JSA Prism | Telecommunications | September 2026

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Indian National Space Promotion and Authorisation Centre notifies framework for authorisation of hosted payloads

The Indian National Space Promotion and Authorisation Centre (“IN-SPACe”), Department of Space, released the Norms, Guidelines and Procedures for Implementation of Indian Space Policy-2023 in respect of Authorisation for Establishment and/or Operation of Hosted-Payloads (“Guidelines”) on September 17, 2026. The Guidelines should be read with the principal Norms, Guidelines and Procedures for Authorisation of Space Activities issued in May 2024 (“NGP”). For the first time, the fast-growing Satellite as a Service (“SaaS”) model has a dedicated authorisation pathway, turning spare satellite bus capacity into a monetisable, but closely regulated asset for satellite communication providers, telecom operators and space start-ups.

Key concepts and scope

Hosted-payloads

• Instruments, transponders or systems owned by 1 (one) entity and housed in (or forming part of) a third-party-owned satellite bus, to use available capacity or avail SaaS. Payloads hosted on the orbiting stage of a launch vehicle, such as the PSLV Orbital Experimental Module (“POEM”), also qualify.
• The hosting satellite bus or launch-vehicle stage is the host space-object (“Host Space-Object”), its owner the Host Entity (“Host Entity”), and the payload owner the Hosted-Payload Owner (“Hosted-Payload Owner”).
• The Guidelines expressly permit Indian entities to offer SaaS to Indian and non-Indian customers, providing the bus with or without International Telecommunication Union (“ITU”) filing support, ground stations or payload operations. The IN-SPACe may consider such satellites for entry into the National Registry of Space Objects.
• Hosted payloads may serve any purpose, including communication, remote sensing, navigation, meteorology, scientific observation, technology demonstration, in-orbit experiments and space situational awareness, and the relevant NGP provisions govern their operations.

Who needs authorisation?

The Guidelines classify hosted payloads into 3 (three) categories:

• payloads of Indian entities on non-Indian Host Space-Objects;
• payloads of Indian or non-Indian entities on Indian Host Space-Objects; and
• payloads on POEM or similar platforms.

Any hosted payload owned by an Indian entity requires IN-SPACe authorisation, whether the host satellite is Indian or foreign, and a single application may cover multiple payloads. A non-Indian entity needs no separate authorisation; the Indian Host Entity must instead disclose complete payload details in its own application.

Indian payloads on foreign satellites

• The applicant must submit its contract with the foreign Host Entity and promptly notify IN-SPACe of any modification during processing and throughout the validity of the authorisation.
• The Hosted-Payload Owner must retain absolute decision-making powers over the payload’s operations and control.
• The contract must place all risks relating to the Host Space-Object unconditionally on the foreign Host Entity, which must fully indemnify the payload owner and the Government of India. The foreign Host Entity must also bear liability under the 1972 Liability Convention and effect registration under the 1974 Registration Convention.
• The applicant must furnish the foreign administration’s licence for the Host Space-Object and details of the ITU filings under which the host and payload will operate.

Foreign payloads on Indian satellites

• Absolute ownership and control of the Host Space-Object must remain with the Indian Host Entity, under Indian jurisdiction and law. The payload owner may operate its payload, but the Host Entity must always be able to switch it off or cease emissions on demand of IN-SPACe/Government of India for national security, radio frequency interference or other critical reasons.
• The foreign payload owner must hold approvals from its own administration (including a valid ITU filing, if applicable), must not cause harmful interference to services using Government of India–assigned frequencies, and must comply with the host’s ITU filing parameters.
• Capturing data over Indian territory requires IN-SPACe approval. The Host Entity must retain records for at least 6 (six) months and must disseminate data in accordance with the NGP data dissemination guidelines. If it does not, IN-SPACe may direct a switch-off.
• The foreign payload owner must indemnify the Host Entity and the Government of India against third-party liability claims.

Spectrum, ITU and telecom licensing interface

Hosted payloads must operate under a valid Indian or non-Indian ITU filing, and either the payload owner or the Host Entity may hold the rights of use. New filings and orbital resource access follow Chapter VI of the NGP. New Indian filings require an interference analysis protecting incumbent Indian and IN-SPACe-authorised systems, unless a coordination or coexistence agreement already exists. In the telecom sector, applicants must disclose the status of their Department of Telecommunications (“DoT”) operating and service licences, including clearances for Indian ground stations, and must undertake to cease emissions if IN-SPACe so directs because harmful interference remains unresolved within a reasonable notice period. IN-SPACe Authorisation therefore complements DoT licensing for satcom services; it does not replace it.

Application, disclosure and validity

• The application form requires detailed ownership and control disclosures, covering 100% direct and indirect shareholding, Indian management and control, and foreign direct investment details, including route and downstream investment. Applicants must also provide net worth, 3 (three) years of audited financials, criminal antecedent and insolvency declarations, and a security clearance proforma.
• Technical submissions cover payload specifications, hazardous material safety, space situational awareness data and an ITU proforma for fresh filings.
• The applicant must report any change in management, control or shareholding within 48 (forty-eight) hours.
• Authorisation co-terminates with the earlier of the hosting contract’s validity or the Host Space-Object’s operational life. Extensions are at IN-SPACe’s sole discretion.
• The Government may control operations or order a switch-off during conflicts, natural disasters or declared emergencies.

Conclusion

The Guidelines bring clarity to a commercially significant segment, allowing Indian operators to monetise spare bus capacity and Indian payload developers to access foreign platforms. The framework is, however, heavily contract-driven: IN-SPACe will scrutinise hosting agreements for control, liability, registration, data handling and switch-off provisions, and parties must report any amendment. Stakeholders should review existing and proposed hosting arrangements for conformity, map parallel DoT licensing requirements early, and factor foreign investment, security clearance and data-localisation considerations into deal structuring.

This Prism has been prepared by:

Tony Verghese Partner

Radhika Gupta Partner

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