- Category: Library
- 2025-11-18
On 25 June 2025, the European Commission published its proposal for the EU Space Act, the first initiative aimed at creating a harmonised regulatory framework for space activities across the European Union. To further refine the proposal, the Commission carried out a public consultation, open from 15 July to 7 November 2025, inviting stakeholders to provide additional input on how the legislative framework should be shaped to enhance safety, resilience, sustainability and Europe’s competitiveness in the global space market.
As a representative voice of Europe’s downstream space industry, Space Y welcomes the ambitions of the proposed Regulation and recognises its potential benefits for companies in the downstream space sector that rely on secure and reliable satellite data. Although the Act primarily addresses satellite operators and primary data providers, its effects will extend across the entire value chain. Space Y therefore submitted its response to ensure that the specific needs, challenges and opportunities of the downstream sector are fully considered. Our full feedback is presented below.
Space Y feedback on the EC Public Consultation on the EU Space Act
November 2025
Space Y welcomes the Proposal for a Regulation on the safety, resilience and sustainability of space activities in the Union as an important milestone to establish a common legislative framework for Space activities in Europe and to position the EU as a global space leader.
The Association, federating the voices of the main industrial players in the European downstream space sector, recognises the potential benefits that the Act would have on the downstream by securing access to reliable and trustable data. We also support the two-fold objective of the proposed Regulation to increase the safety, resilience and sustainability of space activities in Europe, while also boosting the competitiveness of the European space sector at large on the global market.
We understand that the proposed EU Space Act targets satellite operators and primary providers of space-based data, and that hence it does not contain direct obligations for companies operating in the downstream sector. Nevertheless, we consider that the proposed Regulation will affect the downstream part of the European space sector and ask the European Commission to clarify some aspects of the legislative text. In addition, we wish to formulate some recommendations aimed at ensuring that the effects of the Regulation on the European downstream space sector are duly considered within the legislative process.
A downstream perspective on the proposed EU Space Act
The word “downstream” is mentioned only once in the proposed Regulation (p. 18, in the preamble) to stress the role of “primary providers of space-based data” as “intermediaries between the upstream and downstream sectors.” Nevertheless, the EU Space Act will have impacts also on the downstream part of the European space sector that need to be duly considered before the legislation is adopted.
The requirements of the Regulation should increase the competitiveness of satellite-based data and products made in Europe, while also ensuring the resilience of a number of services and infrastructure relying on satellite-data or signals in the EU, such as hospitals, airflight operations, and transport and energy networks, among others. At the same time, to comply with the EU Space Act, satellite operators and space service providers will incur in additional costs and administrative burdens, that are likely to result in increased costs of commercial data and value-added services downstream. This could limit the uptake of data and services by civil society and the competitiveness of the European downstream sector on the global market.
The Act proposes supporting measures to help Member States and businesses operating upstream to transition smoothly towards the implementation of the Regulation, while the EC Communication “A Vision for the European Space Economy” sheds light on the ambitions of the EC to boost the downstream part of the European space sector. Nevertheless, at this stage more clearness is needed on the support measures that will be implemented to help the downstream mitigate the risks linked to the implementation of the EU Space Act and on how policies will be implemented to ensure sustainability, resilience and competitiveness across verticals in the space value-chain and within market segments downstream.
Concerning the provisions of the Act that would need to be better defined, some doubts arise on the critical services and infrastructure to which the regulation should not (fully) apply. It is unclear how these are to be defined and if they include downstream services provided by private companies to public administrations, e.g. for civil protection, secure communications, health, police, and other similar services. This clarification is particularly relevant when considering dual-use projects and services.
Although the requirements of the proposed EU Space Act will only apply as from 2030, their potential impacts on the competitiveness of the downstream industry and the uptake of satellite-based services shall be duly assessed and addressed to ensure that the Regulation does not create additional constrains to the development and commercialisation of space-based products and services.
The EU Space Act will need to be complemented by implementing acts to define how its objectives will be achieved and to establish technical and compliance standards. Active participation of the downstream industry will be essential to ensure that such implementing measures will reflect the real operational and technological conditions downstream, and to duly consider the potential impacts of the Act on the European companies turning satellite data and signals into operational products and services.
We propose that the European Commission introduces a structured process for ongoing consultation with stakeholders, including technical workshops with Member States and industry associations throughout the regulatory process. This would help maintain consistent interpretations of key provisions, minimise implementation challenges, and would strengthen transparency and trust.Bas du formulaire
Finally, Space Y would like to stress the importance of duly embedding measures to foster skills development, market uptake and regional ecosystems in the Regulation and in its implementing measures.
Space Y and its members acknowledge the relevance of the objectives set in the EU Space Act to grant the sustainability of the European space sector throughout the whole space sector value-chain. The association is willing to support the European Commission, European institutions and all relevant stakeholders to make sure that the provisions of the EU Space Act will have a positive impact on the European downstream sector by enhancing sustainable economic growth and the creation and uptake of services responding to concrete societal needs.