As direct-to-device (D2D) satellite services move from trials toward commercial deployment, new tensions are emerging around spectrum rights.
At stake is who ultimately controls the networks, customer relationships and regulatory frameworks. Mobile network operators (MNOs), satellite operators, regulators and standards bodies are navigating a rapidly evolving environment where terrestrial and non-terrestrial networks increasingly overlap.
D2D services blur traditional distinctions between terrestrial mobile networks and satellite systems. In some cases, satellite operators are using spectrum already licensed to mobile carriers. In others, they rely on globally harmonized mobile-satellite service (MSS) spectrum. Increasingly, operators are discovering that neither approach alone is sufficient.
“The efficient answer is not one or the other but both,” said Amy Mehlman, EVP and chief global affairs officer for Lynk Global, which provides D2D connectivity. “The best solution for many MNOs is a combination of IMT and MSS access solutions.”
That hybrid reality is reshaping not only technical architecture but also the geopolitical and regulatory dynamics surrounding spectrum access.
Two Paths to D2D
The D2D market has effectively split into two camps. One model relies on terrestrial mobile spectrum — referred to as International Mobile Telecommunications (IMT) spectrum — that allows satellites to connect directly with existing smartphones without requiring specialized chipsets. This approach has become attractive because it leverages billions of existing devices already in consumers’ hands.
The alternative relies on MSS spectrum, which has long been allocated specifically for satellite communications. MSS-based services typically require newer 3GPP Release 17-compatible handsets or specialized chipsets, but they also avoid many of the coordination problems associated with terrestrial spectrum reuse.
According to Tom Stroup, president of the Satellite Industry Association (SIA), both models offer distinct trade-offs.
“Using spectrum licensed to mobile operators offers the advantage of avoiding modifications to existing handsets, but that comes with the complexity of negotiating agreements with mobile operators around the world as well as needing to avoid interference,” Stroup said. “Using MSS spectrum for service to mobile devices avoids many of these issues but requires inclusion of chipsets to operate on those frequencies.”
For some in the satellite industry, MSS spectrum represents the cleaner long-term solution.
“MSS spectrum is particularly well-suited for providing D2D because it is already used and licensed for satellite service to small handsets.” -John Janka, MSSA and Viasat
“MSS spectrum is particularly well-suited for providing D2D because it is already used and licensed for satellite service to small handsets,” said John Janka, secretary of the Mobile Satellite Services Association (MSSA) board and chief officer of global government affairs and regulatory at Viasat.
According to Janka, D2D services operating in MSS bands are less about changing spectrum governance and more about modernizing the technology itself.
“There is no change needed in the spectrum rights, allocation or governance when MSS spectrum is used,” he said. “Just the use of more advanced equipment to provide better service.”
But commercial realities are complicating that. The ability to connect directly to legacy smartphones has become a powerful market advantage, particularly as operators race to scale services globally. As a result, the industry increasingly sees spectrum flexibility as critical to long-term viability.
“This concept has driven about $30 billion of announced acquisition activity in the past year or so,” Mehlman said. “It is increasingly understood in the industry that a global portfolio of MSS spectrum is essential to deploying a scalable global D2D solution.”
The Interference Problem
While D2D promises expanded connectivity and resilience, it also introduces a potential technical and regulatory challenge: cross-border interference.
Unlike terrestrial towers, satellites do not stop neatly at national borders. Their coverage beams routinely span multiple jurisdictions simultaneously, creating scenarios where transmissions authorized in one country could interfere with services in another.
That risk becomes especially complicated when terrestrial mobile spectrum is reused from orbit.
“Interference may occur if frequencies used along borders are not compatible, harmonized or subject to bilateral or multilateral coordination agreements,” Janka said.
Those concerns are now being studied at the International Telecommunication Union ahead of the World Radiocommunication Conference 2027 under Agenda Item 1.13, which focuses on the use of terrestrial spectrum bands for satellite-based direct connectivity.
Tatiana Lawrence, international and regulatory vice president at satellite operator Iridium Communications, said the issue stems from the fundamental mismatch between national licensing regimes and global satellite footprints.
“Transmissions authorized in one jurisdiction can potentially affect terrestrial mobile networks or other radio communication services in neighboring countries.” -Tatiana Lawrence, Iridium
“Satellite beams cover large geographic areas that routinely cross national borders,” Lawrence said. “Transmissions authorized in one jurisdiction can potentially affect terrestrial mobile networks or other radio communication services in neighboring countries.”
According to Lawrence, systems operating in globally harmonized MSS spectrum face fewer challenges because those frequencies are already internationally coordinated through established ITU frameworks.
“Iridium operates in internationally allocated and coordinated MSS L-band spectrum,” she said. “This substantially reduces cross-border spectrum conflicts.”
Still, regulators face mounting pressure to move quickly as commercial deployments accelerate.
“We are at the starting point of establishing global standards, but in reality, we expect commercial solutions to outpace regulation,” Mehlman said.
Sovereignty vs. Connectivity
The debate surrounding D2D spectrum rights increasingly overlaps with broader geopolitical concerns about sovereignty and control over national communications infrastructure.
Governments are simultaneously attracted to the resilience benefits of satellite connectivity while remaining wary of allowing foreign-controlled systems to operate freely across their territories. That dynamic is shaping regulatory approaches around the world.
“[MSSA is] committed to supporting the integration of space networks into national telecommunications infrastructure via trusted local partners and within sovereign regulatory and national security frameworks,” Janka said.
The issue is especially sensitive because D2D services can effectively bypass traditional terrestrial infrastructure. In some cases, consumers may gain satellite connectivity regardless of whether regulators have fully authorized the service locally.
“The ready access to mobile devices with D2D capability will create challenges for regulators seeking to prevent access to that service.” Tom Stroup, SIA
“The ready access to mobile devices with D2D capability will create challenges for regulators seeking to prevent access to that service,” said Stroup of SIA.
This creates a paradox for governments. Restrictive regulation could slow innovation and limit connectivity benefits, while permissive policies may weaken sovereign control over communications networks and spectrum management.
Mehlman believes regulators ultimately will need to adopt more flexible approaches.
“Regulations must be a reasonable compromise between delivering comfort that a new network will not interfere, clear guidelines on how interference and network degradation is measured and limited and a measure of focus on allowing the societal benefits of D2D to accelerate and flourish,” she said.
Who Owns the Customer?
Despite growing excitement around satellite-based mobile connectivity, most industry stakeholders do not believe D2D will replace terrestrial cellular networks. Instead, many envision a complementary model in which satellites extend coverage into underserved regions, disaster zones and remote environments where traditional infrastructure remains economically impractical.
That reality is shaping the commercial relationships emerging between satellite operators and mobile carriers.
“I envision mobile operators partnering with multiple satellite providers,” Stroup said. “They definitely will seek to retain control of both their customers and spectrum.”
Iridium similarly views D2D as an extension of the traditional roaming model rather than a direct competitive threat to carriers.
“When coverage gaps arise, an MNO’s customers can seamlessly roam onto the Iridium network,” Lawrence said. “The MNO retains full control over how they bill and manage their end customers — and that relationship never changes hands. The customer always remains with the MNO.”
Under Iridium’s model, satellite connectivity effectively becomes another layer of network coverage rather than a standalone service.
Lynk sees the same dynamic emerging globally.
“Although there has been much said about satellite D2D taking over from terrestrial networks, in reality it is a physical and spectrum impossibility for these two network solutions to compete.” -Amy Mehlman, Lynk Global
“Although there has been much said about satellite D2D taking over from terrestrial networks, in reality it is a physical and spectrum impossibility for these two network solutions to compete,” Mehlman said. “We believe D2D is complementary and synergistic with terrestrial networks, and the commercial arrangements should be developed together with MNOs.”
According to Mehlman, satellites are best positioned to address the roughly 2% of low-density areas that terrestrial carriers struggle to serve economically.
“The customer will win with the combination of these two technologies converging,” she said.
Toward a Hybrid Future
Ultimately, the future of D2D may depend less on which spectrum model wins and more on how flexibly operators combine multiple approaches.
The structure of terrestrial mobile networks varies significantly by region, and spectrum availability differs widely between countries. As a result, operators increasingly view hybrid architectures as essential.
“The capabilities of a satellite network operator will need to be flexible to adapt to dynamically changing needs as satellites transit the Earth,” Mehlman said.
That flexibility extends beyond technology into regulation itself.
The next several years likely will determine whether global D2D services evolve into a fragmented patchwork of national agreements or a more harmonized ecosystem built around shared standards and coordination mechanisms.
Explore more:
Spectrum Choices Dictate the Launch and Evolution of D2D Services
D2D: A New Tool for Emergency Response
The Rules of Spectrum Are Changing As We Speak
