing technical characteristics (e.g., boosting transmitter power or shifting antenna beam coverage).
  3. SUPPRESS: Deleting frequency assignments or orbital slots that are no longer needed.

The Date of Protection (2D-Date)​

Your regulatory "priority" against other satellite networks is determined by your date of protection (or 2D-date), which is the date the ITU receives your complete CR/C filing. Whoever has the earlier receipt date has the "priority" right, meaning the later filer must coordinate around the earlier filer.

Resetting the Date of Protection​

If you submit a modification, you risk resetting your date of protection:

  • Minor Technical Modifications: If a modification does not expand the network's interference envelope (e.g., decreasing transmitter power, narrowing beamwidths, or reducing the number of satellites), the original date of protection is retained.
  • Substantive Modifications: If the modification increases the potential for interference to other networks (e.g., shifting a GSO satellite's longitudinal position, adding new frequency bands, or expanding beam footprints), the ITU will assign a new date of protection to the modified assignments. This resets the regulatory priority and starts a new 7-year clock only for the modified portion of the filing.

Bringing Into Use (BIU)​

To "lock in" your frequency assignments permanently in the MIFR and protect them from expiration, you must Bring Into Use (BIU) the frequencies within 7 years of the initial filing receipt date (under Radio Regulations No. 11.44).

GSO BIU Requirements (No. 11.44B)​

To bring a Geostationary space station into use, the operator must:

  1. Deploy a satellite capable of transmitting and receiving the filed frequency assignments.
  2. Place it at the notified orbital location.
  3. Keep it operational at that location for a continuous period of 90 days.

NGSO BIU Requirements (No. 11.44C)​

To bring a Non-Geostationary satellite system into use:

  1. The operator must launch at least one satellite capable of transmitting and receiving the filed frequencies.
  2. The satellite must be operated in one of the notified orbital planes of the system for a continuous period of 90 days.

Milestone Revisions for NGSO Constellations​

Historically, deploying a single satellite was sufficient to secure rights for an entire constellation of thousands of satellites. To prevent this "spectrum warehousing," WRC-19 adopted Resolution 35, establishing a milestone-based deployment framework for NGSO constellations in specific bands (Ku, Ka, and V-bands).

Once the 7-year BIU deadline is met, the operator must meet three phased deployment milestones relative to the end of the BIU deadline:

  • Initial Information (M0): Within 30 days of the 7-year limit, the administration must submit launch dates and satellite characteristics to the ITU.
  • Milestone 1 (M1 - 2 Years Post-BIU): The operator must deploy at least 10% of the total constellation size specified in the filing.
  • Milestone 2 (M2 - 5 Years Post-BIU): The operator must deploy at least 50% of the total constellation size.
  • Milestone 3 (M3 - 7 Years Post-BIU): The operator must deploy 100% (full deployment) of the constellation.
BIU Deadline (7 Years) -> M1 (+2 Years: 10%) -> M2 (+5 Years: 50%) -> M3 (+7 Years: 100%)

Consequences of Failure​

If an operator fails to meet a milestone, the ITU does not cancel the entire filing. Instead, the notified constellation size in the MIFR is reduced to the number of satellites actually deployed at that milestone deadline.

Orbital Tolerances (Resolution 8 - WRC-23)​

To prevent operators from claiming that passing active satellites are part of their constellation, WRC-23 adopted Resolution 8. This regulation defines strict tolerances on orbital parameters (inclination, apogee, perigee, and argument of perigee). If a deployed satellite falls outside these tolerances, it cannot be counted toward the operator's milestone targets.

Next Steps​