Ofcom Opens More Satellite Spectrum for Ships, Aircraft and City Gateways: The October 2026 ESIM Decisions

Most UK space law coverage is about the Space Industry Act 2018 and the Civil Aviation Authority. For satellite broadband operators the more immediate regulator is often Ofcom, because a licence to operate a satellite gives no right to transmit to it from a ship, an aircraft or a ground station in Britain.

On 23 October 2026 Ofcom took two decisions that widen those rights: more spectrum for ESIMs on UK ships and aircraft, and Q/V band gateways in the dense urban areas left out of an earlier decision. This note sets out what Ofcom decided, the ITU rules behind it and what still has to happen.

What an ESIM is and why it needs its own authorisation

An earth station in motion is a satellite terminal that transmits while moving: a flat panel antenna on an airliner, a stabilised dish on a ship, or a terminal on a vehicle.

The legal difficulty is that most Ku and Ka band satellite frequencies are shared with terrestrial services and other satellite systems. A fixed dish can be coordinated once; a terminal on an aircraft crossing several countries cannot. The International Telecommunication Union (ITU) has dealt with this band by band, adopting resolutions that set the technical conditions ESIMs must meet to avoid harmful interference. National regulators then decide whether, and on what terms, to authorise them. Our guide to ITU spectrum and orbital slots explains how that two-level system works.

In the UK, Ofcom authorises radio equipment under the Wireless Telegraphy Act 2006, through licences such as the Ship Radio and Aircraft Radio licences and the Earth Station Network licence for networks of satellite terminals, or through licence exemptions.

The ESIM decision: which bands, and for whom

Ofcom consulted on 16 June 2026, with responses due by 11 August 2026, on proposals to make significantly more spectrum available for ESIM uplink, that is, transmissions from the terminal up to the satellite. Its consultation proposed updating the Aircraft Radio and Ship Radio licences, adding the usable UK frequencies to the Earth Station Network licence and amending two Interface Requirements, IR 2077 and IR 2093.

On 23 October Ofcom confirmed the proposals. As quoted by ISPreview, the decision extends existing authorisations as follows.

For aeronautical ESIMs, Ofcom will authorise terminals communicating with geostationary (GSO) satellites in 12.75-13.25 GHz, 27.8185-28.4545 GHz and 28.8265-29.4625 GHz, and terminals communicating with non-geostationary (NGSO) satellites in 27.5-29.1 GHz and 29.5-30 GHz.

For maritime ESIMs, Ofcom will authorise terminals communicating with GSO satellites in the same three bands, and terminals communicating with NGSO satellites in 27.8185-28.4545 GHz and 28.8265-29.1 GHz.

The maritime NGSO allocation is narrower than the aeronautical one, so a ship terminal working with a low Earth orbit constellation gets less Ka band uplink in the UK than an aircraft terminal on the same network.

Ofcom says the frequencies will become available for UK registered ships and aircraft from early 2027. Much of the spectrum will be usable in UK airspace and territorial waters, and all of it in international waters and airspace, subject to international regulations and local requirements.

The ITU rules behind the decision

Ofcom tied the technical conditions to the global framework in ITU Resolutions 121, 123 and 156 and Resolution 169 of WRC-19. Two of them were adopted at the 2023 World Radiocommunication Conference in Dubai and matter most here.

Resolution 121 (WRC-23) covers the use of 12.75-13.25 GHz by ESIMs on aircraft and vessels communicating with geostationary satellites in the fixed-satellite service. That band is part of the Appendix 30B Allotment Plan set up at the 1988 orbit conference (WARC Orb-88), which reserves certain satellite frequencies so that every country has equitable access to them. Letting moving terminals use planned spectrum is a significant change for that part of the Radio Regulations.

Resolution 123 (WRC-23) covers aeronautical and maritime ESIMs communicating with non-geostationary fixed-satellite systems in 27.5-29.1 GHz and 29.5-30 GHz for uplink, with associated downlink bands between 17.7 GHz and 20.2 GHz. This is the resolution that matters to operators of large low Earth orbit constellations offering in-flight and maritime broadband, such as those discussed in our explainer on how Starlink is licensed.

Resolutions 156 and 169 deal with ESIMs communicating with geostationary networks in parts of the Ka band. Taken together, the four resolutions give Ofcom an agreed international baseline, which is why its conditions follow them rather than inventing UK-specific limits.

What still has to happen before ESIMs can use the new bands

The decision is not self-executing. Two further steps are visible.

First, Ofcom published a general notice on 23 October 2026 of a proposal to vary satellite Earth Station Network licences. Under the Wireless Telegraphy Act, Ofcom generally has to give notice and consider representations before varying existing licences, so holders of those licences should check the notice and the deadline for responses.

Second, Ofcom said it will consult in November on changes to Automatic Identification System (AIS) licences and Suppliers and Demonstration licences. It linked the maritime changes to modernising the systems ships and authorities use to exchange navigation and safety messages.

The Q/V band gateway decision

The second decision concerns gateways, the large ground stations that connect satellite networks to the internet. Q/V band frequencies, around 37 GHz to 52 GHz, carry much more capacity than Ku or Ka band and are becoming important for the newest constellations.

In March 2026 Ofcom made up to 10 GHz of Q/V band spectrum available for gateways across most of the UK. On 23 October it published a further statement extending access to up to 8 GHz in the remaining urban high density areas, which Ofcom describes as the 6% of the UK’s landmass not covered by its existing Q/V band licence products.

The frequencies in high density areas are:

GSO gateways: uplink 47.2-50.2 GHz and 50.4-52.4 GHz, downlink 37.5-40.5 GHz.

NGSO gateways: uplink 47.2-50.2 GHz and 50.4-51.4 GHz, downlink 37.5-40.5 GHz.

These can be authorised through Ofcom’s standard NGSO gateway and GSO Permanent Earth Station licences, with conditions to protect other users. According to Ofcom, those conditions include a maximum transmit power density at the antenna port of -7.4 dBW per MHz for GSO gateways and +6.5 dBW per MHz for NGSO gateways, antennas that meet at least the minimum specification in the relevant ITU recommendations, a minimum elevation angle of 20 degrees for NGSO gateways and 15 degrees for GSO gateways, and compliance with existing ITU rules. Applications will be assessed on a first come, first served basis. Access to 39.5-40.5 GHz and 50.4-51.4 GHz remains subject to coordination with the Ministry of Defence.

Why the cities get less downlink

The most interesting choice is what Ofcom left out. In lower density areas, NGSO gateway and Permanent Earth Station licences allow downlink across 37.5-42.5 GHz. In high density areas Ofcom has excluded 40.5-42.5 GHz because of the difficulty of sharing with other users, including mobile licensees who hold that spectrum.

Operators who want it in a city can instead apply through Ofcom’s Local Access licensing framework, which allows a third party to use spectrum already awarded nationally in places where the licensee is not using it. Ofcom expects that route to work best where a satellite operator first agrees the approach with the mobile licensees and they do not plan to deploy there, and it says it will monitor how well the arrangement works.

In practice, mobile operators’ consent decides access to that spectrum in UK cities. I think that is a sensible compromise, but it leaves satellite operators negotiating with competitors on a point the regulator chose not to settle by rule.

How this fits the wider UK regime

These are spectrum decisions, not space licences. A UK company operating a satellite still needs an orbital operator licence under the Space Industry Act 2018 or, for some activities, a licence under the Outer Space Act 1986, as our guide to UK space law and licensing explains. A constellation run by a non-UK company from outside the UK will usually be licensed in its home State, but it still needs Ofcom authorisation for the terminals and gateways that transmit from British territory. For many non-UK operators, that makes Ofcom the UK regulator they deal with most.

Ofcom is also active internationally. On 12 October 2026 it published a paper on reforming the ITU’s equivalent power flux-density (EPFD) limits for GSO and NGSO sharing in the Ku and Ka bands, limits the FCC has also been revisiting, as we reported in our note on the FCC’s EPFD reference links.

What I would watch

The first is the November consultation on AIS and Suppliers and Demonstration licences, and the outcome of the proposed variation of Earth Station Network licences. Those documents will show how quickly the new ESIM frequencies can actually be used and on what licence terms.

The second is the Local Access route for 40.5-42.5 GHz. If satellite operators cannot reach terms with mobile licensees, urban Q/V band gateways will run with 3 GHz of downlink rather than 5 GHz, and Ofcom may be asked to revisit the point sooner than it planned.

The third is the international picture. Ofcom’s ESIM rules follow the ITU’s resolutions closely, and its EPFD paper suggests the UK wants to shape the next round of changes before WRC-27 rather than react to them.

Anuj KumarEditor-in-Chief

Anuj Kumar is the founder of Legal Desire Media and publishes Fashion Law Journal and Space Law Journal.

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