Introduction
Satellite broadband is no longer a niche technology. It is becoming part of the infrastructure that supports emergency communications, maritime activity, rural connectivity, transport, environmental monitoring and national resilience. For Ireland, that matters. Ireland is an island state with exposed Atlantic infrastructure, a large maritime zone, dispersed rural communities and growing dependence on digital networks for public services and economic activity.
The European Union’s proposed Space Act is an important step toward a common set of rules for space activities and space-based services. It focuses on safety, resilience and environmental sustainability. Those priorities are necessary. But there is a further question that the current policy debate does not yet answer clearly enough: how can regulators tell whether very large satellite broadband systems are being used efficiently once they occupy scarce orbital, spectrum and ground infrastructure?
This paper argues that Ireland should support the addition of a proportionate satellite-broadband transparency layer to the EU Space Act. The purpose would not be to force companies to reveal trade secrets or to publish sensitive operational data. The aim would be to give regulators confidential information that helps them distinguish between legitimate spare capacity and long-term under-use, bottlenecks or restricted access in systems that may become strategically important.
That transparency case is also linked to a second policy issue: infrastructure sharing. Recent research, including the OrbitShare framework, suggests that cross-operator sharing of satellite and ground infrastructure can, in some circumstances, improve efficiency, reduce duplication and support public-interest access.[1] But sharing is hard to design well when regulators cannot see where capacity exists, where bottlenecks are located or whether unmet demand reflects real scarcity or strategic allocation. In that sense, transparency and sharing should be seen as connected questions rather than separate debates.
The timing is important. Ireland will hold the Presidency of the Council of the European Union from July to December 2026.[2] That six-month window will not allow Ireland to reshape the whole European space agenda on its own, but it does create a real opportunity to drive negotiations, build coalitions and give political momentum to parts of the Space Act that connect space policy with resilience, competitiveness and strategic autonomy.
Why this matters for Ireland
Ireland has several reasons to care about how large non-geostationary orbit, or NGSO[i], broadband constellations are governed.
First, satellite services are relevant to resilience. Ireland depends heavily on digital connectivity for government, business, transport, emergency planning and critical infrastructure. Satellite systems can act as backup communications during outages, support offshore activity and extend service into hard-to-reach areas. That makes them valuable. But it also means Ireland may become dependent on systems that are largely designed, owned and operated elsewhere.
Second, Ireland has a strong policy interest in the fair and secure operation of cross-border infrastructure. The EU Space Act will apply not only to European operators but also, in principle, to third-country providers that offer services in the Union. That is especially relevant in satellite broadband, where the most important systems serving Europe are likely to include non-EU operators.
Third, Ireland is already engaged in the debate. The Department of Enterprise, Trade and Employment’s consultation on the EU Space Act raised questions about proportionality, confidentiality, third-country operators and institutional design.[3] That is exactly the right place to start. But the consultation also points to a deeper issue: regulators need to know what information they will actually need if the Union is serious about resilience, strategic autonomy and public-interest access.
Fourth, Irish public policy has to think beyond simple coverage maps. A satellite network may technically cover Ireland while still leaving important policy questions unanswered. Is capacity concentrated in a small number of gateways? Is spare capacity being held for legitimate resilience reasons, or is it unavailable for less defensible reasons? Are public bodies, maritime users or rural communities able to access service on reasonable terms? Are there bottlenecks in gateways, terminals or wholesale access? Without better visibility, those questions are hard to answer.
Those questions also matter for infrastructure sharing. If Ireland and the EU eventually want to encourage gateway sharing, emergency access arrangements, or more open wholesale use of satellite capacity, they first need a clearer picture of how existing systems are organised. Otherwise, policy makers risk debating sharing in the abstract.
Fifth, Ireland now has a stronger national stake in space than it did only a few years ago. The National Space Strategy for Enterprise 2019-2025 set out a vision of an economically sustainable and expanding Irish space-active industry.[4] Its first progress report recorded growth in Irish company participation in European Space Agency (ESA) programmes and linked space activity directly to industrial development, research capacity and public policy needs. In November 2025, the Irish government also announced over EUR 170 million for ESA programmes through 2030.[5] In other words, Ireland is not just observing European space policy, it is investing in the ecosystem that the policy will shape.
The research base is growing too. In 2023, a UCD-led project secured just over EUR 7.9 million from the Disruptive Technologies Innovation Fund to support work in optical communications, autonomous satellites, and spacecraft and payload research support.[6] That matters because the EU Space Act will help define the commercial and regulatory environment in which Irish researchers, start-ups and technology firms will compete and collaborate.
Why the 2026 EU Presidency raises the stakes
Ireland’s Presidency of the Council of the EU from 1 July to 31 December 2026 gives this debate a sharper policy edge. Presidencies do not decide legislation alone, but they do chair negotiations, broker compromises and influence how much political attention a file receives.
That means the Space Act should be treated in Dublin as more than a narrow technical dossier. It sits at the intersection of industrial policy, digital resilience, research strategy and European competitiveness. During the Presidency, Ireland will be well placed to argue that Europe should not only regulate space activities more safely, but also understand whether strategically important broadband constellations are being used in ways that support the public interest.
In practice, an Irish Presidency could push for:
- Clearer attention to satellite broadband and gateway dependence within the Space Act debate
- Stronger links between the Space Act and wider EU resilience and competitiveness goals
- A proportionate confidentiality model so sensitive operator data can be examined without broad public release
- A standardised reporting framework that is workable for regulators and industry
- Recognition that smaller Member States and island states have a particular interest in visibility over access and continuity of service
What is missing from the current EU Space Act debate?
The EU Space Act proposal is a significant development. It aims to reduce fragmentation across Member States and to create a more coherent framework for space activities and services in the internal market.[7][8] Its current pillars are broadly sensible.
The safety pillar focuses on issues such as debris mitigation, manoeuvrability, collision avoidance and trackability. The resilience pillar links space systems to wider European concerns about cybersecurity and critical infrastructure. The environmental pillar introduces lifecycle and sustainability ideas that have often been missing from earlier space regulation.
However, a system can satisfy all three pillars and still raise another problem. A very large broadband constellation can be safe, cyber-secure and environmentally assessed while still using orbital and ground resources inefficiently. For example, capacity might be deployed far ahead of demand to secure market position. Useful capacity might remain inaccessible to public-interest users. Gateways or terminals might become bottlenecks. Wholesale access requests might be delayed or refused without regulators having enough information to know whether the refusal was technically necessary or strategically convenient.
This is where the current framework is weak. It tells regulators a good deal about whether a system is safe enough to operate. However, it tells them much less about whether the scale and organisation of that system are proportionate to the public burdens it creates.
It also means that the EU has only a limited basis for deciding when infrastructure-sharing measures might be justified. Sharing is sometimes presented as either obviously desirable or obviously intrusive. In reality, it depends on context. In some situations, voluntary sharing of gateways, backhaul interfaces, reserve capacity or wholesale access could improve resilience and reduce waste. In others, it might be disproportionate or technically inappropriate. The missing ingredient is evidence.
That matters because very large constellations do not just provide connectivity. They also occupy scarce orbital slots, use valuable spectrum, rely on gateway infrastructure and shape future market structure. If one or two systems become indispensable before public authorities have a clear view of how they are being used, intervention becomes much harder later.
This is also where research and innovation policy enters the picture. The EU is not only regulating space. It is also funding it at scale. The European Commission says that close to EUR 1.6 billion is earmarked for space research and innovation under Horizon Europe over the 2021-2027 programming period.[9] Alongside that, the EU Space Programme itself has a total 2021-2027 budget of EUR 14.88 billion in current prices.[10]
Those figures matter for Irish public policy. If Europe is investing at that scale in satellite communications, Earth observation, access to space, in-orbit validation and technological non-dependence, it also needs a governance framework that protects the public value of those investments. A transparency layer within the Space Act would help make sure that public regulation keeps pace with public and private investment.
The policy idea: utilisation transparency
The practical policy response is not immediate mandatory sharing. It is not a crude rule saying that any unused capacity is wasteful. Spare capacity can be entirely legitimate. Operators may need it for resilience, emergency response, service quality, maintenance or future demand.
The more proportionate idea is utilisation transparency.
Under this approach, very large satellite broadband providers serving the EU would submit confidential, standardised information to competent authorities. The information would stay mainly in regulatory hands rather than being released publicly in raw form. Its purpose would be to help authorities judge whether under-use is justified, whether access bottlenecks exist and whether any further intervention is needed.
In plain terms, regulators would not be asking: “Is every bit of capacity fully used at every moment?” Instead, they would be asking better questions:
- How much relevant capacity is actually directed at Europe?
- Where are the main gateway dependencies?
- How often do congestion, outages or blocked demand occur?
- How much capacity is being held in reserve, and for what reason?
- Are public-interest or wholesale users being turned away?
- Are public burdens increasing without a clear link to useful service output?
That kind of reporting would not solve every problem on its own. But it would give Ireland, other Member States and EU institutions a firmer evidence base.
It would also create a stronger basis for deciding when infrastructure-sharing options deserve attention. The OrbitShare argument is useful here. It shows that sharing can be socially valuable while still being unattractive to dominant operators acting alone.[1] That is exactly why better regulatory visibility matters. Without it, calls for sharing remain speculative. With it, policy makers can judge whether more limited measures such as voluntary gateway sharing, priority public-interest access, rural backhaul arrangements or a neutral capacity exchange deserve support.
Why Ireland should support this approach
There are at least four Irish policy reasons to back a transparency-first model.
1. It supports resilience without overreacting
Irish policy should avoid two extremes. One is to assume that market provision alone will naturally align with public need. The other is to jump straight to heavy-handed sharing mandates without enough evidence. A confidential transparency regime sits in the middle. It allows regulators to see whether resilience claims are credible before stronger remedies are considered.
That is especially important for emergency planning, civil protection and continuity of service. If a provider says that spare capacity is being kept for resilience purposes, regulators should be able to verify that claim in broad terms.
2. It helps a small state deal with dependence on large foreign systems
Ireland is not trying to build a global mega-constellation of its own. Like many EU states, it is more likely to depend on services delivered by large foreign or multinational operators. That does not make dependence unacceptable, but it does make visibility important.
Transparency obligations would not eliminate reliance on external providers. They would, however, reduce the risk that such reliance develops in a regulatory blind spot.
They would also help identify whether dependency could be softened through smarter infrastructure-sharing arrangements. If a small number of systems become critical for continuity of service, then public authorities may eventually need options beyond simple buyer dependence.
3. It links space policy to regional and maritime policy
Ireland’s policy interests are not limited to urban consumer broadband. Satellite capacity can matter for islands, coastal activity, maritime connectivity, fisheries, transport resilience and public service continuity. A transparency framework could help authorities to see whether services are genuinely available in the places and circumstances where they are most needed.
This fits with a wider Irish and European concern about territorial cohesion. Coverage on paper is not the same thing as practical, resilient availability.
It also suggests that sharing is not only a competition issue. In an Irish context, gateway sharing, targeted wholesale access or emergency access arrangements may be relevant to regional policy, maritime resilience and continuity of public services.
4. It is compatible with commercial confidentiality
One obvious objection is that reporting requirements could force operators to disclose commercially sensitive information. That risk is real, and it should be taken seriously. But it is also manageable.
The solution is to separate regulatory visibility from public disclosure. Detailed data can be reported confidentially to trusted authorities under strict safeguards. Public reporting, if any, can be aggregated by geography, time period or service class. This is already familiar in other regulated sectors.
For Ireland, this point is politically important. The Irish consultation on the Space Act specifically raised questions about how sensitive information would be protected and shared.[3] Any Irish position in Brussels should keep confidentiality safeguards at the centre of the design.
What should be measured?
If the EU adopts a transparency layer, the reporting should remain focused and proportionate. It should apply only to very large NGSO broadband operators serving the Union, not to small research missions, universities or early-stage firms.
The most useful categories of information would include:
- Satellite capacity directed toward the EU, including spare capacity categories
- Beam or regional occupancy and signs of congestion or blocked demand
- Gateway use, outages and geographic concentration
- Spectrum use and coordination constraints
- Service availability and performance by broad service class
- Resilience reserves held for emergency, security or continuity purposes
- Wholesale and public-interest access requests, including refusals
- Selected sustainability indicators linked to useful service output
The point is not to create a perfect measure of efficiency. That would be unrealistic. The point is to provide enough evidence for informed regulatory judgement.
Some of these categories matter directly for sharing decisions. Gateway utilisation data could reveal whether there is scope for shared ground infrastructure. Wholesale request data could show whether access demand exists but is being blocked. Reserve-capacity reporting could clarify when public-interest access arrangements would be realistic and when they would threaten core service resilience.
This would also fit the direction of EU research policy. Current European space research funding is designed to strengthen competitiveness, reduce technological dependence, support downstream applications and improve Europe’s ability to access and use space. If public money is being used to expand capability, public authorities also need the capacity to see whether key infrastructure is becoming more resilient, more strategically useful and more open to public-interest needs.
What could Ireland argue for in the EU process?
An Irish contribution to the EU debate could be practical and constructive rather than maximalist.
Ireland could support:
- A narrow scope focused on very large NGSO broadband systems serving the EU
- Confidential reporting rather than broad public disclosure
- Standardised definitions so operators cannot report incompatible metrics
- Explicit protection for commercially sensitive and security-sensitive data
- A role for national authorities working with EU-level technical support
- A channel for public-interest users to flag unmet demand during emergencies or service gaps
- A staged policy model in which transparency can, where justified, support voluntary sharing, gateway access, rural backhaul solutions or other proportionate infrastructure-sharing measures
Ireland could also argue that any transparency regime should be linked clearly to the existing aims of the Space Act: safety, resilience, sustainability and the functioning of the internal market. That would make the proposal easier to defend legally and politically.
Due to the Irish Presidency, there is a second argument as well: leadership. If Ireland wants to use the second half of 2026 to show that it can connect industrial strategy, research investment and practical European regulation, the Space Act is a credible place to do it. Ireland now has enough skin in the game, through ESA commitments, national strategy and university- and enterprise-led projects, to argue not only for compliance rules but for smarter market oversight.
Risks and Limits
This proposal is not without risks. Poorly designed metrics could mislead regulators rather than help them. Different operators use different technical architectures, so standardisation would matter. Authorities would also need enough expertise to interpret what they receive. There is a risk of collecting large volumes of data without building the institutional capacity to use them.
Another limit is that transparency alone does not guarantee better outcomes. It is an evidential tool, not a full policy solution. If persistent problems were identified, any follow-up response would still need to be proportionate and evidence-based.
The same applies to sharing. Infrastructure sharing is not automatically efficient or fair. It can create technical, commercial and security complications. But dismissing it entirely would also be a mistake. The stronger position is to treat transparency as the foundation for deciding when sharing would improve resilience, access or efficiency, and when it would not.
Still, these limits are arguments for careful design, not for inaction.
Conclusion
Ireland has a clear stake in how Europe regulates large satellite broadband systems. The EU Space Act is already an important policy development, but its current structure does not fully address a market-design problem created by mega-constellations: public authorities may end up relying on strategically important infrastructure without enough visibility into how that infrastructure is being used.
A confidential, proportionate utilisation-transparency regime would not amount to overregulation. It would give regulators a better basis for deciding when spare capacity is justified, when bottlenecks matter and when public-interest intervention may be needed. For Ireland, that is a sensible position. It supports resilience, reduces blind dependence, respects confidentiality and fits the country’s emerging role in the wider EU debate on space governance.
It would also give Ireland a more credible way to approach infrastructure sharing. Rather than arguing for blanket mandates or leaving the issue entirely to the market, Ireland could support a staged model: first build visibility, then use evidence to decide whether voluntary sharing, gateway access, wholesale commitments or neutral exchange mechanisms would improve outcomes. That is a more practical and more defensible policy path.
Acknowledgments
This research was supported by the Disruptive Technologies Innovation Fund (Call 4), managed by the Department of Enterprise, Trade and Employment and administered by Enterprise Ireland. NSSPI: National Space Subsystems and Payloads Initiative, Contract Ref: DT 2021 0353 (https://www.ucd.ie/space/projects/nsspi/).
References
[1] de Silva, M. and Afraz, N. (2026) OrbitShare: The policy imperative for satellite internet mega-constellation sharing.
[2] Council of the European Union (2026) List of presidencies of the Council of the European Union.
[3] Department of Enterprise, Trade and Employment (2025) Ireland’s consultation on the proposed EU Space Act.
[4] Government of Ireland (2021) National Space Strategy for Enterprise 2019-2025: First Progress Report.
[5] Government of Ireland (2025) Ireland commits EUR 170 million to European Space Programmes – opening new opportunities for Irish businesses.
[6] University College Dublin (2023) UCD-led space project receives over EUR 7.9m from Disruptive Technologies Innovation Fund.
[7] European Commission (2025a) Proposal for a Regulation on the safety, resilience and sustainability of space activities in the Union (EU Space Act).
[8] European Parliamentary Research Service (2025) EU Space Act briefing.
[9] European Commission (2026a) Research, Development and Innovation.
[10] European Commission (2026b) European Space Programme.
[11] European Commission (2022) An EU Approach for Space Traffic Management.
[12] European Commission (2025b) Annexes to the proposal for a Regulation on the safety, resilience and sustainability of space activities in the Union.
[13] European Economic and Social Committee (2025) Opinion on the EU Space Act.
[14] Committee of the Regions (2025) Opinion on the EU Space Act.
[15] Letta, E. (2024) Much More Than a Market.
[16] Draghi, M. (2024) The Future of European Competitiveness.
[i] The term NGSO refers to non-geostationary orbit systems, including large low Earth orbit broadband constellations.