How Ofcom’s D2D Authorisation Framework Actually Works

On 25 February 2026, the UK became one of the first countries in the world to bring a formal regulatory framework for direct-to-device satellite services into force. That date marks the point at which connecting a standard smartphone directly to a satellite in UK mobile spectrum bands became a legally authorised activity rather than a regulatory grey area.

But understanding what the framework does — and what it does not do — requires looking past the headline. I have been following the development of this framework closely since my 2023 TEDx talk on LEO satellite connectivity, and the gap between how the regulations are reported and how they actually work in engineering and spectrum management terms is worth closing.

This article explains the two instruments that make up the framework, how the authorisation process works in practice, which spectrum bands are covered, what the interference conditions actually require, and where the significant remaining question of MSS spectrum sits.

Key facts at a glance:

Framework in force: 25 February 2026

Legislation: Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) Regulations 2026

First licence variation: VMO2 + SpaceX Starlink (1800 MHz band)

Second licence variation: VodafoneThree + AST SpaceMobile (900 MHz band)

Authorised bands: 700, 800, 900, 1400, 1800 MHz, 2.1 GHz, 2.6 GHz (FDD and SDL only)

MSS spectrum: separate track, consultation expected later in 2026

Why a New Framework Was Needed
Before February 2026, there was no legal route for a UK mobile handset to connect to a satellite using terrestrial mobile spectrum. The Wireless Telegraphy Act 2006 requires devices that transmit or receive radio signals to be individually licensed, or to fall within an exemption. Standard mobile handsets are covered by existing exemptions for terrestrial use — but those exemptions did not extend to satellite connectivity in mobile bands.

The result was a legal gap. Satellite operators and mobile network operators were developing the technology, trials were taking place, but the regulatory framework had not kept pace. Ofcom’s 2025 consultation process was designed to close that gap in a controlled way, ahead of the ITU’s World Radiocommunication Conference in 2027, where the international spectrum framework for D2D will itself be debated.

The Two Instruments
The framework rests on two distinct legal instruments working in combination. Understanding both is necessary to understand how the system actually operates.

Instrument 1: The Exemption Regulation
The Wireless Telegraphy (Direct to Device Satellite Communications) (Exemption) Regulations 2026 remove the individual licensing requirement for handsets and SIM-enabled devices when they connect to an authorised D2D satellite service. Without this, every smartphone connecting to a D2D satellite would technically require its own wireless telegraphy licence — clearly unworkable at consumer scale.

The exemption is not unconditional. It applies only to devices connecting to services provided by an MNO that holds a valid D2D licence variation. It specifies which mobile standards are eligible — including GSM, UMTS, LTE and 5G NR. It prohibits airborne use. And it sets limits on device transmit power. The exemption exists to enable the user-side of the service; the operator side is controlled through the licence variation.

Instrument 2: The Licence Variation
Any MNO that wants to offer D2D services must apply to Ofcom to vary its existing Wireless Telegraphy licence. This is not a new licence — it is an amendment to the spectrum authorisation the MNO already holds, adding a dedicated D2D schedule alongside the existing terrestrial use conditions.

The licence variation application must include:

The specific frequencies the MNO proposes to use for D2D
Evidence of the commercial agreement with the satellite operator
Trial results demonstrating the service can operate without causing harmful interference, including overseas trial data with an explanation of its applicability in the UK context
A coordination plan for co-channel and adjacent-channel spectrum users
Evidence of communication with operators in adjacent jurisdictions whose spectrum may be affected
Once Ofcom approves a variation, the relevant frequencies are added to the Exemption Regulations, which then come into force for those bands. The sequencing is deliberate: the exemption regulation tracks the approved variations rather than pre-authorising all bands at once.

How the Authorisation Process Has Worked in Practice
The process followed a three-stage regulatory timeline across 2025 and early 2026:

March 2025
Ofcom publishes initial consultation on enabling D2D services in mobile spectrum bands.
September 2025
Ofcom publishes statement and further consultation, confirming the two-instrument framework and technical conditions. Consultation on device exemption regulations opens.
December 2025
Ofcom publishes final statement confirming all policy decisions. Final draft exemption regulations published alongside sample licence variation schedule.
16 February 2026
Exemption Regulations made, following approval of VMO2’s licence variation request for the 1800 MHz band (partnership with SpaceX Starlink).
25 February 2026
Regulations come into force. UK D2D services in mobile spectrum legally authorised for the first time.
April 2026
Ofcom approves second licence variation for VodafoneThree in the 900 MHz band (partnership with AST SpaceMobile). Amendment regulations consulted on to add 900 MHz to the exemption.
Which Spectrum Bands Are Covered
The framework covers all frequency division duplex (FDD) and supplementary downlink (SDL) mobile bands below 3 GHz. Time division duplex (TDD) bands are excluded for now. The authorised bands are:

Band Frequency Notes
700 MHz 703–733 / 758–788 MHz Strong rural propagation; long range
800 MHz 791–821 / 832–862 MHz 4G coverage band in UK
900 MHz 880–915 / 925–960 MHz VodafoneThree first variation band
1400 MHz 1452–1492 MHz (SDL) Supplementary downlink only
1800 MHz 1710–1785 / 1805–1880 MHz VMO2 first variation band
2.1 GHz 1920–1980 / 2110–2170 MHz 3G and 4G/5G
2.6 GHz 2500–2570 / 2620–2690 MHz Additional radar protection conditions apply
The selection of FDD-only bands is a deliberate RF engineering decision. In a D2D satellite link, the satellite transmits on the downlink frequency and the handset transmits on the uplink frequency. FDD separates these onto different frequency pairs, which simplifies interference management between the satellite signal and terrestrial base station transmissions. TDD bands, where uplink and downlink share the same frequency in alternating time slots, create more complex coordination problems in a mixed terrestrial and satellite environment.

What the Interference Conditions Actually Require
The interference conditions built into the licence variation schedule are where most of the engineering work sits. D2D services operate on a non-interference, non-protection basis — they must not cause harmful interference to existing spectrum users and cannot claim protection from interference themselves. That is standard for a secondary or exempted use, but the detail of how it is implemented is specific to the D2D context.

The key condition is a power flux density (PFD) limit at the Earth’s surface. The satellite’s signal arriving at the ground must stay below a specified power level that protects co-channel terrestrial receivers. This is an internationally recognised technique for managing interference between satellite and terrestrial systems in the same band — it appears in ITU Radio Regulations and is familiar from existing MSS licensing frameworks.

For the 2.6 GHz band specifically, there is an additional requirement: the MNO must demonstrate that combined out-of-band emissions from both satellite and terrestrial transmissions do not exceed the protection limits for air traffic control radar operating in the 2.7 to 3.1 GHz range. The MNO is responsible for calculating how to apportion the interference budget between its ground network and its satellite partner. This is a shared engineering problem, not just a contractual one.

Cross-border coordination is also mandatory. Before activating D2D transmissions, the MNO must communicate with co-channel operators in adjacent countries and agree operational arrangements for reporting and investigating suspected interference. For operators with holdings near the Scottish borders, the English Channel coast, or in Northern Ireland, this is not a trivial administrative step.

What the Framework Does Not Cover: MSS Spectrum
The February 2026 framework covers D2D in terrestrial mobile spectrum bands only. It explicitly does not cover D2D services using mobile-satellite service (MSS) spectrum — for example, the 2 GHz MSS band used by operators such as Inmarsat and Intelsat under existing authorisations.

This is a separate regulatory track. As I explained in an earlier article on the two main D2D spectrum options, MSS spectrum sits in a different licensing environment with its own international coordination framework. Ofcom ran a separate call for input on the future use of the 2 GHz MSS band in mid-2025, and a consultation on detailed proposals is expected during 2026.

The UK Government also opened a consultation in late 2025 on revoking the regulations that currently authorise two MSS operators to use 2 GHz spectrum, with a view to allowing Ofcom to reassess the band’s future use once existing licences expire in 2027. The outcome of that process will shape whether a new D2D authorisation regime is created for MSS bands, or whether an existing regime such as the Earth Station Network licence framework is adapted.

What It Means From a Radio Engineering Perspective
For RF and systems engineers, the most significant aspect of this framework is not the legal instrument — it is the spectrum management philosophy behind it. Ofcom has not allocated new spectrum for satellite use. It has instead allowed existing terrestrial mobile spectrum to become a dual-use asset: the same frequency band can now carry both a ground-based cell signal and a satellite downlink, subject to interference conditions.

That approach requires the satellite signal to look credible to a standard mobile handset. In practice, it means the satellite must generate a signal in the correct format for the relevant mobile standard — LTE or 5G NR — at sufficient signal strength to register as a serving cell, while staying within the PFD limits that protect terrestrial users. The link budget challenge in doing that from a satellite in low Earth orbit, to a handset with a small omnidirectional antenna and low transmit power, is substantial. It is why the AST SpaceMobile approach of deploying very large phased array antennas in LEO exists: more aperture means more gain, which closes the budget without breaking the interference limits.

What Happens Next
The framework Ofcom has built is explicitly designed to be reviewed after WRC-27 in 2027, when international spectrum policy for D2D will be established. Whatever emerges from WRC-27 may require refinements to the UK framework — potentially relaxing some conditions if international coordination arrangements improve, or tightening others if interference problems emerge at scale.

In the near term, the expected next steps are:

Further licence variation requests from EE and other MNOs as they finalise their satellite partnerships
Ofcom consultation on MSS band D2D proposals, expected during 2026
Amendment regulations adding further frequency bands as additional variations are approved
Potential extension to TDD bands if coordination problems prove manageable in FDD deployment
Final Thoughts
Ofcom’s D2D authorisation framework is a carefully constructed two-instrument system: an exemption regulation that handles the handset-side licensing problem at consumer scale, and a licence variation mechanism that gives Ofcom granular control over which operators can offer which services in which bands under what interference conditions. The framework is live, two operators are already authorised, and a third track covering MSS spectrum is moving through consultation.

For anyone working in RF engineering, spectrum management, or satellite communications, the detail of how interference conditions are structured — PFD limits, cross-border coordination, radar protection at 2.6 GHz — is where the real engineering challenge of D2D deployment lives. The regulatory framework is not a rubber stamp on the technology; it is a set of constraints that the technology must be designed to satisfy.

Craig Miles
RF and satellite systems engineer with 30 years spanning aerospace, satellite programmes, and wireless communications. TEDx Brayford Pool 2023. Founder, Yesway Communications Ltd.

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