D-Orbit SpA
D-Orbit
D-Orbit is a global market leader in the space logistics and transportation service industries with a track record of space-proven technologies and successful missions.
ID: 222144794924-51
Lobbying Activity
Response to EU Space Law: Union law for safe, secure and sustainable space activities
7 Nov 2025
D-Orbit appreciates the European Commissions commitment to strengthening Europes role in space and promoting sustainability. The proposed EU Space Act is an important step toward creating a clear framework for space activities, and we welcome the effort to address safety, resilience and responsible operations. At the same time, we believe some aspects of the draft could slow down innovation and make it harder for European companies to compete globally. The current proposal introduces a very broad and complex system of authorisation that would apply to most space activities. For companies like D-Orbit, this could mean multiple overlapping approvals for the same mission or service, creating uncertainty and significant administrative burden. It is not clear whether authorisation would be required for each mission, each satellite, or each type of service, which makes planning and operating difficult. The timelines for authorisation are also a concern. The process could take more than a year and a half, which does not match the fast pace of commercial space activities. Delays of this length could cause companies to miss opportunities and reduce Europes competitiveness. Technical requirements in the proposed Act are extensive and sometimes unclear. They do not always refer to existing international standards, and exemptions for lighter requirements are limited to very small entities. Mid-sized and innovative companies should also benefit from simplified processes. Cybersecurity rules need to be aligned with existing EU legislation to avoid duplication. Supply chain obligations, such as requiring environmental data from all suppliers, may be unrealistic. Many suppliers are small businesses without the resources to provide such data, which could lead to delays and extra costs. These requirements should be proportional and based on standard methods. The governance structure proposed in the Act could create overlaps and inefficiencies if roles and responsibilities are not clearly defined. Adequate resources and streamlined processes will be essential to avoid delays and conflicts. Finally, the definition of Union space operator is very broad and could impose obligations on subsidiaries operating outside the EU, even when they serve non-EU customers. This could discourage international growth and make European companies less competitive. We recommend refining this definition to focus on activities within the EU market. Overall, we support the Commissions objectives and appreciate the progress made so far. We encourage continued dialogue with industry to clarify the rules, ensure proportionality, and align requirements with commercial realities. A balanced framework will help Europe achieve its goals while fostering innovation and growth in the space sector. D-Orbit hopes that the Commission and other EU regulatory bodies will find the attached position and detailed commentary on the proposed EU Space Act useful and we remain committed to provide any further necessary support to help achieve what the Unions ambitious regulatory initiative has envisaged for the space ecosystem.
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