JSA Prism | Telecommunications | September 2026

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Authorisation Guidelines for Undertaking Space Situational Awareness Related Activities

On June 25, 2026, the Indian National Space Promotion and Authorisation Centre (“IN-SPACe”), Department of Space, Government of India, released the Norms, Guidelines and Procedures for implementation of the Indian Space Policy 2023 in respect of Authorisation for undertaking Space Situational Awareness (“SSA”) related Activities (“SSA Authorisation Guidelines”). The SSA Authorisation Guidelines are to be read in conjunction with the Norms, Guidelines and Procedures in respect of Authorisation of Space Activities (NGP), May 2024. The SSA Authorisation Guidelines establish a comprehensive framework governing the authorisation of SSA activities by Indian entities, including the establishment and operation of space-based and ground-based SSA sensors, and the provision of SSA services. The SSA Authorisation Guidelines set out definitions, general terms and conditions, activity-specific authorisation requirements, tiered regulatory obligations and detailed reporting, audit and monitoring mechanisms.

The key provisions under the SSA Authorisation Guidelines are as follows:

Scope and Applicability

1. Any Indian entity intending to establish and/or operate SSA facilities or provide SSA services is required to obtain authorisation from IN-SPACe under 3 (three) categories:
   • establishment and/or operations of space-based sensors for SSA related observations;
   • establishment and operations of ground-based sensors for SSA related observations; and
   • providing SSA services.
2. Each SSA activity requires a separate authorisation. However, applicants will not require a separate authorisation for providing SSA services if they intend to disseminate only the SSA Raw Data pertaining to their authorised SSA sensor to their customers/end-users.

Non-Indian Entities

1. Non-Indian entities intending to undertake any SSA activity in India are required to seek IN-SPACe authorisation only through Indian incorporated entities such as Indian subsidiaries, joint ventures, partnerships or collaborations with Indian entities, which will be responsible for compliance with Indian laws, regulations and national security requirements.
2. Consent from both the applicant and the non-Indian entity is required to be furnished to IN-SPACe affirming that complete control over the concerned SSA activity will reside with the applicant and that the jurisdiction will be under Government of India and Indian law. Where the applicant is a subsidiary, joint venture or partnership with a non-Indian entity, the applicant is required to disclose the extent of control exercised by the Indian entity, and a risk assessment will be undertaken by the Government of India.

Exemptions from Authorisation

1. Individual hobbyists, amateurs, formal/informal groups and academic entities are exempt from IN-SPACe authorisation provided that their activities are non-commercial, the ground-based SSA sensor hardware and software systems meet the prescribed technical thresholds, and SSA data dissemination is limited to general interest, hobbyist forums or public/academic education and research. Academic entities are, however, required to intimate IN-SPACe about their ground-based SSA sensor installations;
2. Any entity in India can source SSA raw data for their self-use from any Indian or non-Indian entity without authorisation. However, an Indian entity intending to supply, sell or disseminate SSA Raw Data to any Indian or non-Indian entity must seek IN-SPACe authorisation for providing SSA services;
3. IN-SPACe authorised satellite owners/operators, launch operators and academic entities are exempt from authorisation for availing basic SSA services or exchanging SSA data for their own-use or for research and development purposes;
4. SSA data and SSA services for space safety published or made available by recognised international or academic sources are exempted from IN-SPACe authorisation.

Authorisation Tiers

1. The SSA Authorisation Guidelines adopt a two-tiered regulatory approach that scales obligations proportionate to risk and sensitivity levels:
2. restricted tier i.e., applicable to SSA activities of a sensitive nature or high security relevance, requiring enhanced authorisation terms and conditions, reporting and audit mechanisms; and
3. controlled tier i.e., applicable to all other SSA activities, with standard and simplified regulations aimed at ease of doing business.
4. Applicants with non-Indian management and control, or those intending to provide SSA data or services to a non-Indian government or to a non-Indian entity for defence or security purposes, or those establishing ground-based SSA sensors outside India, fall under the restricted tier.
5. Applicants are required to self-assess and declare the applicable tier in their application to IN-SPACe. IN-SPACe reserves the right to reclassify an application under a different tier, and once authorised, the applicant must seek prior approval of IN-SPACe before undertaking any SSA activity under a different tier.

Space-Based SSA Sensors

1. Establishment and/or operations of any space-based SSA sensor owned and/or operated by an Indian entity requires one-time IN-SPACe authorisation. Separate authorisation is required for associated ground systems such as data reception stations and telemetry, tracking and command stations.
2. The applicant must have absolute decision-making powers (full operational authority) with regard to the operations and control of the SSA sensor, and must be able to cease the operations of the SSA sensor without any delay, as and when directed by IN-SPACe for national security and geopolitical considerations.
3. Space-based SSA sensors are not permitted to collect data pertaining to ground establishments or activities, and applicants intending to use SSA sensors for remote sensing applications are required to seek separate authorisation.
4. Under the Restricted Tier, SSA data received using ground stations outside Indian territory must be routed through India before dissemination, and third-party or foreign-located mission control centres are not permitted. Under the Controlled Tier, third-party mission control centres within or outside Indian territory are permitted where the SSA sensor is hosted on an Indian or non-Indian satellite.

Ground-Based SSA Sensors

1. Establishment and operations of ground-based SSA sensors within or outside Indian territory by Indian entities requires one-time IN-SPACe authorisation, which will normally have a validity of 10 (ten) years.
2. Existing ground-based SSA sensors which are already operational within or outside Indian territory by an Indian entity are required to be regularised through IN-SPACe authorisation by May 31, 2027. With effect from June 1, 2027, only IN-SPACe authorised ground-based SSA sensors will be permitted to operate.
3. Remote access from outside India to control authorised ground-based SSA sensors is governed by prescribed guidelines, including requirements for monitoring, audit trails and multifactor authentication.
4. Under the Restricted Tier, ground-based SSA sensors established outside Indian territory are required to route SSA data through India before dissemination, and enhanced logging, reporting and audit mechanisms apply. Under the Controlled Tier, academic entities are eligible for fast-track authorisation processing.

Providing SSA Services

1. An Indian entity intending to provide SSA services is required to obtain one-time authorisation from IN-SPACe valid for 5 (five) years. End-users in India are required to avail SSA services or SSA data only from IN-SPACe authorised SSA service providers, subject to certain exemptions.
2. Authorised SSA service providers are required to indemnify the Government of India against any claim made by customers, end-users or third parties for damage or loss arising from the services provided by them.
3. Under the Restricted Tier, dissemination of SSA data or services to customers/end-users through captive network or commercial cloud is required to be hosted on servers in India, and enhanced logging, reporting and audit mechanisms apply.

Security, Data Governance and Compliance

1. Applicants are required to employ appropriate safety and security measures, including physical security, cyber security resilience, encryption mechanisms, disaster recovery systems and immutable activity logs.
2. Applicants are required to comply with the Cyber Security Framework and Guidelines for Space including Satellite Communication (dated February 26, 2026) as the baseline framework and are mandated to carry out periodic cyber security audits and inform IN-SPACe of any security or data breach within 1 (one) week of detection.
3. Procurement of components, systems, hardware and software is required to be undertaken only from trusted sources, following the Government of India’s Trusted Telecom Directive and National Security Directive on Telecommunication Sector.

Government Rights and Data Sharing Obligations

1. Authorised entities are required to share SSA data with the Government of India, upon request, on a non-discriminatory basis for purposes of national security and India’s international commitments, subject to fair market value compensation.
2. The Government of India reserves the right, in circumstances of national emergency or crisis affecting national security, to take over or direct the operation of any authorised SSA infrastructure, subject to reasonable compensation, provided that no entity will be compelled to violate applicable foreign export control laws or binding international sanctions.
3. The Government of India reserves the right to designate certain resident space objects which must not be identified or catalogued while providing SSA services, for national security requirements.
4. End-use cum end-user certificates are required to be obtained and maintained by applicants from their customers/recipients while disseminating SSA data or providing SSA services, and such certificates are required to be maintained for 3 (three) years.

Reporting, Audit and Monitoring

1. Applicants are required to maintain complete and immutable activity logs for up to 3 (three) years and submit periodic reports to IN-SPACe on the IN-SPACe Digital Platform every 6 (six) months.
2. IN-SPACe or any other authorised agency of the Government of India reserves the right to carry out periodic or random audits and inspections (on-site or off-site) and may suspend or terminate an authorisation upon detection of violations.
3. The export of any SSA data or SSA services is subject to applicable Indian export control laws. IN-SPACe may also develop standards, protocols and benchmarks for SSA services in consultation with industry stakeholders.

Conclusion

The SSA Authorisation Guidelines represent a significant step in implementing the Indian Space Policy 2023’s framework for regulating SSA activities. By introducing distinct authorisation categories and a two-tiered regulatory approach calibrated to risk and sensitivity levels, the SSA Authorisation Guidelines seek to balance innovation and commercial participation with national security considerations. From an industry perspective, the tiered approach and exemptions are likely to be viewed positively, although stakeholders will closely assess the impact of the extensive compliance, security and reporting requirements, particularly for entities with non-Indian participation. The requirement to regularise existing ground-based SSA sensors by May 31, 2027, sets a near-term compliance milestone. Overall, the SSA Authorisation Guidelines are expected to serve as an important milestone in developing a structured regulatory framework for SSA activities in India.

This Prism has been prepared by:

Tony Verghese Partner

Radhika Gupta Partner

For more details, please contact km@jsalaw.com.