Independent report

Regulatory Sandbox for Rendezvous and Proximity Operations: Stage 1 report

Published 20 August 2025

This is an independent report and does not represent government policy.

1. Executive summary

This independent report presents the outputs of Stage 1 of the regulatory Sandbox (hereafter, the Sandbox) for Rendezvous and Proximity Operations (RPO) – a project delivered by the RPO Operators Consortium (hereafter, the Consortium) composed of Astroscale, ClearSpace and D-Orbit, for the Department for Science, Innovation and Technology (DSIT), with the participation of the Civil Aviation Authority (CAA) and the United Kingdom Space Agency – between December 2024 and March 2025. The principal outputs are the Sandbox methodology, which can be used for other future sandboxes, and a set of identified challenges for RPO operators with recommendations to address them. The report also presents other findings of the Sandbox, including on spectrum challenges, insurance considerations, and the economic impact assessment of the Sandbox.

The independent report integrates Consortium analyses based on stakeholder workshops and an iterative simulation of the licensing of a hypothetical yet realistic RPO mission. The aim is to provide DSIT, the UK Space Agency and the CAA with a list of actionable recommendations to make the UK the place of choice for licensing RPO missions.

1.1 Project overview

Stage 1 of the Sandbox was designed to assess and enhance the UK’s legal and regulatory environment for in-orbit servicing (IOS), debris removal, and other space missions involving RPO. These so-called RPO missions, which can involve performing inspections, docking with another satellite, delivering orbital corrections, or removing debris, are expected to play a growing role in sustainable and commercially driven space operations.

Rationale

• The Sandbox responds to the UK government’s Space Regulatory Review 2024, which underscored the need for clearer, more effective licensing processes to accommodate emerging technology and mission types.
• RPO missions involve distinctive technical and legal challenges, such as varying levels of spacecraft cooperation, indefinite mission scopes, cross-border involvement, and dynamic risk profiles, that necessitate closer scrutiny and potential regulatory adaptation.

Sandbox approach

• Iterative Testing: A “sandbox” mechanism was used to simulate the end-to-end licensing process for a fictional RPO mission under the Space Industry Act 2018 (SIA 2018), the Space Industry Regulations 2021 (Regulations) and associated guidance.
• Collaborative Engagement: Regulators, industry and government stakeholders, insurers, and technical experts convened in dedicated workshops and mock application exercises to explore gaps in the existing framework and to propose practical recommendations.

1.2 Objectives

Stage 1 sought to address 4 key objectives:

1. Develop and test a minimum viable product (MVP) for licensing
   • Create a robust, representative test case (a realistic yet fictitious mission concept) that would reveal current bottlenecks in licensing, legislation, policy and guidance, and enable stakeholders to propose realistic improvements through recommendations.
2. Identify and map UK licensing gaps
   • Investigate points of confusion or conflict within legislation, regulations, and guidance, particularly regarding insurance, security, liability, safety, and sustainability requirements for multi-year RPO missions.
3. Strengthen stakeholder confidence
   • Offer a transparent, data-driven forum for government, regulators, operators, and insurers to exchange views, refine approaches, and build trust in the UK’s capacity to regulate and license complex RPO activities.
4. Lay foundations for future policy and regulatory phases
   • Produce immediate, actionable recommendations to better align current practices with industry needs, while forming the foundation for Stage 2 (more advanced simulations) and Stage 3 (final validation).

1.3 Methodology

An iterative delivery model was employed, combining simulated licensing exercises, targeted stakeholder workshops, and detailed technical assessments. Key steps in the methodology included:

Regulatory workshops

• Engaged with the CAA, the UK Space Agency, and DSIT to clarify the legislative framework and agree on focal points for the sandbox (e.g., liability caps, ALARP assessments, security checks, etc.).

Target mission concept (TMC)

• Developed a fictitious RPO space activity within UK jurisdiction, performing up to three servicing tasks (life-extension, debris removal, controlled de-orbit) to simulate both cooperative and non-cooperative client objects.
• Incorporated realistic mission parameters to reflect uncertainties, multi-year timelines, and indefinite client spacecraft identification.

Iterative licensing simulations

• Conducted a mock licensing application using a tailored subset of the CAA’s Technical Question Set (TQS), focusing on key topics (e.g., ALARP safety demonstration, in-orbit changes, client spacecraft not defined by the moment a licence is granted, etc.).
• Captured regulator feedback to assess the completeness, clarity, and coherence of the existing Acts, Regulations, policy, and guidance.

Expert workshops

• Liability & Insurance: Explored the feasibility of third-party liability (TPL) insurance for novel RPO missions, the applicability of standard liability caps, and potential new paradigms that reward sustainability-enhancing activities.
• Spectrum and communications: Evaluated ITU processes, frequency allocations, and steps to ensure timely licensing of mission-critical communications and spectrum access for RPO missions.
• Cross-Industry Perspectives (Catapult Sessions): Gathered direct feedback from prospective RPO operators and customers on commercial feasibility, technical readiness, and perceived legal and regulatory barriers.

1.4 Key Stage 1 achievements

Aside from the key achievements related to the identification of challenges and development of recommendations summarised in section 1.5, the Sandbox Stage 1 has produced the following 2 key outputs:

1. Successfully piloted an RPO-focussed MVP

• Designed a representative RPO mission (the TMC) to “stress-test” licensing complexities across multiple mission phases (rendezvous and docking with both cooperative and non-cooperative client objects, inclination correction, controlled re-entry).
• Demonstrated how existing UK licensing processes can cover advanced RPO missions, while also highlighting key challenges.

2. Established productive stakeholder collaboration

• Brought together government, regulators, insurers, and industry for a structured exchange of ideas in a neutral or ‘safe’ forum.
• Demonstrated that collaborative “sandbox” environments can bridge knowledge gaps and reduce uncertainty, thereby driving more predictable licensing timelines and better commercial outcomes.
• Established foundational insights to guide subsequent project stages.

1.5 Stage 1 challenges and recommendations

Since singling out specific challenges and recommendations while summarising them concisely fails to acknowledge the breadth of work accomplished during Stage 1 and risks misinterpretation, the Consortium encourages the reader to explore the details in section 4 of this report.

Based on extensive dialogues, licensing simulations, and expert workshops, Stage 1 has identified 61 challenges to the licensing of RPO missions. The common themes among the challenges identified in the current regulatory framework are primary legislation, regulation and guidance that (1) have gaps or are not clear enough for RPO operators to understand how to comply (i.e., knowing what is expected in terms of evidence and demonstration, what is required, and what is acceptable) or (2) are not targeted and proportionate. There is especially uncertainty for RPO operators regarding the regulator’s approach to safety assessments, as well as requirements associated with sustainability and security.

Some of the identified bottlenecks and uncertainties include:

• challenges related to the interpretation of “operating a space object” under the SIA 2018 when the RPO operator physically controls the client spacecraft.
• uncertainties over the scope of ALARP demonstrations in orbit, the applicability and scope of sustainability requirements, as well as key challenges with security regulations.
• lack of guidance on how to handle indefinite or multi-service missions, on the regulator’s involvement in RPO missions’ operational decisions, and on expected information on customers and the client space objects.

Stage 1 has identified more than 61 targeted recommendations for HMG and the regulator to strengthen the UK regulatory environment for RPO missions. The recommendations proposed are all aimed at providing a clear, transparent, proportionate and predictable regulatory framework. Some examples of recommendations are summarised below:

Improve clarity and predictability

• Issue guidance confirming that the UK’s existing framework, particularly section 1(4) of the SIA 2018, covers RPO missions under “operating a space object,” while clarifying who is legally considered the operator and who merely has technical control.
• Align primary, secondary legislation and guidance to provide clear and coherent obligations and requirements (e.g., RPO-specific requirements and information, mission-specific environmental assessments).

Optimise licensing pathways

• Envelope-Based Licensing: Create a mechanism for awarding a single orbital operator licence that covers multiple prospective client satellites, provided each fits within an approved envelope.
• Efficient Variations Process: Clarify where minor mission modifications (e.g., additional station-keeping burns) only require notification rather than a formal licence variation.

Tailor ALARP for orbital risks

• Develop a specialised risk assessment methodology for in-orbit safety assessment.
• Provide additional guidance akin to CAP 2220 that clarifies how licensees can demonstrate ALARP for RPO missions.

Update liability and insurance requirements

• Formalise variable liability caps so that sustainability-enhancing activities may benefit from lower indemnification limit or even zero liability caps.
• Ensure that all insurance obligations align with statutory authority in SIA 2018 or OSA 1986, avoiding confusion over when or how third-party liability coverage is mandated and that clear guidance outlines conditions and approach in respect of RPO missions.

Streamline national security and sustainability assessments

• Clearly define a consistent threshold for what constitutes “national security impairment” or “issues” under SIA 2018, limiting the need for security managers or additional screening to missions with identifiable risk.
• Translate international space debris mitigation guidelines (e.g., IADC, LTS) into clear licensing requirements – while ensuring that non-binding guidelines or best practice documents are not applied as if they were mandatory regulations, unless supported by formal legislation.