Debris Mitigation Regulation for the EU and the UK

A Comparative analysis of the EU Space Act and UK Regulatory Regime

Authors: Joshua Goodland, Andrew Iwanoczko

Reviewers: Alexander Simmonds, Andrew Wilson, Charlotte Hook, Molly MacEachen

Executive Summary 

Space debris represents an escalating threat to the orbital environment on which critical national infrastructure depends. Without effective regulatory intervention, the increasing risks generated by rapid satellite population growth have the potential to render key orbital bands unusable, with far reaching consequences extending beyond space operators to governments and the public as consumers of satellite-enabled services.

The World Economic Forum estimates that under a business-as-usual scenario, space debris could generate between $25.8-$42.3 billion in cumulative losses to the global space economy between 2025-2035, while the Organisation for Economic Co-operation and Development places the total value of space activity currently at risk from debris at $191 billion. These estimates make clear the urgent need to reduce economic exposure to space debris. To achieve this, national regulators and international institutions are developing varied approaches to debris mitigation compliance.

The European Union and the United Kingdom have adopted fundamentally different approaches to the challenge of regulating debris mitigation. Proposed by the European Commission in June of 2025, the draft EU Space Act pursues regulatory certainty through technically specific requirements and defined timelines, at the cost of greater compliance burdens. This risks introducing disproportionate barriers to entry for Small and Medium-sized Enterprises (SMEs) and prematurely restricting operators of innovative and emerging technologies. The UK’s principles-led As Low As Reasonably Practicable (ALARP) framework ensures flexibility and proportionality, but its case-by-case assessment process creates uncertainty about what compliance requires that leads to protracted licensing processes and added costs.

This report identifies two areas where neither regulatory framework fully meets the challenge that debris mitigation presents. The first concerns the balance between prescriptive compliance requirements that provide operators with certainty, and flexible requirements that allow regulation to keep pace with industry development. The second concerns whether each regime structures its licensing submissions and assessments in a way that both signals debris mitigation as a priority and accounts for its broader environmental and operational trade-offs.

The report then argues that while the UK’s principles-led approach has genuine strengths worth preserving, the proposed EU Space Act offers insights into how the UK regime can resolve its weaknesses. Four recommendations follow:

First, the UK Civil Aviation Authority should adopt presumed baseline standards into the licensing framework, covering dimensions such as orbital lifetimes, collision avoidance thresholds, and passivation measures. These could be drawn from the international standards that regulation currently defers to, with case-by-case assessment reserved for exceptional missions.

Second, the UK should establish a formal regulatory trajectory that monitors international best practices, tracks emerging technology, and develops regulatory reforms in tandem with the industry through a structured and predictable update cycle.

Third, a dedicated standalone debris mitigation submission should be adapted from the end-of-life plan and Debris Mitigation Plan currently embedded in the Technical Question Set, setting minimum standards of practice across the full mission lifecycle while retaining ALARP flexibility over how those standards are achieved.

Fourth, the environmental and operational trade-offs assessed across submissions should be integrated into a system-level environmental assessment, with the CAA providing guidance to operators on how competing considerations are weighed against one another. This would ensure that debris mitigation neither overrides nor becomes subordinated to other environmental impacts, and that the CAA’s licensing assessments are producing genuine sustainability outcomes.

The UK’s current reform moment, with the UK Space Agency - Department for Science Innovation and Technology integration completed, and the British Standards Institution Flex Standards maturing, represents a window for targeted reform that could enhance the UK’s regulatory approach. The cost of inaction is severe; an orbital environment whose long-term viability is compromised by inadequate governance, and a UK sector whose regulatory environment hinders rather than supports its competitive position.

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1 Introduction

1.1   The Debris Challenge

For many of us, space-enabled services play a role in our day to day lives before we leave the front door. Whether it's checking the weather, getting directions, or a bank transfer, the space industry has developed from exploration to infrastructure in fundamental and meaningful ways. The impact of losing these services could be as inconsequential as being caught without an umbrella, or getting lost in the mountains with no GPS.

The providers of space-enabled services take advantage of a global commons resource, orbital space. The recent rush of commercial activity growth represented by the ‘New Space’ era has ushered in projects orders of magnitude bigger in scale than their predecessors. Chief among them is US based Starlink (currently making up two thirds of the active satellite population^(1a)) and China based Qianfan (aiming for 15,000 satellites)⁽²⁾, actors caught in a space race to establish first mover advantages by building megaconstellations of satellites. This increased activity brings increased risk. Already Starlink is making over 300,000 avoidance manoeuvres yearly to minimise debris risks^(1b), while the upper stage of Qianfan's first satellite launch broke apart, generating more than 300 pieces of debris⁽³⁾. Loosely regulated satellite proliferation and uncoordinated space traffic management threaten to render the orbital environment unusable and disable the global services it enables. 

The risks produced by satellite proliferation are not borne solely by megaconstellation operators, as any debris generated becomes a hazard for all spacecraft. Every satellite within the same orbital band faces increased collision risk regardless of their operator’s own mitigation measures. Without international mechanisms to hold commercial operators accountable for the debris they generate, there is little market incentive to limit satellite proliferation and improve debris mitigation practices. By comparison to Chinese and US megaconstellation operators like Shanghai SST and SpaceX, UK and EU regulators approach rising debris risks as a call to action, recognising that orbital sustainability cannot be left to market forces.

As of 2025, the European Space Agency (ESA) estimates that there are 1.25 million 1-10 cm pieces of debris in Earth’s orbit⁽⁴⁾. When debris objects collide, they break apart into multiple pieces, increasing the risk of future collisions. As such, debris hazards and their associated risks escalate non-linearly, due to their self-reinforcing nature. Models of extreme scenarios predict what is known as a Kessler event⁽⁵⁾, where a series of cascading collisions results in a debris cloud that renders certain orbital bands unusable. Forecasts of the next major collision range from an annual one in ten chance^(6a) to a 29% probability in the most congested orbital zone by 2032⁽⁷⁾, with cascading effects expected to develop over the following decades^(6b). The potential for a Kessler event represents a tipping point. One that was first brought into focus by the Iridium-Cosmos collision in 2009, when a commercial satellite collided with a defunct Russian military satellite. The collision generated more than 1800 >10 cm pieces of debris and served as a demonstration of the very real threat posed by space debris⁽⁸⁾. Debris generation is not always a result of accidental collisions. In 2021, Russia tested an anti-satellite weapon on their defunct Kosmos 1408 satellite, generating more than 1500 trackable debris objects⁽⁴¹⁾. The resulting debris posed an indiscriminate risk to other spacecraft severe enough that it forced the crew of the ISS to take emergency measures⁽⁴²⁾.

The scale of the economic exposure to debris-related risk is significant. The WEF estimates that ‘business as usual’ could cost as much as $42.3 billion in losses to the global space industry by 2035^(7b) and the European Commission estimating that effective debris reduction has the potential to save operators billions of euros^(9a).

1.2 Where the EU and UK Regimes Fall Short

As the UK undergoes incremental reform, the proposed EU Space Act takes a fundamentally different approach to debris mitigation. This report compares the two frameworks to see what the UK’s regulatory regime can learn from the EU Commission’s contrasting proposal. In doing so, the report identifies two key areas where both approaches fall short of the needs of operators, and the challenge of space debris.

The first lies in the balance between regulatory certainty, achieved by the draft EU Space Act through prescriptive and fixed requirements, and flexibility in regulation, achieved by the UK regime through case-by-case assessment and non-binding standards. By compromising one for the other, the two approaches risk placing disproportionate compliance burdens on SMEs and operators of novel missions, either through overly restrictive compliance requirements or protracted and uncertain licensing processes.

The second area concerns how debris mitigation is structured and assessed within the two regulatory frameworks. The draft EU Space Act will include prescriptive technical requirements determined in large part through future implementing acts^(10a), with debris mitigation compliance demonstrated through three standalone licensing submissions^(10b). The UK framework defers to international standards for debris mitigation, namely those of the IADC⁽¹¹⁾ and ISO 24113^{(12)(13)(14a)}, applied through the case-by-case assessment of a Debris Mitigation Plan^(14b), submitted as part of a broader Technical Question Set^(15a). By consolidating debris mitigation into isolated submissions^(10a) the EU regime risks blinding itself to the broader systemic risks and environmental trade-offs that debris mitigation involves. By fragmenting debris considerations across submissions and deferring to non-binding international standards, the UK regime risks under-signalling debris mitigation as a regulatory priority and upholding inconsistent standards of practice.

The recommendations of this report emerge from a comparative analysis of the two contrasting approaches, suggesting targeted reforms aimed at resolving the weaknesses of the UK regime while preserving its strengths.

Section 2 of this report establishes the issue of space debris, the scale of the problem, and the case for regulation. Section 3 compares the EU and UK frameworks, while Section 4 explores what that comparison reveals about the strengths and weaknesses of each. Section 5 then sets out four recommendations for the UK regulatory regime based on the insights drawn from this analysis.

2 An Unsustainable Status Quo

The draft EU Space Act and UK regulatory regime have both been developed, in part, as a response to a sustainability challenge that market mechanisms and fragmented national standards cannot address on their own. This section covers the non-linear escalation of debris risks, asymmetric compliance burdens, and scale of economic exposure that characterise the status quo. Taken together, these show that regulatory action is not only justified, but necessary.

2.1 The Escalation of Space debris 

Estimates from the World Economic Forum anticipate the global space industry will grow as much as 9% annually until 2035, representing a potential end value of $1.8 trillion⁽¹⁶⁾. As space activity grows so does the potential for debris generation events and collisions that escalate the risks posed by space debris. Each collision has the potential to produce multiple new pieces of debris, meaning that such impacts represent a self reinforcing and non-linear risk⁽⁵⁾. Models of worst case scenarios predict what is known as a Kessler event, where cascading collisions lead to runaway debris populations across an orbital band⁽⁵⁾. Without the technology needed to remove debris, Kessler events have the potential to generate debris clouds that render whole orbits unusable⁽⁵⁾. Beyond potential Kessler events, conjunctions between satellites and debris require collision avoidance manoeuvres that impose operational costs. While megaconstellation operators may have the capacity to accommodate higher manoeuvre rates, smaller and single-satellite operators could be edged out of the orbital domain as the operational cost incurred by debris rises⁽³⁷⁾.

Operators in Low-Earth Orbit routinely perform collision avoidance manoeuvres to minimise the risk of conjunctions with debris. SpaceX’s Starlink megaconstellation recently adjusted its satellite’s orbits in an attempt to limit debris-related hazards⁽¹⁷⁾ after reporting more than 300,000 avoidance manoeuvres in 2025^(1b). The recognition of risk within the industry is reflected in the proposed EU Space Act’s Impact Assessment reporting, where 84% of industry stakeholders contacted by the European Commission believed that the increase in space activity calls for specific requirements and guidance^(9b), and 79% of respondents said that they do not believe current national space laws are fit to ensure the safe and long term use of space^(9b).

2.2 The Fragmentation of International Standards

Space law and regulation was originally designed to negotiate between state actors, and national frameworks for debris mitigation reflect this origin^(18a). International standards have developed from non-binding interagency agreements into ‘soft-law’ guidelines^(18b). In the UK, for example, regulators defer to international guidelines such as the Inter-Agency Space Debris Coordination Committee (IADC) guidelines on debris considerations^(14a), and the technically prescriptive BS ISO 24113^(12)(14a) for debris mitigation planning. A lack of international governance on space debris has resulted in fragmented national regimes. Table 1 illustrates the extent of  fragmentation across EU Member States, showing how soft law guidelines have yet to be fully translated to legally-binding standards at the national level. 

Table 1: ‘Overview of Member States with space laws on safety and environmental requirements’ - EU Space Act IA Report ^(9c)

	BE	DK	EL	FR	LU	NL	AT	PT	SI	SK	FI
General Reference to International Standards/Guidelines for Space Debris Mitigation	x						x	x		x	x
Specific Reference to In-Orbit Collision Avoidance Measures				x			x	x			x
Requests Operator to Make Appropriate Provision for Space Debris Mitigation with Few Specifications		x	x				x	x	x	x	x
Detailed Measures for Space Debris Mitigation				x
Limit on Orbital Lifetime (25 Years)		x		x			x
Requires an Environmental Impact Assessment of Space Activity Under National Law	x	x	x	x							x
General Condition that Space Activities Do Not Cause Adverse Changes to the Environment							x		x	x

Given the transboundary nature of the orbital environment, fragmentated regulation produces an asymmetric compliance burden. Operators in jurisdictions with higher standards of practice bear greater compliance costs while remaining exposed to debris generated under lenient regimes. Space debris therefore presents as a classic tragedy of the commons, a scenario common in sustainability matters such as climate change, where benefits to an individual come at a diffused cost to the wider community. In the UK fragmentation is present at the national scale. ESA has formally adopted the ISO 24113 standards into its requirements for ESA agency projects(19), meaning that operators of ESA funded projects in the UK are held to this standard while those of privately funded projects are deferred to them as voluntary guidelines(14b).

2.3 The Cost of Inaction 

The global commons character of space limits the scope for market-driven solutions for regulating debris generation. Debris risks accumulate over time and are distributed across jurisdictions, while the absence of international enforcement mechanisms means operators cannot be held accountable for their contribution to aggregate debris risks. The responsibility to assign and enforce accountability therefore falls upon individual nation states and their regulators.

Operator behaviour illustrates that market incentives alone are insufficient to drive adequate debris mitigation practice. Despite undertaking more than 300,000 avoidance manoeuvres in 2025 alone^(1b) Starlink is expanding rapidly, reaching the 10,000-satellite benchmark as of March 2026^(1a). This single megaconstellation constitutes two thirds of all satellites currently in orbit^(1a). Adding to this, competitors are emerging: Shanghai SST’s Qianfan is aiming to launch a total of 15,000 satellites by 2030⁽²⁾, and US based Amazon Leo is planning a constellation of 3,236 by 2029⁽²⁰⁾.

The consequences of this proliferation are already materialising, SpaceX reported a near miss with one of its satellites⁽²¹⁾ and a Chinese satellite, and in 2024 a failed launch led to the uncontrolled re-entry of a Starlink satellite that generated a 2.5kg piece of debris which landed on a farm in Canada⁽²²⁾. These incidents demonstrate that the costs of megaconstellation growth are not borne solely by the operators responsible, or even operators as a community, nor are the increasing collision risks discouragement enough to prevent further rapid expansion.

The economic exposure to debris-related risks is significant. The WEF estimates that under a business-as-usual scenario with no Kessler events triggered, orbital debris could generate between $25.8 billion to $42.3 billion in cumulative losses to the global space economy between 2025-2035^(7b). The OECD gives an estimate of the downstream economic exposure, placing the value of global economic activity at risk from space debris at $191 billion⁽²³⁾. Against this backdrop, the EU has attempted to quantify what effective debris mitigation could save the European space industry.

The European Commission's Impact Assessment for the draft EU Space Act models an illustrative scenario in which total space debris is reduced 50% by 2034, concluding that under these conditions the EU space industry could avoid losses of an estimated €6.998 billion over a ten-year period^(9a). While at first this seems modest compared to global exposure, it is important to differentiate between downstream and upstream industry. The upstream European space industry, the manufacturers and operators most directly affected by debris mitigation regulation, represented ~€5 billion in annual market value in 2023, around 10% of the global upstream market^(9d). The estimated avoided losses of €6.998 billion represent more than the entire value of the EU upstream space industry’s 2023 valuation, a substantive potential gain for the sector even if modest relative to the global space economy. Table 2, taken from the Impact Assessment Report, breaks down the components of the projected savings.

Table 2: Projected benefits from the draft EU Space Act IA Report based on Roland Berger consulting support^(9a)

Europe	Collision Avoidance Manoeuvre Reduction (Yearly)	Impact Over Time (10 Years)	Indicative Economic Effect in EUR Billion (10 Years)	Annualised Economic Effect in EUR Million
779 Satellites in LEO	516	302 Total Years of Mission Lifetime Extensions	6.874	662.15
26 Satellites in EO	18	183 Days of EO Data Gain	0.003	0.325
145 Satellites in GEO and MEO	15	11 Total Years of Mission Lifetime Extensions	0.121	12.325
Total	549		6.998	675

If potential debris harm is realised, the cost would not only be on operators through mission loss, insurance, and avoidance measures, but ultimately on governments through degraded infrastructure, and the public through service disruption. Although the Commission's figures are focused on the European market, the cost categories are characteristic of debris hazards and therefore universal to space operators. Notably none of the figures provided in this section account for tipping point scenarios that could escalate debris risks beyond current modelling.

Given the inability of current market mechanisms to drive adequate debris mitigation, and the scale of economic exposure as illustrated above, the design and approach taken by regulators is crucial in determining whether debris risks are effectively mitigated or escalating out of control.

3 The Two Approaches 

The UK’s ALARP framework and the proposed EU Space Act represent fundamentally different approaches to debris mitigation compliance. This section compares them across five dimensions, revealing the opposing compromises made by the two regimes across two underlying tensions: certainty and flexibility of regulation, and isolation and integration of debris mitigation. These compromises shape operator experiences, compliance costs, and how each regime approaches emerging technologies.

Both frameworks draw on international standards, and a common suite of regulatory tools. These include behavioural restrictions such as orbital lifetime limitations, which cap how long a satellite may remain in orbit after its operational life; technical requirements such as passivation, the process of removing stored energy from a spacecraft to prevent accidental explosions that generate debris; and collision avoidance obligations, which govern how operators must respond to conjunction warnings. The two different approaches to utilising these tools and standards is what shapes the compliance architecture of each regime. For example, the frameworks differ in how they treat emerging technologies such as Active Debris Removal (ADR), the collection and removal of debris by spacecraft, and In-Space operations and Services (ISOS), which involves in-situ servicing, maintenance, and repair of satellites. The draft EU Space Act empowers the Commission to regulate ADR and ISOS through delegating acts as the technologies mature. The UK regime handles them through regulatory sandboxing⁽²⁴⁾ and case-by-case licensing assessments^(15d).

Table 3 summarises where the proposed EU Space Act differs from the UK regulatory regime; each dimension is examined in detail throughout this section.

Table 3: A Summary of the comparison of the EU and UK regulatory approaches

Dimension	EU Space Act	UK ALARP Framework
Summary:	Harmonises national regulation at the bloc level, building on international norms to define prescriptive standards through future implementing acts. Provides clarity in regulatory direction through timelines, with debris mitigation as a stated priority.	Preserves flexibility and proportionality that supports innovation and novel missions, but produces uncertainty that burdens operators. Debris mitigation is largely addressed through voluntary international standards and assessed on a case-by-case basis.
Regulatory Approach	Prescriptive, technically specific, mandatory measures	Principles led, ALARP, case-by-case assessments(15d)
Compliance Requirements	Prescriptive technical thresholds. 3 mandatory plans for spacecraft operators(10b) Debris Control Plan End-of-Life Disposal Plan Failure Response Plan 3 mandatory plans for launchers Debris Control Plan End-of-Life Disposal Plan Failure Response plan as a subcomponent of the End-of-Life Plan(10g) Environmental Footprint Declaration	Flexible technical thresholds:(22)(24) For spacecraft operators: Technical Question Set(15a,b,c) Debris Mitigation Plan(14b) End-of-Life Plan(28) Assessment of Environmental Effects(25) (Discretionary) Safety Case(27) (Conditional for orbital operators, required for novel or complex missions(15b)) For launch operators: Launch Collision Avoidance Analysis (LCOLA)(26) Safety Case(27) Assessment of Environmental Effects(25)
Debris Mitigation Tools	Disposal plan, passivation requirements, EU Space Surveillance and Tracking (SST) subscription(10d)	Debris Mitigation Plan(14b). Mandatory end-of-life plan(28). Deference to international guidelines under Space Industry Act(11)(14a).
Incentives	Space labelling scheme(10e), an optional certification for higher standards of practice. Designed to provide proportionality to SMEs	No formal incentive mechanisms. BSI Flex Standards may encourage greater mitigation measures if used by operators to support licensing compliance.
Timeline	Pre-implementation phase (2025–2029)(10f): A transitional period during which the act undergoes legislative procedure to determine revisions and amendments through negotiation. Implementation (2030–2032)(10f): Legal implementation with a two-year transitional period involving special conditions for exceptions.	Ongoing regulatory development (2025–2029)(24)(29)(30)(35): Continued reliance on principles-based regulation and case-by-case licensing, with adjustments introduced incrementally.
Costs	Higher direct costs through higher greater compliance requirements, long-term benefit assumed based on modelling(9a)	Costs incurred through protracted or failed licensing processes resulting from unclear compliance requirements.
Support for Small and Medium Enterprises	Clear support mechanisms, high burden	Flexible but potentially uncertain, especially for SMEs
Global Positioning	Aims for global leadership	Aims for competitiveness through flexibility

3.1 Regulatory Philosophy: Prescription vs Principles

In determining compliance requirements, the draft EU Space Act takes a prescriptive approach, establishing their scope and empowering the Commission to determine technically specific baseline requirements over time through future implementing acts^(10a). The UK regime adheres to As Low As Reasonably Practicable (ALARP) principles^(15d) where compliance is assessed on a case-by-case basis.

The proposed EU Space Act would establish harmonised regulatory standards at the bloc level, consolidating regulation for debris mitigation into a single framework. The Space Act intends to build on international standards, replacing non-legally binding guidelines with legally binding requirements subject to the EU oversight^(9e). Its mechanism for flexibility comes in the form of implementing acts that empower the Commission to specify and expand technical requirements in the future, without the need to reopen the legislative procedure^(10a). The potential strength of this framework is certainty, where prescriptive requirements provide the clarity needed for operators to have confidence in their compliance, long-term mission planning, and estimated compliance burdens.

The UK approach requires operators to demonstrate through case-by-case licensing assessments^(15d) that the risks associated with their activities have been reduced to a point where the benefits of further mitigation would be disproportionate to its cost. This is referred to as the principle of As Low As Reasonably Practicable (ALARP)^(15d) where risks are categorised across three ranges, broadly acceptable, tolerable, and unacceptable. Debris risk is explicitly stated as a potential disqualifier as part of the ALARP assessment if high enough^(15d), though there is no guidance on how it might be weighed against its compliance burdens, or trade-offs with other environmental and operational risks. The strength of this framework is flexibility, where operators can justify their risk case without being held to inflexible benchmarks.

3.2 Debris Mitigation Architecture: Standardised Vs Deferred

The two frameworks differ fundamentally in how they structure debris mitigation compliance. The proposed EU Space Act aims to set prescriptive standards, with spacecraft operators demonstrating debris mitigation compliance through three standalone plans that cover the full mission lifecycle^(10b). By contrast, the UK addresses debris mitigation discretionally through open ended submissions. For spacecraft operators, the primary debris mitigation submission is a Debris Mitigation Plan subordinated within the Technical Question Set, for which the CAA provides no structure, opting instead to refer operators to ISO 24113^(14a,b). The difference in how debris mitigation submissions are structured and assessed determines whether compliance standards are consistently applied across licensing applications and how effectively mitigation outcomes can be assessed.

The proposed EU Space Act structures its debris mitigation compliance as three mandatory plans, which cover the full mission lifecycle. These include a Debris Control Plan applicable to both spacecraft and launch vehicles, an End-of-Life Disposal Plan for spacecraft and launchers, and a standalone Failure Response Plan for spacecraft operations^(10b). While elements of each exist within the regimes of several Member States, the proposed Act formalises them as distinct and mandatory within a single framework. Operators will also be required to produce an assessment of the environmental footprint of the activities being authorised, an ‘Environmental Footprint Declaration (EFD)^(10h)’. The datasets used in calculating the EFD will be retained in a single database, used to inform policymaking and regulatory reforms. The Commission intends to use future implementing acts to specify the methods for calculation and verification of this assessment. These will be drawn from a sector specific adaptation of the EU’s existing Product Environmental Footprint methodology, the PEFCR4Space⁽³⁸⁾. Beyond the three mandatory debris plans and EFD reporting, operators will be required to subscribe to the EU Space Surveillance and Tracking (EU SST)^(10d), a service that supports collision avoidance and debris monitoring, to build situational awareness at the sector level.

Within the UK’s framework, the structure of debris mitigation submissions varies by license type. For launch operators, the LCOLA⁽²⁶⁾ addresses collision risk during the launch trajectory, without a dedicated submission addressing orbital debris risks that may result from late-stage launch activities. For spacecraft operators, the primary submission is a Technical Question Set^(15a) covering sustainability, safety and security. The most relevant submission for orbital debris is the Space Debris Mitigation Plan^(14b) required as part of the Technical Question Set⁽¹⁴⁾. The plan is expected to demonstrate compliance with debris mitigation requirements presented in national regulation, with the CAA referring operators to the standards and structure suggested by ISO 24113^(12)(14b). This is where the UK regime's deference to international standards is most prominent. While the content of ISO 24113⁽¹²⁾ lays out technically prescriptive thresholds and standards, under the UK framework they are non-binding requirements. As such, case-by-case licensing assessments leave room for justifications of non-compliance^(15d) in accordance with ALARP.

Licensing materials released by the CAA come in the form of guidance that occupies a legal middle ground. While industry-specific case studies are lacking, those involving other domains show that when contested in court, guidance is expected to have been considered and adhered to unless ‘cogent’ justification is provided for not doing so⁽⁴³⁾. This is reflective of the CAA’s case-by-case ALARP approach and allows the regulator to retain flexibility over the application of requirements. Not only does this contrast with the EU’s prescriptive approach, it is unique among comparable legal traditions. Both New Zealand and Australia require debris mitigation submissions with prescribed content as part of their licensing applications⁽⁴³⁾.

Table 4 lays out the debris mitigation relevance of each of the UK’s licensing submissions across both license types.

Table 4: the content of the submissions required of operators by the CAA for licensing applications

Submission	Purpose	Debris Mitigation Relevance
Safety Case(27)	Demonstrates risks to people and property are ALARP.	Indirect, may include debris risk if it could endanger other space objects or public safety. Required as standard for launch operators. Conditional for orbital operators of novel and/or complex missions.
Assessment of Environmental Effects (AEE)(25)	Evaluates localised terrestrial and atmospheric environmental impact during a mission’s launch phase.	Minimal, focuses on the local environment. Mandatory for launch and spaceport operators. Discretionary for orbital operators.
Launch Collision Avoidance Analysis (LCOLA)(26)	Screens launch trajectory for potential collisions with existing objects.	Direct, mitigates immediate launch-phase collision risk.
Technical Question Set(14)	Primary Sustainability Assessment for orbital operators. Covers all mission phases.	Direct, addresses debris mitigation compliance through the Space Debris Mitigation Plan. Refers operators to the IADC guidelines and the BS ISO 24113(12).
End-of-Life Plan(28)	Ensures operators maintain and carry out end-of-life disposal throughout the licensing period.	Direct, mandatory for orbital operators as part of the Technical Question Set(28).

Deference to international standards allows the UK regime to retain flexibility in its assessment of debris mitigation compliance by keeping technically prescriptive standards as non-legally binding guidelines. The risk of this approach is that these standards can be applied inconsistently. If international standards can be routinely deviated from through case-by-case justifications, aggregate assessment of the UK’s debris mitigation approach may be complicated by a lack of standard practice. This would make it difficult for the UK to demonstrate the efficacy of its regulatory regime to a global market, undermining attempts to establish the national space industry as an international leader of sustainable practices.

3.3 Operator Experience and Compliance Architecture 

The compliance architectures of the two frameworks shape operator experiences in different ways. The draft EU Space Act, currently in pre-implementation phase, aims to provide ex ante clarity so that operators will know in advance what compliance requires. The goal of such clarity is to support long-term planning, insurability, and investment within the EU space sector. Based on the Commission's own projections, this is anticipated to create higher upfront compliance and manufacturing costs that disproportionately affect SMEs^(9f). Already in force, the UK’s principles-based approach provides flexibility, but produces uncertainty. Operators must construct and justify their own risk profiles without formal benchmarks, and industry feedback indicates that this results in extended licensing timelines and increased planning risks^(24)(35). This uncertainty is most harmful for SMEs and operators of novel missions where the lack of precedent adds to the challenge of demonstrating ALARP compliance^(24)(31).

3.3.1 The EU: The Cost of Certainty

The draft EU Space Act’s technically prescriptive requirements are projected to result in increased compliance burdens for operators and manufacturers. According to the European Commission’s Impact Assessment, manufacturing costs are expected to rise by between 3%-10%^(9f), with the upper end of this range being most applicable to SMEs^(9f). These increased costs are attributed to the technical and design requirements needed to achieve debris mitigation, safety, and security compliance.

Table 5 summarises what the annual costs to operators anticipated from the proposed EU Space Act are, projecting aggregate annual costs to the EU space industry of approximately €323 million^(9g).

Table 5: Annual costs of the proposed EU Space Act according to the European Commission's own Impact Assessment Report^(9g)

Cost Category	Annual Cost (to Operators)
Compliance costs	€136 million annually (about 1% of annual turnover of upstream + midstream)
Manufacturing cost increase	€180 million annually (due to higher technical requirements)
Private overhead	€2.4 million annually
Administrative overhead	€4.4 million annually
Total (all operator costs)	€322.8 million annually

While these costs seem large in absolute terms, they should be understood as the price of the clarity and certainty that the draft EU Space Act provides, and as will be examined in section 3.5, the European Commission projects benefits from the regulation that offset these extra costs. The desire for clarity is reflected in operator feedback. When surveyed by the Commission 84% of operators called for specific requirements in space safety regulation that 83% tied to increased activity, while 79% said that current regimes were insufficient^(9b).

To support proportionality for smaller operators, the proposed EU Space Act commits to a Space Labelling Scheme^(10e). This would take the form of optional certifications for higher standards of practice, aimed at providing incentives without imposing additional mandatory burdens on SMEs. The Act also differentiates between single satellite and constellation applications and includes a tiered system for constellation size separating them into Constellation (10-99 spacecraft), Megaconstellation (100-999), and Gigaconstellation (1000+)⁽¹⁰ⁱ⁾. For constellation operators this tiered system includes a single authorisation pathway, which the Commission projects could save operators €68 million over a decade^(10j).

3.3.2 The UK: The Cost of flexibility

The UK’s ALARP principles-based framework ensures flexibility through case-by-case licensing assessments^(15d). The framework requires operators to justify their risk case within their compliance submissions, and acceptability is determined through the licensing process rather than being defined in advance^(15d). Industry feedback indicates that this flexibility comes at a cost. The 2024 Space Regulatory Review⁽³¹⁾ found that definition of 'acceptable' within the Space Industry Act 2018⁽¹¹⁾ in reference to ALARP was 'considered unclear and subjective' by industry, with this uncertainty adding 'costs, time and delay for applicants negotiating the licensing process'. The UK’s recent 2025 Regulatory Sandbox for Rendezvous and Proximity Operations⁽²⁴⁾ also found that operators experienced limited clarity around approvable standards and difficulty navigating licensing processes. The House of Lords released a report in 2025 on national space sector competitiveness that reiterated these concerns, calling for greater regulatory clarity and a stronger strategic direction⁽³²⁾. The Government’s January 2026 response to the House of Lords further acknowledged the need to deliver ‘clarity, certainty, and confidence’ for operators⁽³⁵⁾ echoing the sandbox and regulatory review.

The UK regime has acknowledged this feedback and is responding incrementally. The British Standards Institution has published two BSI Flex standards⁽²⁹⁾. One sets out overarching principles for space sustainability^(29a), and the other provides detailed guidance on launch-specific orbital and suborbital environmental considerations^(29b). These standards are voluntary and intended to mature into industry benchmarks, they are not intended to be converted into legally binding compliance requirements that the CAA has ownership of. The integration of the UK Space Agency into DSIT signalled a similar intention to improve regulatory efficiency⁽³⁰⁾ though its implications for the UK’s regulatory capacity are uncertain. Most recently, the CAA released its Spaceflight Regulatory Objectives⁽³⁴⁾, which are intended to clarify to operators how the regulator undertakes assessments of licensing submissions for space activities. Notably, the objectives for orbital operators are lacking a section on environmental objectives. Instead, environmental concerns appear under a single safety objective, stating that applicants must make appropriate consideration for the sustainability of the orbital environment. The CAA is clear that these objectives are not intended to be used as a checklist for licensing applications, and that they support rather than replace case-by-case regulatory judgement. All these developments demonstrate the UK's adaptive character. So far, it remains unclear whether the rate and scale of incremental reform is sufficient to keep pace with the sector's development and its coinciding debris risks.

3.4 Emerging Technologies: ADR and ISOS 

The draft EU Space Act and the UK’s ALARP framework accommodate emerging technologies in the sector such as Active Debris Removal (ADR) and In-Space Operations and Services (ISOS) through distinct regulatory mechanisms. The draft EU Space Act empowers the European Commission to regulate these technologies through future delegating acts^(10c), placing them within the scope of regulation and signalling license availability to operators. The UK framework formally includes both in its regulation, approaching them through case-by-case assessment and regulatory sandboxing⁽²⁴⁾, preserving flexibility and developing regulation in dialogue with the industry as capabilities evolve.

3.4.1 The EU: Codified Ambitions 

In its current form, the draft EU Space Act includes ADR and ISOS within its regulatory scope, empowering the European Commission to regulate these technologies through delegating acts as capabilities evolve^(10c). This provides operators with a regulatory trajectory, signalling that these technologies will be brought into the compliance framework, even before the technical standards to do so have been developed. The timeline for ISOS reflects the European Commission’s recognition that these technologies will take time to mature before such standards can be set^(10f).

This codified ambition has a genuine advantage. Operators and investors in ADR and ISOS can anticipate the direction of regulation without knowing the specific requirements, reducing uncertainty that typically surrounds emerging technology in the market. The risk is that delegating acts rely on the European Commission keeping pace with technological development. If they fall behind, the proposed EU Space Act could constrain technologies prematurely or leave certain activities outside of regulation.

3.4.2 The UK: Adaptive but Undirected 

The UK’s orbital operator licensing framework formally includes ADR and ISOS, though it develops regulation for them through regulatory sandboxing⁽²⁴⁾ and bespoke licensing conditions^(15d), allowing novel missions to operate without being held to fixed benchmarks that might be unfit for purpose. The 2025 Regulatory Sandbox for Rendezvous and Proximity Operations⁽²⁴⁾ is a concrete example. It provides a structured environment for operators to develop and test the compliance of novel mission architectures in collaboration with regulators. Operator feedback from the sandbox indicates that while flexibility is valued, there was difficulty in navigating the regime's unclear requirements for novel missions⁽²⁴⁾.

The limitation of this approach is not in current practice but in its lack of a defined direction. While ADR and ISOS are included in the UK’s orbital operator licensing scope, there is no formal trajectory for how and when the UK regime will develop standards and requirements for ADR and ISOS as they mature. Sandboxing is a useful mechanism for immature technologies but without a defined regulatory direction and timeline, the UK’s approach remains reactive and fails to signal a strategic direction to operators(32)(35). At present, the adaptive regulatory processes of the UK are irregular and unpredictable. A consistent and outlined approach to regulatory reform would build patterns of feedback into these adaptive processes so that the CAA could effectively maintain a tacit and up to date understanding of industry needs, ensuring that regulation keeps pace with technological development.

3.5  Costs, Benefits, and Limits

The EU and UK regulatory frameworks for space activities have different economic profiles. The European Commission has modelled both the projected costs and benefits of the draft EU Space Act in detail^(9g), while the UK’s approach makes equivalent modelling difficult. Without a consistent standard for compliance, the UK may not be able to demonstrate whether the costs its regulatory approach incurs on operators is justified by the sustainability outcomes it produces.

3.5.1 The Draft EU Space Act: Projected Costs and Benefits

The European Commission’s Impact Assessment projects that the proposed EU Space Act will generate annual benefits of approximately  €1 billion to EU space operators, overshadowing the €322.8 million compliance cost examined in 3.3.1^(9g). These benefits are derived primarily from the reduced collision avoidance manoeuvres, extended satellite lifetimes, and improved operational resilience.

Table 6: Summary of Commission’s estimates of annual benefits associated with  the proposed EU Space Act^(9g) under an illustrative 50% total debris reduction scenario.

Benefit Category	Estimated Annual Benefit
Operational benefits (e.g. extended mission lifespans)	€674 million
Resilience benefits (e.g. cyber risk)	€320 million
Regulatory simplification benefits	€6.3 million
Total benefits	€1,000.8 million (≈ €1.00 bn)

These projections are based around a central assumption. The European Commission bases the annual benefit figures on a scenario where total space debris is reduced by 50% between 2024 and 2034^(9a). This assumption is derived from unpublished consultations and workshops rather than publicly available calculations or modelling^(9a), which limits the confidence with which it can be treated as a forecast rather than an illustrative scenario. The benefit projections are better understood as indicative of the potential gains available from effective debris mitigation, rather than precise predictions.

3.5.2 The UK: Low Burden, Uncertain Outcomes

The UK’s principles-led approach carries a lower upfront cost than the EU framework as ALARP as case-by-case assessment^(15d) accommodates proportionality by design. As established in 3.3.2 however, the flexibility of the UK framework generates its own indirect costs. Operator feedback indicates that uncertainty around acceptable standards translates into extended licensing timelines, application revisions, and increased planning risk^(24)(31). These are costs that are harder to quantify but no less real than the EU’s upfront compliance burden.

Unlike the EU, which has attempted to project benefits of defined objectives^(9g), the UK’s regime provides no equivalent aggregate cost-benefit projections for debris compliance. As such, the question of whether its compliance measures are succeeding may prove difficult to answer as a consequence of its flexible licensing assessments.

4 The Limits of Each Approach

The compromises made by the UK regime and the proposed EU Space Act produce two identifiable gaps where neither regulatory approach meets the challenge of space debris mitigation. Compromising on certainty and flexibility creates disproportionate debris mitigation burdens for SMEs and operators of novel missions. Compromising on the isolation and integration of debris mitigation leaves each regime unable to pre-emptively respond to systemic risks. This section examines those consequences in turn.

4.1 Regulatory Certainty vs. Flexibility

Clarity and certainty surrounding compliance requirements and licensing processes is necessary to enable long term planning and compliance budgeting for operators. At the same time, such requirements and processes must remain flexible enough to adapt to the changing industry landscape of a rapidly developing space sector. The EU approach prioritises certainty at the cost of flexibility, the UK prioritises flexibility at the cost of certainty. Neither compromise is totally successful, and the consequences for each are felt most by SMEs and operators of novel missions.

4.1.1  The EU’s Certainty

The draft EU Space Act proposes harmonised technical standards, mandatory lifecycle^(10b) plans, and a defined implementation timeline^(10f), giving operators a clear picture of future compliance requirements that supports long-term planning, insurability, and investment. Implementing acts further provide a mechanism for adapting requirements as technologies evolve, without reopening primary legislation^(10a).

Prioritising certainty comes at the risk of inflexibility. The prescriptive approach could prematurely constrain emerging technologies by codifying requirements before the technical landscape has matured. Alongside this, the increased compliance and manufacturing burden, projected at up to 10% of manufacturing costs for SMEs^(9f), imposes fixed obligations that fall disproportionately on smaller industry players, for whom such costs can create barriers to market entry. The Space Labelling Scheme does offer some proportionality, though this is an optional measure, rather than a result of proportionality being built into the draft EU Space Act’s regulatory approach^(10e).

4.1.2 The UK’s Flexibility

The UK prioritises flexibility. Case-by-case ALARP assessments allow novel missions and emerging technologies to be licensed without being held to fixed benchmarks that may be unsuitable for their unique mission characteristics and risk profiles^(15d). This preserves the adaptability that SMEs and novel missions require, and allows for regulation to develop iteratively alongside the industry.

Prioritising flexibility this way has, in practice, led to uncertainty. The absence of nationally developed and legally-binding standards means operators must construct and justify their own risk case without such baselines, and industry feedback shows that this produces uncertainty around what constitutes compliance^(31)(35). An uncertainty compounded by the legal middle ground status of regulatory guidance⁽⁴³⁾. The 2025 Regulatory Sandbox⁽²⁴⁾ findings show that this uncertainty is particularly impactful for operators of novel missions, leading to extended licensing timelines and added compliance costs. The BSI Flex Standards⁽²⁹⁾ and recently completed UKSA-DSIT integration⁽³⁰⁾ reflect an acknowledgement of the uncertainty experienced by operators, but being voluntary and institutional measures respectively, they do not structurally address the uncertainty imposed on operators by the UK’s regulatory approach.

The Spaceflight Regulatory Objectives⁽³⁴⁾ clarify what objectives the CAA looks for applications to achieve as well as the processes and deliverables it uses to assess them. The objectives themselves however remain conditional, intended to support rather than replace case-by-case assessment, and entirely subordinate to requirements outlined in policy and regulation. What constitutes acceptable practice remains determined through the assessment itself, with each objective graded Satisfied, Satisfied with Conditions, or Not Satisfied. The CAA’s objectives give clarity around the process of application assessment, but fall short of providing the clarity of acceptable practice that industry feedback has called for.

4.1.3 The Consequence

The consequences of compromising either flexibility or certainty are felt most acutely by SMEs and operators of novel missions, both of which are often considered a driving force behind the future development of the space industry. Under the proposed EU Space Act, fixed compliance and manufacturing costs could create barriers to entry that fall disproportionately on smaller operators, for whom the same absolute costs represent larger upfront burdens. The Space Labelling Scheme recognises this issue, but the Space Act’s core compliance burdens are currently uniform^(10e). Under the UK framework, the absence of legally binding standards generates uncertainty that translates into extended licensing timelines and planning risk^(24)(31), costs that fall disproportionately on novel missions, where the lack of precedent compounds the difficulty of demonstrating compliance with ALARP.

The result is that both frameworks, despite compromising on the certainty-flexibility balance in opposite directions, converge on similar outcomes for the industry's most innovative actors. They create a regulatory environment either too costly or too uncertain to navigate efficiently. Neither framework establishes a regime with both the certainty to support planning and the flexibility to support innovation, and the cost of this failure is borne by the industry.

4.2 Isolated vs. Integrated Debris Mitigation

Both the UK regime and draft EU Space Act fail to resolve the tension between making debris mitigation visible and accountable as a priority, while integrating it with wider operational and environmental considerations. How submissions are structured determines whether debris mitigation is signalled as a priority, and how it is assessed against its broader sustainability or operational trade-offs. The EU frames debris mitigation as a clearly defined priority for sustainability, structuring compliance through three standalone plans^(10b). Without integrating these plans into an environmental assessment framework however, isolating debris considerations this way has the potential to obscure the environmental and operational trade-offs they involve. The UK framework structures debris mitigation across submissions such as the LCOLA⁽²⁶⁾, end-of-life plan⁽²⁸⁾, and Debris Mitigation Plan^(14b). Subordinating debris submissions the way this structure does under-signals debris mitigation as a regulatory priority, and fails to weigh debris considerations against their wider environmental and operational impacts. 

4.2.1 The EU: Visibility Without Integration

Through its three mandatory plans for spacecraft operators (the Debris Control Plan, End-of-Life Disposal Plan, and Failure Response Plan^(10b)), the EU regime frames debris mitigation as a distinct priority across the full mission lifecycle with clear compliance expectations. This gives operators a clear picture of what debris compliance requires, and gives regulators defined criteria against which to assess licensing submissions. Mandatory subscription to the EU SST further enhances debris mitigation at the sector scale through collision avoidance^(10d). What the EU approach does not achieve is the integration of debris mitigation within a wider sustainability framework. Standalone plans risk compliance requirements becoming isolated from their wider trade-offs if debris considerations are assessed separately from submissions where their impacts are expressed.

Debris mitigation can affect fuel budgets, space traffic distributions, and mission characteristics in ways that a standalone submission may not fully accommodate. For instance, fuel allocated to meeting collision avoidance requirements reduces the fuel available for operational manoeuvres. This in turn shortens the usable lifetime of the satellite, leading to a higher rate of replacement that itself carries environmental impacts associated with launch and re-entry. Where these first and second order impacts may be accounted for in application approval decisions is unclear, though the most likely candidate is the Environmental Footprint Declaration.

The draft EU Space Act includes five articles^(10h) detailing requirements for operators to carry out an environmental footprint assessment and submit an Environmental Footprint Declaration, alongside a certificate of verification. In their current form the articles do not mandate that the content of the EFD determines or informs the approval of an application beyond the methods of its production, framing it instead as a reporting requirement. The EU Commission is currently developing the PEFCR4Space⁽³⁸⁾, an adaptation of a life cycle analysis methodology employed as a reporting requirement in other EU industries. This reinforces the EFD’s role as the disclosure of an application's environmental effects, rather than an assessment of their acceptability. The datasets produced for this submission by operators will be incorporated into an aggregate database, used to inform future policy and regulatory reform. Structured in this way, the EFD does not evaluate how environmental and operational impacts can be weighed against each other in order to inform the approval process. If the EFD data does reveal systemic risks or unintended environmental impacts this information is responded to reactively, after the approval process.

4.2.2 The UK: Integration Without Visibility

The UK’s regulatory framework addresses debris mitigation with a broader set of licensing submissions that differ across license types and mission phases. For launch operators, debris considerations are included across the Safety Case⁽²⁷⁾, LCOLA⁽²⁶⁾, and AEE⁽²⁵⁾, where regulators can, in part, evaluate them within the wider context of environmental and operational trade-offs. For orbital operators, debris mitigation is addressed primarily through the Space Debris Mitigation Plan^(14b) and the end-of-life plan⁽²⁸⁾ subordinated within the Technical Question Set^(15a) with additional assessments applied discretionally^(15b). The Space Debris Mitigation Plan^(14b) is an open-ended submission for which the CAA refers operators to ISO 24113⁽¹²⁾ for its structure and technical requirements.

What this structure fails to provide is a clear signalling of debris mitigation as a regulatory priority. Its fragmentation across submissions and reliance on non-binding international standards means that debris mitigation in the UK regime lacks clearly defined requirements and risks sustaining inconsistent standards of practice. Without a licensing submission that consolidates debris considerations across the full mission lifecycle with clear and legally-binding baseline requirements, debris mitigation cannot be assessed with the consistency needed to evaluate whether the regime is producing adequate sustainability outcomes. Integrating such a submission within a wider environmental assessment framework could allow the trade-offs from debris mitigation to be appropriately assessed and provide guidance on how environmental and operational effects are weighted against each other.

4.2.3 The Consequence

The consequence of assessing debris mitigation without integrating it into a broader environmental assessment framework extends beyond individual licensing outcomes. The EU risks blinding itself to system-level environmental impacts that may emerge from debris mitigation practices by evaluating debris considerations in isolation from the operational or environmental trade-offs they involve. This leaves the regime vulnerable to regulatory decisions that resolve one harm while inadvertently worsening another, leading the EU industry away from genuine sustainability. The collection of datasets used for EFD submissions into a database intended to inform policymaking and regulatory reform may allow for course corrections that mitigate systemic risks long-term, but it does so reactively. Trade-offs are responded to after they have happened rather than pre-emptively, as an integrated environmental assessment that informs approval decisions would enable. For a non-linear risk like space debris, producing licensing processes that can act pre-emptively to emerging risks will be crucial.

Without baseline requirements within a standalone debris mitigation submission, the UK regime fails to signal debris as a regulatory priority and cannot assess whether its licensing regime is producing adequate sustainability outcomes at scale. Where international standards may be inconsistently applied, there is no consistent unit of measurement against which mitigation outcomes can be compared across missions. This is compounded by the absence of formal structure or prescribed methodologies within submissions, a mechanism intentionally deployed by the draft EU Space Act to enable aggregate assessments that inform regulatory reforms. The CAA has built a regulatory structure that lacks a common baseline, and may be unable to identify systemic risks, justify policy change with evidence, and demonstrate to international partners that the UK’s principles-led approach is producing the sustainability outcomes necessary for tackling the challenge of space debris.

5 Recommendations for the UK

Drawing on the analysis undertaken in Sections 3 and 4, this section sets out four recommendations for the UK regulatory regime. Each recommendation aims to take insights from the EU approach and target specific weaknesses in the UK framework.

Recommendations 1 and 2 address the UK regime’s uncertainty by introducing clear compliance expectations and a regulatory trajectory, repositioning case-by-case assessment from the default mechanism to an exception reserved for novel or exceptional circumstances. Recommendations 3 and 4 seek to elevate debris mitigation to a distinct regulatory priority within the UK regime without undermining ALARP’s holistic advantages, integrating it within a broader assessment framework to ensure that trade-offs involved in debris mitigation are systematically identified and weighed against each other.

5.1 Recommendation 1: Establish Clear Baseline Expectations Within the ALARP Framework

The absence of clear baseline expectations produces uncertainty that burdens operators and extends licensing timelines. While current debris mitigation plans rely on international standards set by the IADC and ISO 24113^(13)(14,a,b), operator feedback shows that these are an insufficient anchor to provide operators with certainty and clarity about compliance requirements^{(24)(31)(32)(35)}. The BSI Flex standards⁽²⁹⁾ represent a step toward resolving this uncertainty, providing reference material for ALARP compliance. However, as voluntary guidance that sits outside of the licensing framework these standards do not address the inherent uncertainty that the CAA’s regulatory approach creates. Meaning that even if the BSI Flex standards⁽²⁹⁾ successfully resolve current uncertainties, they still leave the regime open to new ones in the future. Similarly, the recent Spaceflight Regulatory Objectives⁽³⁴⁾ clarify licensing processes rather than compliance requirements, requiring applications for orbital operations to make ‘appropriate consideration for the sustainability of the orbital environment’ without defining what ‘appropriate’ means. Such language echoes the ‘acceptable’ terminology directly named in industry feedback as producing uncertainty. While in line with their role as objectives, this does not address the uncertainty produced by the regime on a structural level. Ultimately, even the guidance produced by the CAA itself sits within a legal middle ground⁽⁴³⁾ that leaves the standards it defers to without the clear legal status that formal baseline requirements would provide.

This recommendation argues for the formal adoption of presumed baseline standards into the licensing framework, drawn from the international guidance currently deferred to, and the BSI Flex Standards⁽²⁹⁾ under development, brought into the CAA's ownership. These would act as an anchor point to provide clear and certain compliance pathways to operators, shifting the case-by-case assessment from the default approach to one reserved for exceptions. This would allow operators to justify deviation where their mission's characteristics require it, particularly in the case of novel missions, or rely on baseline standards where they don’t.

Standards that are formally embedded in the licensing process carry different weight than voluntary guidance that operators may or may not consult and regulators may or may not enforce. These baselines could cover a range of debris mitigation measures and considerations, such as ground impact risk from end-of-life disposal, orbital lifetimes, collision avoidance thresholds, and stratospheric burnup impacts. All of these are areas covered by the IADC guidelines and BS ISO 24113⁽¹³⁾, which currently substitute for the development of nationally binding standards^(14b).

In practice, the CAA might establish that current best practice prefers atmospheric ablation (complete burnup in the upper atmosphere) as an end-of-life disposal method, with acceptable ground impact probability not exceeding a certain threshold, while leaving open the possibility of revision as the understanding of its environmental impacts on the atmosphere and alternative end-of-life disposal options develop. It may be found that greater ground impact probability is tolerable as new understanding of the potential environmental impacts of atmospheric ablation emerges, requiring baselines to adjust. Through this mechanism, the CAA can ensure that its compliance requirements are demonstrably adhering to statutory obligations, such as the precautionary principle, or Secretary of State’s Environmental Objectives⁽³³⁾. The trade-offs assessed in such a case illustrate the need for the inclusion of the baselines recommended here in the environmental assessment framework outlined in Recommendation 4.

5.2 Recommendation 2: Articulate a Forward Facing Regulatory Trajectory and Responsive Reform Structure

The UK’s current approach to regulatory development limits long-term planning for operators in an industry that is characterised by multi-year mission lifecycles. The Technical Question Set⁽¹⁴⁾ for orbital operators can be updated as understanding develops, but this occurs without a defined timeline or advanced notice to industry. Where the draft EU Space Act provides a clear timeline and scope for future regulation^(10f), the UK offers limited visibility. The extent of concern in this regard is clear, reaching the House of Lords, which in a 2025 report on national space sector competitiveness reiterated concerns about the impacts of such limited visibility, and called for greater strategic direction⁽³²⁾ with the Government affirming this in their response⁽³⁵⁾.

This recommendation argues for the establishment of a formalised regulatory trajectory that is internationally informed, technology-responsive, and communicated to industry through a structured cycle of feedback and reform. Rather than committing to a defined implementation timeline paired with an unpredictable adaptation mechanism as the EU has, the UK should develop its own approach to regulatory reform that monitors international best practice, assesses the UK position against it, and coordinates its requirements accordingly.

Building a responsive structure for regulatory reform would not only allow the CAA to keep pace with industry and signal a clear trajectory, but may also produce insights that justify divergence from international norms where the long-term sustainability of the orbital environment warrants a unique approach. This has the potential to position the UK as a leader in global standards of practice, strengthening the national sector’s international standing. A responsive reform approach would require the CAA to take ownership of its standards, as proposed in recommendation 1, to uncouple the UK’s standards from the pace of international standards development.

Staying responsive to emerging technology is central to maintaining a regulatory trajectory. As new capabilities become commercially viable, the UK’s mechanisms for reform should be able to accelerate their adoption into compliance expectations. This would require the CAA to actively engage with the technology landscape rather than waiting for industry to champion new developments. The inclusion of a structured update cycle, where the CAA could communicate regulatory changes in advance at defined intervals, would allow the UK regime to develop this responsive capacity. Such an update cycle could take many forms as long as it is regular and predictable, enabling industry and regulator to establish patterns of feedback, communication, and networking that are essential for the transfer of tacit knowledge and understanding that underpin effective regulation.

For example, the CAA could hold an annual forum that serves three purposes: announcing new reforms and regulation, gathering industry feedback on technological developments and regulatory efficacy, and formally bringing announced reforms into effect. A mechanism of this kind has the potential to achieve the adaptability that the UK regime strives for through BSI Flex Standards⁽²⁹⁾ and regulatory sandboxing⁽²⁴⁾ in a way that strengthens and improves the dynamic character of its existing approach, while addressing its lack of strategic direction at a structural level.  

5.3 Recommendation 3: Introduce Dedicated Debris Mitigation Submissions

The UK’s current approach embeds debris mitigation for operators within the broader Technical Question Set⁽¹⁴⁾, where it lacks the weight to signal mitigation as a regulatory priority and hinders aggregate assessment of sustainability outcomes at the sector scale. While the existing Debris Mitigation Plan^(14b) provides lifecycle coverage in scope, its subordination within the Technical Question Set⁽¹⁴⁾ along with the end-of-life plan⁽²⁸⁾, and deference to non-binding international standards^(14a), mean that it lacks the formal clarity and prioritisation of the EU’s debris mitigation submissions^(10b). Recommendation 3 argues for upgrading the Debris Mitigation Plan^(14b) into a standalone submission with presumed baseline requirements, and extending its coverage by consolidating it with the end-of-life plan⁽²⁸⁾. This frames debris mitigation as a priority for compliance, and ensures a baseline standard of practice to enable aggregate assessment of compliance outcomes.

Drawn from the existing Debris Mitigation Plan^(14b), end-of-life plan⁽²⁸⁾, and international best practice⁽¹³⁾, a standalone debris mitigation submission would include minimum standards in line with Recommendation 1 that establish baseline expectations for operators across the full mission lifecycle. The submission would consolidate coverage of areas such as collision avoidance, disposal planning, and passivation to bring greater visibility to mission-scale debris mitigation impacts. The submission’s scope would be tailored to each licence type, covering the full operational lifetime for orbital operators, and the launch/upper stage phase for launch operators. In practice, the upgraded plan would specify what standards operators must achieve, not how they achieve them, mirroring the EU’s three mandatory plans^(10b) in structure without matching their prescriptiveness.

These minimum standards should not be static. Newly developed technologies or mission architectures will present their own trade-offs, a new disposal method might reduce ground impact risk but increase atmospheric burnup. ALARP methodology is well suited to accommodate holistic assessments of those trade-offs, as in Recommendation 4. Ensuring that baseline standards within licensing submissions adapt to new developments requires a responsive reform mechanism, such as the structured update cycle of Recommendation 2.

A standalone debris mitigation submission with formal and legally-binding baseline requirements would enhance aggregate assessment of sustainability outcomes at the sector scale. Regulators would be able to assess the effectiveness of debris mitigation measures across licensing applications with greater consistency, and identify systemic risks across the sector. The resulting evidence base would enable the UK to demonstrate to operators and international partners the efficacy of its principles-led approach in achieving substantive outcomes for orbital sustainability. This recommendation preserves the characteristic flexibility of ALARP by maintaining the principles-led approach, while introducing a structural change that gives debris mitigation the consistency, visibility, and priority it requires.

5.4 Recommendation 4: Introduce System-Level Environmental Assessment of Application Submissions

Assessing debris mitigation in isolation risks overlooking its wider environmental and operational impacts. Recommendation 4 argues for the integration of debris considerations within a broader operational and environmental assessment, ensuring visibility of the trade-offs mitigation involves.

The principle underpinning this recommendation is that the goal of debris mitigation should be achieved in a way that generates the least harm possible across all other relevant environmental and operational considerations. Measures aimed at reducing debris generation can have wider implications for fuel budgets, traffic distributions, atmospheric burn-up effects, and light pollution. System-level assessment evaluates the mission’s environmental impacts as a whole rather than as separate components of compliance. Introducing this kind of assessment would allow regulators to weigh these impacts against one another proportionately, to ensure that addressing one harm does not inadvertently cause another. The atmospheric burn-up trade-off outlined in Recommendation 1 illustrates the kind of considerations that need to be weighed against one another to ensure compliance is effectively producing sustainable outcomes. The draft EU Space Act approaches this in part by collecting the environmental impacts of a mission under one assessment/ However,  limited to reporting and data collection the EFD embeds a reactive approach to systemic risks into the EU regime. A system-level environmental assessment that directly impacts licensing approval decisions would allow its insights to inform regulators pre-emptively, an approach that more closely embodies the precautionary principle that effective debris mitigation depends on.

This is particularly important for novel missions where trade-offs are most acute and often the most obscured. As new mission architectures and technologies develop, the criteria for what constitutes acceptable practice in different operational scenarios will need to be revised. A disposal approach that leads to extended disposal lifetimes but reduces atmospheric impacts may be appropriate for small LEO cubesats but wholly inappropriate for a large LEO platform or lunar orbiter. Any system-level environmental assessment should be designed to accommodate the diversity and development of the industry by adapting how trade-offs are weighed in respect to different mission architectures. ALARP is well suited for this kind of holistic assessment^(15d), and its acceptability categories could be applied to the trade-offs between environmental considerations.

The CAA could develop guidance for operators on both the dimensions assessed and how trade-offs will be weighed between them, providing additional regulatory clarity in the style of the existing Regulatory Objectives. This is particularly relevant for novel missions where trade-offs are often most prominent, whose operators currently experience uncertainty in ALARP assessments⁽²⁴⁾ where such guidance is missing. A system-level environmental assessment that incorporates mission-wide trade-offs ensures that debris mitigation neither overrides nor becomes subordinated to other operational and environmental considerations. Designed for both data-collection and as an input to application approval decisions, the assessment would allow systemic risks to be addressed pre-emptively. This would ensure that the priorities and requirements of the UK’s regulatory regime remain legitimate and aligned with the changing needs and understanding of space sustainability.

6 Conclusions 

6.1 Two Core Considerations

Effective debris mitigation requires a deliberate regulatory design that balances certainty and flexibility, without compromising one for the other. This analysis shows that the proposed EU Space Act and UK regime make that compromise in opposite directions. The draft EU Space Act’s prescriptive approach provides the certainty that operators and investors require at the cost of upfront compliance burdens that risk creating disproportionate barriers to entry for SMEs^(9f) and prematurely constraining emerging technologies. The UK regime’s principles-led approach provides the flexibility that innovation requires, but produces uncertainty that hinders operator planning and protracts the licensing process^(24)(35). Compromising one for the other, as each regime has, leaves SMEs and operators of novel missions bearing the greatest costs, either through the high upfront compliance burdens of the proposed EU Space Act or the protracted and uncertain licensing processes of the UK regime.

Debris mitigation also demands a regulatory design that frames it as a distinct priority with clear and consolidated requirements, while integrating debris considerations within a wider assessment that ensures the visibility of its trade-offs. The draft EU Space Act consolidates debris mitigation through three standalone plans^(10b) that clearly signal its prioritisation but assess its impacts in isolation. The UK distributes debris considerations across submissions^(14b)(28), where case-by-case ALARP assessment implicitly integrates debris considerations with their trade-offs but fails to signal debris mitigation as a priority. Both regimes therefore fall short of producing a regulatory framework that can pre-emptively address systemic risks, and ensure that compliance achieves genuine sustainability outcomes.

6.2 Four Recommendations

The first two recommendations made in this report aim to address how the certainty of the draft EU Space Act can be incorporated by the UK regulatory regime without sacrificing the flexible and adaptive nature that provides its greatest strengths. Presumed baseline requirements would establish a formal standard of practice and encourage consistent application of compliance requirements, while retaining case-by-case assessment for exceptional circumstances. Developing a regulatory trajectory that is signalled and maintained through a responsive reform structure gives clarity to operators about the future direction of regulation, and creates a consistent feedback cycle. This allows the UK regime to enhance its flexibility and adaptability by growing its responsive capacity so that it can incorporate reforms at pace with the industry, and identify opportunities to lead global standards of practice.

The final two recommendations of this report aim to address how debris mitigation can be framed as a regulatory priority while integrating its trade-offs within licensing assessments. Consolidating debris mitigation requirements into a standalone submission with formal baseline requirements frames mitigation as a clear regulatory priority and enables consistent compliance that enhances aggregate assessment of its outcomes. Introducing a system-level environmental assessment integrates debris considerations with their broader environmental effects, allowing trade-offs between impacts to be identified and weighed against one another. Together, these recommendations ensure that the UK regime’s compliance requirements produce demonstrable sustainability outcomes, and that debris considerations are neither subordinated nor isolated within the licensing process. 

Table 7 below summarises each recommendation, its purpose, and their enabling mechanisms.

Table 7: Summary of Recommendations and Pathways

Recommendation	Purpose	Potential Mechanism
Establish Clear Baseline Expectations Within the ALARP Framework	Provide operators with clear baseline standards that provide them with a clear understanding of what constitutes compliance. Ensure the CAA has a baseline standard of compliance enforcement to enable aggregate assessment of its outcomes.	Prescriptive standard setting within CAA guidance and under CAA ownership. Case-by-case assessment reserved for exceptional circumstances or novel operations to preserve flexibility as the industry develops.
Articulate a Forward Facing Regulatory Trajectory and Responsive Reform Structure	Provide operators with certainty surrounding the direction of regulation, and signal areas that will receive regulatory support in future/if developed. Create a cycle of feedback between regulator and industry that builds the knowledge resources of the CAA and allows them to regulate responsively to industry development.	Open statement documentation of a regulatory strategy, future direction, and scope. A reform cycle that includes a consistently scheduled forum with industry and external stakeholders.
Introduce Dedicated Debris Mitigation Submissions	Signal debris mitigation as a clear regulatory priority to operators, while preventing it from overriding other environmental considerations. Ensure that the CAA’s assessment of debris related hazards incorporate mission-scale impacts and beyond.	An unsubordinated Debris Mitigation Plan licensing submission for orbital operators that covers the full mission lifecycle.
Introduce System-Level Environmental Assessment of Application Submissions	Integrate debris mitigation with its wider environmental and operational trade-offs, ensuring that compliance is aimed at genuine sustainability outcomes.	A licensing assessment framework that incorporates a system-level assessment of an applications environmental and operational characteristics, impacts, and their relation to each other. Accompanying guidance to operators on how the CAA intends to weigh considerations against each other, e.g. is lower debris risk more desirable than reduced light pollution.

6.3 The UK’s Opportunity

Without action, the UK risks contributing to an orbital environment where debris populations expand beyond recoverable thresholds, and a regulatory environment where uncertainty drives innovative operators to jurisdictions with clearer licensing processes and a stronger vision for the future. The recent integration of the UKSA into DSIT⁽³⁰⁾, the publication of the CAA’s Spaceflight Regulatory Objectives in March 2026⁽³⁴⁾, and the ongoing development of BSI Flex Standards⁽²⁹⁾ represent an opportunity to change this status-quo future through targeted reform of the UK’s regulatory structure.

The four recommendations argue for the development of a regime that not only maintains its flexible nature but enhances it, while creating a structure of baseline requirements, clear priorities, and forward-looking timelines, that allow its adaptive processes to develop with clear strategic direction and provides operators with the clarity and certainty they need to drive the UK space industry forward. A regime that operators can navigate predictably and efficiently is one that attracts commercial activity, particularly from SMEs and novel mission operators who bear the greatest cost of its current uncertainty.

The UK’s principles-led approach already ensures flexibility, but without structure this leads to uncertainty, not adaptability. The reforms proposed here are intended to give the UK regime’s adaptive regulatory character a structure and direction that allows it to develop consistently toward true orbital sustainability and debris mitigation outcomes.

7 References

1.       https://www.scientificamerican.com/article/spacex-reaches-milestone-of-10-000-starlink-satellites-in-orbit/ Scientific American, Jonathan O’Callaghan, March 2026, Accessed 01/05/2026

a. ‘As of today, more than 10,000 active Starlink satellites are in space, constituting about two thirds of all satellites that are currently in orbit’

b. ‘300,000 manoeuvres’ citing SpaceX FCC Semi-annual Constellation Status Report from December 2025

2.      https://aerospaceamerica.aiaa.org/features/heavy-traffic-ahead/ Aerospace America, ‘Heavy Traffic Ahead’, Jonathan O’Callaghan, October 1st 2025, Accessed 01/05/2026

3.      https://x.com/US_SpaceCom/status/1821615199230816555 United States Space Command (@US_SpaceCom), post on X (formerly Twitter), 8 August 2024, Accessed 01/05/2026

https://www.space.com/china-megaconstellation-launch-space-junk Space.com, Mike Wall, August 8 2024, Accessed 01/05/2026

4.      https://sdup.esoc.esa.int/discosweb/statistics/ Space Environment Statistics, Pg.1 Derived from ESA Space Environment Report 2025, Accessed 16/02/2026

5.      https://agupubs.onlinelibrary.wiley.com/doi/abs/10.1029/JA083iA06p02637 Collision frequency of artificial satellites: The creation of a debris belt, Donald J. Kessler, Burton G. Cour-Palais (1978), Accessed 01/05/2026, The original paper defining a Kessler event.

6.      https://aerospaceamerica.aiaa.org/features/understanding-the-misunderstood-kessler-syndrome/ Aerospace America, ‘Understanding the misunderstood Kessler Syndrome’, March 1 2024, Jon Kelvey, Accessed 01/05/2026:

a. ‘we’re on a timescale of something like a one in 10 chance each year of another major collision.’ attributed to Mark Matney NASA Orbital Debris Program Office at NASA Johnson.           

b. ‘A Kessler Syndrome cascade is something that, whether it has begun or not, would play out over the course of decades‘

7.      https://reports.weforum.org/docs/WEF_Clear_Orbit_Secure_Future_2026.pdf WEF, ‘Clear Orbit Secure Future: A Call to Action on Space Debris’, January 2026, Accessed 02/05/2026,

a.  ‘identifies dense debris clusters forming at altitudes of around 775 km, 840 km and 1,000 km, with the highest-risk band facing up to a 29% probability of a major collision by 2032.’ Conclusions from a model developed by the Saudi Space Agency and LeoLabs

b.  ‘The projected cumulative cost between 2025 and 2035, ranging between $25.8 billion and $42.3 billion, represents a business-as-usual scenario, one that assumes no major debris-generating events occur.’

8.      https://ntrs.nasa.gov/citations/20100002023 NASA, October 16 2009, ‘The Collision of Iridium 33 and Cosmos 2251: The Shape of Things to Come’, Accessed 02/05/2026, Report on the Iridium-Cosmos Collision, ‘ More than 1800 debris approx. 10 cm and larger were produced.‘

9.      https://defence-industry-space.ec.europa.eu/document/download/18cb5e4d-c060-4ca8-b15c-00a45cd5f61a_en?filename=SWD-Impact-assessment-report-part1.pdf The proposed EU Space Act Impact Assessment Report Part 1, 25/6/2025, Accessed 02/05/2026, European Commission 

a.  Pg.56 Table 19

b.  Pg.10, Pg. 17, Stakeholder Feedback.

c.  Pg.18 Table 3

d.  Pg. 4 Downstream and Upstream EU Market

e.  Pg.36, Table 9, ‘Certain technical elements (building on international standards and best practices when they already exist) would be developed through implementing acts’ from the contents for policy option 2 which are incorporated into policy option 2+ which the draft EU Space Act Represents, as seen in Table 10 on the next page.

f.  6.1.8 ‘manufacturing costs ranging from 3% to 10%. For smaller actors it would be proportionally more expensive to comply with such measures.’

g.  Pg.49,Table 13: Summary of Expected Costs, Table 14: Summary of Expected Benefits

10.   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025PC0335 The EU Space Act Proposal, European Commission, 25/6/2025, Accessed 02/05/2026

a.  Article 104 (2) - Implementing Acts

b.  Article 61 (2a)(2b), The two plans for launch operators, Article 70 (2) - The Three Plans for spacecraft operators

c.  Article 101 (4), - ISOS delegating acts

d.  Article 64 (1), EU SST Subscription

e.  Article 112, Space Labelling Scheme

f.   Article 117, 118, 119, Timeline

g.  Annex II, 2.6, 3.2(e), Failure Response Plan for launch operators

h.  Article 96 Environmental footprint of space activities

i.   Article 73, Constellations

j.    Context of the Proposal, Section 3

11.    https://www.legislation.gov.uk/ukpga/2018/5/section/2 The Space Industry Act 2018, Section 2(2)(h), up to date as of 28/04/2026, Accessed 01/05/2026, provides the policy obligation to the CAA to consider ‘any space debris mitigation guidelines issued by an international organisation in which the government of the United Kingdom is represented.’

12.   https://www.iso.org/standard/83494.html International Organization for Standardization (2023), Space Systems - Space Debris Mitigation Requirements, ISO 24113:2023, 4th edition. Paywalled though utilised through its abstract and source below

13.   https://www.hou.usra.edu/meetings/orbitaldebris2019/orbital2019paper/pdf/6053.pdf Stokes, H. et al. 'Evolution of ISO's Space Debris Mitigation Standards', First International Orbital Debris Conference, December 2019, Paper 6053, Accessed 01/05/2026

14.   https://www.caa.co.uk/publication/download/19252 Civil Aviation Authority, Technical Question Set (TQS): Guidance and Checklist, CAA Publication 19252, Version 2.1, 16 February 2024. Accessed 01/05/2026

a.  The need for applicants to assess their impact on the orbital environment is driven by the goals set out in… Inter-Agency Space Debris Coordination Committee (IADC) to which the United Kingdom is a signatory or member agency.

b.  Question 6-A-10: ‘Please provide a Space Debris Mitigation Plan.’ ‘Applicants may wish to refer to ISO 24113 for guidance on how to structure a Space Debris Mitigation Plan.’

15.   https://www.caa.co.uk/publication/download/18909 CAA, CAP2210 (2026), 3rd edition, Accessed 01/05/2026

a.  i.            Chapter 3.1 Technical Question Set named as a requirement

     ii.            Chapter 5.3, 5.4, Technical Question Set relevance to debris safety and orbital sustainability

b.      Chapter 3.3 Safety Case for exceptional circumstances

c.      Chapter 5.6 the Technical Question Set may change over time

d.      Annex 1, Outlines ALARP and case-by-case assessment

16.   https://www3.weforum.org/docs/WEF_Space_2024.pdf World Economic Forum / McKinsey report, April 2024, ‘Space: The $1.8 Trillion Opportunity for Global Economic Growth’, page Pg.4 Section 1, Accessed 16/02/2026, ‘The space economy is forecast to reach $1.8 trillion by 2035, up from $630 billion in 2023 and growing at an average of 9% per annum‘

17.   https://www.space.com/space-exploration/satellites/spacex-lowering-orbits-of-4-400-starlink-satellites-for-safetys-sake Space.com, Mike Wall, 02/01/2026, Accessed 01/05/2026

18.   https://www.elgaronline.com/edcollchap/edcoll/9781781000359/9781781000359.00010.xml Peter Jankowitsch, Handbook of Space Law, 27/02/2015, Accessed 01/05/2026

a.  '...space law as it was originally conceived was only considered as an instrument regulating relations between states with no other actors present in space…'

b.  '..the slow ascendance of rules for space debris mitigation from an essentially non-legal agreement between major space agencies to a status of soft-law regulation blessed by a 2007 Resolution of the General Assembly.’

19.   https://indico.esa.int/event/450/contributions/8992/attachments/5691/9447/ZeroDebris_standard_pdf.pdf Letizia, F., 'ESA Space Debris Mitigation Standard and Policy', European Space Agency, presented at ESA ESTEC, 17 October 2023, Accessed 01/05/2026, Slides 2 and 4.

20.  https://www.aboutamazon.com/news/company-news/amazon-receives-fcc-approval-for-project-kuiper-satellite-constellation AmazonNews, 'Amazon receives FCC approval for Project Kuiper satellite constellation',  July 30 2020, Accessed 01/05/2026

21.   https://www.thespacereview.com/article/4338/1 Lan, C., 'The Starlink-China Space Station near-collision: Questions, solutions, and an opportunity', The Space Review, 28 February 2022, Accessed 01/05/2026.

22.  https://starlink.com/public-files/Starlink_Approach_to_Satellite_Demisability.pdf SpaceX, 2025, Accessed 01/05/2026, ‘On August 20, 2024, a 2.5 kg piece of aluminum was found on the ground in a farm in Saskatchewan, Canada, and determined by SpaceX engineers to have come from a Starlink satellite that re-entered following the erroneous Falcon G9-3 deploy.‘

23.  https://www.oecd.org/en/publications/the-economics-of-space-sustainability_b2257346-en.html OECD, 28 June 2024, 'The Economics of Space Sustainability', Accessed 01/05/2026,  ‘The total global value of economic activity at risk is estimated to be USD 191 billion’

24.  https://www.gov.uk/government/publications/regulatory-sandbox-for-rendezvous-and-proximity-operations-stage-1/regulatory-sandbox-for-rendezvous-and-proximity-operations-stage-1-report RPO Operators Consortium (Astroscale, ClearSpace and D-Orbit), ‘Regulatory Sandbox for Rendezvous and Proximity Operations: Stage 1 Independent Report’, published by the Department for Science, Innovation and Technology (DSIT) with the participation of the Civil Aviation Authority and UK Space Agency, 20 August 2025, Accessed 01/05/2026: Operators experienced uncertainty around ALARP demonstration scope for novel missions

25.  https://www.caa.co.uk/space/guidance/environmental-requirements/ CAA, CAA Space Guidance: Environmental Requirements, Accessed 01/05/2026

26.  https://www.caa.co.uk/space/resources/launch-collision-avoidance-analysis-lcola/ CAA, CAA LCOLA, Accessed 01/05/2026

27.   https://www.caa.co.uk/data-and-publications/publications/documents/content/cap2259a/ CAA, CAP2259A: Launch Operator Safety Case Licensing Statement, Accessed 01/05/2026

28.  https://www.caa.co.uk/space/guidance/disposal-phase-and-end-of-life/ CAA, Disposal Phase and End of Life: Temporary Guidance, Accessed 01/05/2026

29.  BSI, BSI Flex Standards, Accessed 01/05/2026

a.  https://www.bsigroup.com/en-GB/insights-and-media/insights/brochures/bsi-flex-1969-space-sustainability-overarching-principles-and-framework/ BSI flex 1969 - Overarching principles

b.  https://standardsdevelopment.bsigroup.com/projects/9025-11909 BSI Flex 1971 - guidance on launch-specific orbital and suborbital environmental considerations

30.  https://www.techuk.org/resource/the-uk-space-agency-is-being-brought-into-dsit-what-does-this-mean-for-the-sector.html TechUK.Org,The UK Space Agency is being brought into DSIT, 20/08/2025, Accessed 21/02/2026

31.   https://www.gov.uk/government/publications/space-regulatory-review-2024 Space Regulatory Review 2024, Annex 4.1.1, Accessed 01/05/2026

32.  https://publications.parliament.uk/pa/ld5901/ldselect/ldukspace/190/190.pdf House of Lords The Space Economy: Act Now or Lose Out, 4/11/2025, Accessed 01/05/2026

33.  https://assets.publishing.service.gov.uk/media/5a7f09b640f0b6230268d173/air-navigation-guidance.pdf Department for Transport, January 2014, Guidance to the Regulator on Environmental Objectives Relating to the Exercise of its Functions under the Space Industry Act 2018, Accessed 01/05/2026

34.  https://www.caa.co.uk/data-and-publications/publications/documents/content/cap3227/ CAA, March 2026, Spaceflight Regulatory Objectives, Accessed 01/05/2026

35.  https://www.gov.uk/government/publications/government-response-to-the-house-of-lords-uk-engagement-with-space-committee-report-the-space-economy-act-now-or-lose-out/government-response-to-the-house-of-lords-uk-engagement-with-space-committee-report-the-space-economy-act-now-or-lose-out Department for Science, Innovation and Technology (2026) Government response to the House of Lords UK Engagement with Space Committee report: The Space Economy: Act Now or Lose Out. CP 1478. London: HMSO., Accessed 01/05/2026, Recommendation 24

36.  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32011L0092 Directive 2011/92/EU Of The European Parliament And Of The Council, ‘on the assessment of the effects of certain public and private projects on the environment‘, 13/12/2011, Accessed 13/05/2026

37.  https://www.sciencedirect.com/science/article/pii/S0094576525006332?dgcid=author Parker, W.E. et al. (2026) ‘Constraining earth’s orbital capacity via operational feasibility’, Acta Astronautica, 238, pp. 769–778. doi:10.1016/j.actaastro.2025.09.055. , Accessed 13/05/2026

38.  https://defence-industry-space.ec.europa.eu/eu-space/product-environmental-footprint-category-rules-pefcr-space-sector_en European Commission, Product Environmental Footprint Category Rules (PEFCR) for the space sector, Accessed 15/05/2026

39.   Murphy, D.M. et al. (2023) ‘Metals from spacecraft re-entry in stratospheric aerosol particles’, Proceedings of the National Academy of Sciences, 120(43). doi:10.1073/pnas.2313374120. Accessed 15/05/2026

40.  Schulz, L. et al. (2026) ‘Space waste: An update of the anthropogenic matter injection into Earth’s atmosphere’, Advances in Space Research, 77(9), pp. 9589–9616. doi:10.1016/j.asr.2026.03.026. Accessed 17/05/2026

41.   https://space.commerce.gov/u-s-response-to-russian-anti-satellite-test/ Office of Space Commerce, November 15 2021, Accessed 17/05/2026, Confirms the 1500 trackable debris objects number.

42.  https://www.nasa.gov/news-release/nasa-administrator-statement-on-russian-asat-test/ NASA, November 15 2021, Accessed 17/05/2026, NASA administrator confirming the ISS undertook emergency procedures.

43. A Simmonds, 2025, “The Space Legislation of the UK”, Studies in Space Law Vol.28, Brill, Pg.32-36, <https://discovery.dundee.ac.uk/en/publications/the-space-legislation-of-the-united-kingdom/> Accessed: 28/05/2026