The “Part 25” Commercial License and Market Access Checklist provides a list of the required elements of a part 25 application. This checklist contains links to document templates and examples, which are meant to aid applicants in ensuring they’ve met requirements and are more likely to have filed a “substantially complete” application that could be placed on Public Notice (PN) following application submission.

The Commission has previously explained what is meant by “substantially complete”: “[t]he applications must be complete in substance, and must provide all the information required in the application” or a waiver must be sought and justified.1

Applicants are reminded that all statements made in exhibits are part of the application, and that the person signing the application must certify, individually and for the applicant, that all statements made in the application and exhibits are true, complete, and correct to the best of their knowledge and belief and are made in good faith.  Willful false statements are punishable by fine, imprisonment, revocation of any station authorization, and/or monetary forfeiture.

The information provided in this webpage is for the convenience of applicants and is not controlling in case of discrepancies between this webpage and other Commission rules, orders, and releases. If you believe this webpage contains inaccuracies or omissions, please e-mail any concerns to

“Part 25” Commercial Space Station License and Market Access Checklist
Form or AttachmentLink to Form, Template or Example DocumentDescription
Form 312Form 312 Template, note that this fillable version of the form is provided for reference, but applicants input text directly into ICFS.Applications for space stations must be filed electronically on FCC Form 312 and include all information required under § 25.114.
Form 312, Question 40

Form 312, Question 40: Corporate Ownership Template

Form 312, Question 40: Corporate Ownership Example

Applicants and market access petitioners are required to disclose all stockholders owning an indirect or direct equity or voting interest of 10 percent or more of the Filer's stock. Information to disclose include: the percentages held, name, address, and citizenship of each interest holder. 
The names and addresses of the officers and directors of the Filer are required. A box diagram showing relationship amongst owners and entities can be helpful to provide.

Indirect stock ownership disclosure: Indirect stock ownership of 10% or more must be disclosed. To calculate the ownership percentage, multiply the percentage each agent has in the vertical ownership chain. For example, if A owns 30 percent of company X, which owns 60 percent of company Y, which owns 26 percent of “applicant,” then X's interest in “applicant” would be 26 percent (the same as Y's interest because X's interest in Y exceeds 50 percent), and A's interest in “applicant” would be 7.8 percent (0.30 × 0.26 because A's interest in X is less than 50 percent).

Additional information on foreign ownership.

The Enforcement Bureau also issued a public notice (DA-23-336) on this in 2023. From page 3 of the Notice: Through this review process, the applicant provides the Commission with, among other things, contact information, ownership information (equity and voting interests), including citizenship, information on any affiliations it may have with foreign carriers, certification that it will comply with Commission rules, and certification that the applicant is not subject to denial of federal benefits pursuant to the Anti-Drug Abuse Act of 1988. 47 CFR 63.04, 63.18(a)-(d), (h)-(p), 63.24(e)(2).  


Part 25 Narrative Template for U.S. Space Station License

Part 25 Narrative Template for Market Access for Non-U.S. satellite or system (Petition for Declaratory Ruling)

The legal Narrative provides information pertaining to the proposed system’s space and ground segment, and band-by-band frequency use. It additionally covers how the proposed system will serve the public interest, and whether there are any requests for waivers of the Commission’s rules.  

Separate templates for U.S. licenses and market access petitions are provided.

Technical AnnexDue to the complexity and unique nature of Technical Annex, templates and example documents are not provided.

The Technical Annex provides information (in the form of diagrams, tables, and text) required in section 25.114(d) that is not part of the “fill in the box” format of the Schedule S or other Exhibits.

Some applicants find it helpful to complete a Compliance Matrix, or table of listing each regulation and the corresponding Technical Annex section in which it is covered.

Schedule SSpecific Instructions for Schedule S (April 2016) - updated version forthcoming with ICFS update

The Schedule S contains most of the technical and operational details, primarily included in 25.114(c), pertaining to the space station.

An updated version of Schedule S is planned as part of the forthcoming ICFS update.

Orbital Debris Mitigation Plan Templates and examples are targeted for release by Q2 2024.

ITU Filing Related Materials

ITU SpaceCap Filing (API / CR) Applicants must download the latest version of the ITU SpaceCap software to produce an ITU filing.
To obtain an FCC issued operating agency code, email and request an operating agency code.  You will need to identify a point of contact to receive the ITU invoice for cost recovery fees for your network.  Next you will need to request an FCC issued network name, by emailing and This name will need to be included in the FCC ITU Filing Cover Letter and in the Cost Recovery Letter (templates below). If you do not obtain a FCC issued satellite network name before submitting these ITU related documents, you will be asked to update and resubmit them with the issued satellite network name. 
Note: Please do not attach the SpaceCap filing in ICFS. Instead, email the filing with a .itu file extension, replacing .mdb to Joe Hill and Kathyrn Medley.
ITU Graphical Interference Management System (GIMS) file 

Applicants must download the latest version of the ITU GIMS software, and utilize the tool to document aspects such as beam patterns, and coverage areas.

The ITU provides GIMS exercises and how-to videos on their website.

ITU SpaceVal Output Please supply a screenshot of your SpaceVal output showing no fatal errors (warnings are okay).
FCC Cover Letter for ITU SpaceCap FilingFCC Cover Letter for ITU SpaceCap Filing 
ITU Cost Recovery LetterITU Cost Recovery Template 

The information provided in this webpage is for informational purposes only.  It is not intended to be exhaustive, nor is it intended to serve as legal guidance or precedent.  Most filing requirements are detailed in the Communications Act of 1934, as amended, 47 U.S.C. § 151 et. seq., or the rules of the Federal Communications Commission (“FCC”) found in Title 47 of the Code of Federal Regulations.  Also, some filing requirements are set forth in orders or as conditions to authorizations.  The information provided in this webpage does not amend, replace, or supersede any statute or any rule, order, or authorization adopted by the FCC.   The information provided in this webpage is not controlling in case of discrepancies between this webpage and any statute or any rule, order, or authorization adopted by the FCC.  In all cases, independent research and determination of the applicability of any statute or FCC rule, order, authorization, or requirement is required.  The information provided in this webpage does not bind the FCC and does not create any rights, benefits, expectations, or defenses—substantive or procedural—that are enforceable by any party in any manner.  The FCC retains the discretion to adopt approaches on a case-by-case basis, where appropriate, that may differ from the discussion on this webpage.

[1] See Amendment of Commission's Space Station Licensing Rules and Policies, IB Docket Nos. 02-34, 00-248, Notice of Proposed Rulemaking, FCC 02-45 at 29, para. 84 (2002). As observed in the NPRM, finding an application to be acceptable for filing and for placing on public notice does not imply that the Commission has no questions regarding the application or that the application is being looked upon favorably for grant. NPRM at para. 12.

Friday, October 27, 2023