In 2024, the UK Space Agency consulted on new approaches to downloaddetermining limits of operator third-party liability, associated insurance requirements and licence application fees for orbital operations licences, along with further consideration of new models of third-party liability insurance provisions. The consultation also sought views on other matters regarding space sustainability.

Since the consultation launched, the government has further consulted on these and other matters, taking into account the recommendations of the Space Regulatory Review and wider government policy supporting economic growth.

This consultation outcome sets out the government’s decisions on these matters, in particular noting the following changes, included as part of the announcement of the government’s new Space Strategy:

• The introduction of variable liability limits for orbital operations licence applications received after 1 December 2026.
  • The approach will be structured using three tiers (£50 million, £20 million and £0), to incentivise responsible behaviour by operators through security and space sustainability criteria.
  • £50 million will be the default limit applied however operators may submit evidence on a voluntary basis to seek a reduction in their limit of liability for the activities covered by the orbital operations licence.
  • The initial criteria will assess whether operators have completed UK Space Agency cyber and physical security assessments and how they educate themselves on space sustainability.
  • A next iteration of the approach will be considered for implementation in late 2027 or early 2028, with possible alternative criteria, and could include an additional tier/s.

• To support innovation, liability and insurance requirements will be waived for in-orbit servicing, assembly and manufacturing and lunar missions launched before 2030, aligning with a recommendation from the Rendezvous and Proximity Operations regulatory sandbox. This will apply to licences issued from 1 December 2026 for such missions.

• Alternative insurance models, such as voluntary mutuals and collective sector policies, are endorsed. Where such policies are proposed by organisation, the CAA and BIST will need to work with the proposers of such policies to ensure that they meet the necessary requirements placed on licensees. We propose also to explore the potential merits of a Space Re concept, similar to flooding and terrorism insurance models, to help with longer term stability of the space insurance market. Unlike discussions on the sector-led mutual and collective policies, this publicis feedback.still an exploratory consideration, with no commitment being made to introduce or support such an approach.

• Any existing decommissioning funds set up to de-orbit satellites in the event of a constellation operator’s insolvency will be wound up. Going forwards the Civil Aviation Authority (CAA) will balance risk and proportionality for any financial measures, allowing a more proportionate approach to deposit and security requirements.

• Licences issued for orbital operations and procuring a launch from applications received after 1 December 2026 will contain liability limits in pounds sterling, replacing the current euro-based limit determination.

Detail of feedback received

We received 46 responses to this consultation, (not including subsequent engagement following the closure of this consultation) from a broad range of stakeholders including:

• Satellite operators
• insurers
• trade bodies
• legal representatives
• academia’