The short version

• Space law in France rests on the French Space Operations Act of 3 June 2008 (loi n° 2008-518). It requires prior authorisation for launches from France, for French operators launching or controlling objects anywhere, and for transfers of control of a space object, which on my reading includes buying a satellite already in orbit.
• CNES checks each application against a detailed technical regulation, overhauled on 28 June 2024. It now limits orbital lifetime after disposal to 25 years at most, and to 5 or 2 years for satellites in mega-constellations.
• The operator is strictly liable for damage on the ground and in airspace. Above a ceiling set in each authorisation, between €50 million and €70 million under the 2008 finance law, the State guarantees the operator for operations conducted from the EU or EEA.
• The Act has been tightened for defence three times since 2022, most recently by loi n° 2026-791 of 16 August 2026, which made it an offence to capture or spread space-origin data on zones where aerial image capture is banned.

Space law in France matters well beyond France. Europe’s spaceport is in French Guiana, commercial launches from it need French authorisation, and the French Space Operations Act also governs what happens when a French satellite changes hands, which is why a deal as large as Amazon’s purchase of Globalstar can end up waiting on Paris.

This guide explains the regime as of 9 November 2026, using the consolidated Act on Légifrance, the 2008 finance law and CNES’s English version of the technical regulation. Article numbers are from the Act unless I say otherwise.

The Act and who it catches

The loi n° 2008-518 du 3 juin 2008 relative aux opérations spatiales is usually called the LOS in French and the FSOA in English. Article 2 requires prior authorisation from the administrative authority in three situations.

First, any operator of any nationality that launches a space object from French territory or from means or installations under French jurisdiction, or returns one there. That covers commercial launches from the Guiana Space Centre.

Second, any French operator launching from another State’s territory, from facilities under foreign jurisdiction, or from an area outside any State’s sovereignty, or returning an object to such places.

Third, any French national or company with its seat in France that procures the launch of a space object, whether or not it is the operator, and any French operator that controls a space object or a group of coordinated objects in orbit.

So a French company buying a launch on a US rocket needs French authorisation, whatever licences the launch provider holds at home.

Transfers of control and in-orbit purchases

Article 3 requires prior authorisation for any transfer to a third party of control of a space object whose launch or control was authorised under the Act. As amended in 2023, it also requires a French operator to obtain authorisation before taking control of an object whose launch or control was never authorised under French law. On my reading, that captures the purchase of a foreign satellite already in orbit.

This is the provision that makes French law relevant to satellite mergers. Our analysis of the FCC’s approval of Amazon’s Globalstar deal explains why that closing is still waiting on French authorisation.

How authorisation works

Under Article 4, the authority checks the applicant’s moral, financial and professional guarantees, including those of shareholders where relevant, and its compliance with the technical regulation. Licences can certify an operator’s guarantees for a set period. No authorisation can be granted if the operation would compromise national defence or France’s international commitments.

CNES, the national space agency, checks applications against the technical regulation on behalf of the ministry responsible for space. It reports that more than 150 authorisations for orbital systems and more than 120 for launch systems have been granted since 2008.

Article 5 lets the authority attach conditions, including to limit space debris risks, Article 8 lets it issue instructions at any time, and Article 9 allows suspension or withdrawal. Under Article 11, launching, returning or transferring control without authorisation, or carrying on after a suspension, is punishable by a fine of €200,000, rising to three years’ imprisonment and a €300,000 fine where national defence is harmed.

Article 12 requires launched objects to be entered in a national register kept by CNES on the State’s behalf, which is how France meets the Registration Convention.

Article 11-1 takes CNES public missions and State defence operations outside the authorisation chapter, although the technical rules still apply to the latter, with derogations only so far as strictly necessary.

The technical regulation after June 2024

The real engineering content is in a ministerial order of 31 March 2011, which CNES calls the RT. A major revision of 28 June 2024 applies to authorisation applications submitted on or after 1 July 2024. CNES publishes an English consolidation of the revised order, and some of its rules go further than the FCC’s five-year deorbit rule for US-licensed satellites.

For launches, Article 20 of the order sets a maximum collective risk of 2 x 10^-5 for causing at least one casualty during the flight phase. Launcher elements placed in orbit are expected to make a controlled reentry. Only in exceptional, justified cases may an operator fall back on an uncontrolled one, and then it must use its best efforts to meet a 10^-4 objective.

For satellites, Article 41-9 caps the time in orbit after disposal at three times the operational phase and never more than 25 years, or three years for systems that operate for less than a year. Article 41-13 requires satellites without propulsion to fly with an apogee below 600 km.

For constellations, Chapter VI applies to groups of at least ten objects and adds tougher rules for “mega-constellations” of at least one hundred. Each satellite in a mega-constellation must carry propulsion for collision avoidance (Article 48-5). In the lowest protected region, its time in orbit after disposal is capped at five years, or two years if the constellation has 1,000 or more satellites (Article 48-7). Article 48-10 even sets a brightness objective to protect astronomy.

Article 55 phases some of this in: for applications made by 31 December 2026, disposal reliability thresholds are slightly relaxed and the operator need only show its “best possible strategy” towards the lifetime limit within 25 years. Further transitional rules run to the end of 2028. Our explainer on the space debris mitigation guidelines sets out the international baseline.

Liability, insurance and the State guarantee

In my view, Title IV is the most commercially important part of the Act. Article 13 makes the operator liable without fault for damage caused to third parties on the ground and in airspace, and liable for fault elsewhere, including in orbit. That liability ends, except for intentional fault, once the obligations in the authorisation have been met, and at the latest one year after they fall due.

Article 6 requires insurance or another approved financial guarantee for as long as Article 13 liability can arise, up to the ceilings set under Articles 16 and 17. The cover must also benefit the State, the European Space Agency and its member states.

Above that ceiling, Article 15 provides a State guarantee for an operator ordered to compensate a third party, for operations conducted from France, another EU State or an EEA State, within the limits of the finance law. Article 119 of the amending finance law of 30 December 2008 provides that the ceiling “sera compris entre 50 millions d’euros et 70 millions d’euros”, so each authorisation fixes a figure in that range. The guarantee does not apply to intentional fault.

If France pays as a launching State under the Liability Convention, Article 14 lets it recover from the operator only up to the same ceilings, save for intentional fault.

Articles 19 and 20 set up a statutory cross-waiver: participants bound by contract cannot sue each other for damage to a participant, save for intentional fault or an express contrary clause for certain phases. Our piece on cross-waivers in launch services agreements explains why US contracts have to achieve the same result by drafting.

Since the ordinance of 23 February 2022, Article 13-1 allows the operator’s sole liability to third parties to be adjusted by an agreement with the State for services performed in the interest of national defence.

Defence and space data: the 2022, 2023 and 2026 changes

The Act has been amended repeatedly with defence in mind. Ordonnance n° 2022-232 of 23 February 2022 added, among other things, Article 11-2 on transfers of control to the State and the Article 13-1 derogation, and revised the space data rules. Loi n° 2023-703 of 1 August 2023, the military programming law for 2024 to 2030, amended Articles 1 to 4, 7 to 9, 11, 11-1 and 20-1, including the Article 3 rule on taking control of objects never authorised under French law.

The latest change came with loi n° 2026-791 of 16 August 2026, which updated that programming law. Article 28 of the 2026 law rewrote Article 25-1 and created Article 25-2, both in force since 19 August 2026. Title VII of the Act already required primary operators of space-origin data carrying out technically defined activities in France to declare them in advance, with penalties of three years’ imprisonment and a €300,000 fine for breaches. The new Article 25-2 makes it an offence, punishable by the same penalties and subject to authorisation under a decree, to capture, record, transmit, store, use or disseminate space-origin data about zones listed under Article L. 6224-1 of the Transport Code, the zones where capturing images from aircraft is already prohibited.

Official missions under the justice, defence, customs and interior ministers are excluded. In effect, satellite imagery now follows the existing ban on aerial image capture over sensitive sites.

France and international law

France signed the Artemis Accords on 7 June 2022, becoming the 20th signatory, according to NASA. It has no space resources statute.

The bigger change ahead is European. The EU Space Act, proposed by the Commission on 25 June 2025, would set common authorisation, safety and sustainability rules across the Union. As our report on the Irish Presidency’s October 2026 compromise text shows, it is still in Council negotiation, and how it sits alongside national regimes such as the FSOA is one of the points being worked out.

What I would watch

The first is the end of the first transitional window on 31 December 2026. From 2027 applicants must meet the full disposal reliability and lifetime rules in the 2024 order, which will matter most for constellation operators.

The second is the implementing decree for Article 25-2, which will decide how imagery companies can obtain authorisation and how the offence applies to data collected outside France.

The third is the EU Space Act. If it is adopted in something close to its current form, France will have to decide which parts of the FSOA and its technical regulation survive as national rules.

The short version

• On 27 October 2026 three FCC offices, led by the Space Bureau, approved the transfer of Globalstar’s US licences and authorisations to Amazon in Order DA 26-1160, finding no material public interest harm.
• The only condition is that Amazon keeps to two national security letters of agreement that Globalstar signed with the Defense Department, the Justice Department and the FBI in 1999 and 2004.
• A former customer’s petition was denied because the FCC will not referee private contract disputes, and a late objection to its jurisdiction failed because Amazon has no reportable foreign ownership.
• The deal has not closed. Globalstar’s 5 November filing says closing depends on French authorisations for its planned C-3 constellation and is expected in 2027.

The Amazon Globalstar FCC approval came on 27 October 2026, and most coverage treated it as the end of the road for Amazon’s $11.57 billion purchase of the company that carries emergency texts for iPhones. It is the end of the US licensing review. It is not the end of the deal.

I have read the order and Globalstar’s latest quarterly report. Both show a transaction that cleared Washington easily, on a narrow condition, while its closing still waits on a regulator in Paris. If you advise satellite operators on mergers, financing or spectrum, the order is also a clean example of how the FCC now reviews a space deal under delegated authority.

What the FCC decided

The Order (DA 26-1160) was adopted and released on 27 October 2026 in GN Docket No. 26-134. It was signed by the chiefs of the Space Bureau, the Office of Engineering and Technology and the Office of International Affairs, acting under delegated authority, not by a vote of the Commissioners.

It grants consent under sections 214(a) and 310(d) of the Communications Act for Amazon to take 100% control of Globalstar, its subsidiaries and their authorisations. Globalstar becomes a wholly owned subsidiary of Amazon and an affiliate of Kuiper Systems LLC, the entity behind Amazon Leo. The Globalstar licensee companies keep their corporate identities and their licences.

The grant covers more than the existing fleet. Earlier in October the Space Bureau gave Globalstar US market access for its C-3 System, a planned constellation of 48 non-geostationary satellites licensed by France. The order extends the transfer approval to that grant too, at the applicants’ request.

FCC Chair Brendan Carr said the agency “has empowered Amazon Leo to deliver fast, next-gen satellite broadband services”, according to Reuters.

The test the bureaus applied

Section 310(d) of the Communications Act bars any transfer of control of a radio licence unless the FCC finds that it serves “the public interest, convenience, and necessity”. The order walks through the usual three steps: whether the parties are qualified and the deal breaks no statute or rule, whether it causes public interest harm, and whether its benefits outweigh any harm.

The first step was quick. No one challenged either company’s qualifications, and both already hold FCC licences.

On harm, the bureaus found nothing horizontal and nothing vertical. Globalstar sells mobile-satellite service (MSS) in the 1.6/2.4 GHz bands: messaging, asset tracking, emergency links and wholesale capacity for Apple devices. Amazon Leo sells fixed broadband through Ka-, Ku- and V-band terminals. The order says they “do not currently compete to provide the same satellite services”, and neither supplies the other. Amazon, it adds, holds no L-band or S-band spectrum that could reach a smartphone without special hardware.

On benefits, the bureaus credited three claims: that the deal gives Amazon a practical path into direct-to-device (D2D) service, that a bigger and newer fleet will use Globalstar’s spectrum more intensively, and that Amazon’s capital will improve service in unserved areas. The comparison of scale is stark. The order says the FCC has approved 7,736 Amazon satellites, against up to 26 for Globalstar.

One condition, and it is about national security

The grant carries a single condition. Amazon must comply with two letters of agreement that Globalstar entities signed in 1999 and 2004 with the Defense Department, the Justice Department and the FBI. The order calls the first of those agencies the Department of War, the name the current administration uses. The applicants asked for this condition themselves in a July 2026 supplement.

There was no Team Telecom referral. The FCC refers applications to the Executive Branch for national security review when there is reportable foreign ownership, and the applicants stated that Amazon is 100% US-owned. The bureaus sent a courtesy copy to the review committee on 9 June 2026 and went no further.

That is worth noting for anyone structuring a satellite acquisition. A US buyer with no reportable foreign ownership can keep national security review to existing commitments. A buyer with foreign investors would face a longer path.

The objections that failed

Two filings opposed the deal. Neither got far.

Yippy, Inc., a former Globalstar customer in an ongoing arbitration with the company, asked the FCC to dismiss the application or condition it to protect its claimed contract rights. The bureaus denied the petition, saying a transfer of control proceeding “is not the proper forum for resolving private contract disputes”, and citing the D.C. Circuit’s description of the FCC’s long-standing refusal to decide contract questions that a court can hear. They also found that no rule required the applicants to disclose the dispute.

A late filing by an individual, Dana Scioli, argued that the FCC lacked jurisdiction, pointing to foreign investment review and the National Environmental Policy Act. The order calls those claims “without merit”, says the application raised no foreign ownership issue, and notes that the filer had shown no interest in the transaction.

The lesson for counterparties is plain. If you have a commercial grievance against a licensee being sold, the FCC docket is a poor place to press it. Your contract and your arbitrator are where the real pressure lies.

Why direct-to-device was the deciding factor

Read as a whole, the order is a D2D decision. Amazon has a pending application for its own global D2D system, accepted for filing in August 2026, but the order notes that Amazon “would not have access to MSS spectrum needed to operate that system absent this transaction”.

That matters because of an earlier Space Bureau ruling. In its April 2026 MSS Clarification Order (DA 26-398), cited in the Globalstar order, the bureau reaffirmed that existing MSS licensees hold exclusive rights to use their bands for D2D. If you want satellite-to-phone service in the MSS bands, you buy or partner with an incumbent. SpaceX did that with EchoStar spectrum in May 2026, and Amazon has now done it with Globalstar. Our explainer on the FCC’s direct-to-device rules covers the wider rewrite now under way.

Apple is the other piece. The order records that Apple accounted for about 63% of Globalstar’s 2025 revenue and owns a 20% equity stake that Amazon says it will acquire. Reuters reports that Amazon has agreed with Apple to keep the iPhone emergency and Find My services running.

What still has to happen before closing

This is the part most reports missed. Globalstar’s quarterly report filed on 5 November 2026 sets out where things stand:

The waiting period under the Hart-Scott-Rodino Act expired on 17 July 2026. All required antitrust and foreign investment approvals under current law have been obtained, though Globalstar warns that new foreign investment laws could add more before closing. Shareholder approval was given by written consent.

Amazon’s obligation to close is still subject to Globalstar receiving authorisations from the FCC and “the relevant French authorities” for the C-3 System. Globalstar says it has applied to the French government to launch and operate C-3, which rests on a French filing with the ITU. The FCC part is done. The French part is not, as far as the filing shows.

French law is strict on control. Article 3 of the French Space Operations Act of 2008 requires prior authorisation for any transfer to a third party of control of a space object authorised under that Act. Whether a change in Globalstar’s ultimate owner counts as such a transfer for the French-licensed satellites is for the French authorities; the filing does not say, and I would not assume it does not.

Globalstar expects the mergers to close in 2027. Either side can terminate if the deal has not closed by 13 April 2027, a date that can be extended to 13 October 2027 and then 13 April 2028 if regulatory or satellite milestone conditions are still open. Amazon would owe a termination fee of about $592.1 million in some cases, including where required regulatory approvals are not obtained. Globalstar would owe about $419.8 million in others.

For background on how the ITU filing system ties a satellite network to one administration, and on what happens to licences when a satellite operator changes hands or fails, see our earlier pieces.

Can anyone still challenge the order?

Yes, briefly. The order took effect on adoption. Under 47 CFR 1.106, petitions for reconsideration may be filed within 30 days of adoption, which by my count runs to 26 November 2026. Because the bureaus acted under delegated authority, an aggrieved party can also ask the full Commission to review the decision under 47 CFR 1.115, within 30 days of public notice of the action. Given the thin opposition record, I would be surprised if either route changed the result.

What I would watch

The first is France. A decision on C-3 authorisation, and on any transfer of control of French-licensed satellites, is now the critical item on the closing list. Watch Globalstar’s next filings for news of it.

The second is Amazon’s own D2D application. With Globalstar’s spectrum in reach, the Space Bureau will have to decide how Amazon’s planned D2D satellites fit with Globalstar’s existing system and the MSS exclusivity it has just reaffirmed.

The third is the FCC’s wider D2D rulemaking. Performance requirements and any codified MSS exclusivity will set the terms on which Amazon, SpaceX and AST SpaceMobile compete for phone users. As our guide to how Starlink is licensed shows, the spectrum rules usually decide more than the satellites do.

The fourth is any petition filed before 26 November. Silence would make the order final at the FCC.