Office of Space Commerce Seeks US Stakeholder Perspectives on Indian Space Operation and Investment

Purpose: The Office of Space Commerce (OSC) seeks industry feedback from operators currently operating in, investing in, or intending to operate or invest in the civil Indian space markets. This feedback will inform OSC’s continued participation in the Commercial Space Sub-Working Group (CSSwG), a subgroup of the US-India Civil Space Joint Working Group (CSJWG). The CSJWG, established in 2005, provides a bi-lateral framework for “structured collaboration, to address challenges promptly, and to pursue mutual goals.” In turn, the CSSwG subgroup focuses on four primary areas of interest: (1) market access, (2) export controls, (3) government procurement, and (4) foreign direct investment. Industry perspectives will assist the US Government identify and prioritize issues for the CSSwG and other US-India government engagements in 2026 and beyond.

Background: Against the backdrop of President Trump’s December 18, 2025 Executive Order on space policy, entitled “Ensuring American Space Superiority,” OSC provides background on India’s domestic space policy, which was reformed in 2023 and 2024. The Indian space policy, comprised predominantly of regulatory guidance, includes guidance on launch, satellite operations (to include remote sensing), and ground station operations.

Additionally, OSC outlines the 2025 Indian framework for Foreign Direct Investment (FDI policy) applicable to Indian civil space activities but also notes that US companies must incorporate an Indian subsidiary or joint venture to take advantage of this policy.

As of 2025, India’s Space FDI Policy allows up to 100% foreign investment, categorized as follows:

  • Manufacturing Components and Systems: 100% FDI is allowed via the automatic route for manufacturing components, systems, or sub-systems related to satellites, ground segments, and user segments.
  • Satellite Manufacturing and Operation: FDI up to 74% is permitted under the automatic route, but anything exceeding this limit requires government approval.
  • Launch Vehicles and Spaceports: Up to 49% FDI is allowed under the automatic route while requiring government approval beyond this threshold.

And, in 2024, India established a $120M Space Venture Capital Fund to co-invest alongside foreign capital in Indian space startups, to be deployed over five years.

Known Challenges:

OSC identifies the following challenges for US companies and investors seeking to operate or invest in India:

  • India Space Policy 2023 and the 2024 Norms, Guidelines, and Procedures (NGP) restrictions on foreign-owned space services, and FDI Policy, requiring the setup of an Indian subsidiary or joint venture to proceed.
  • India’s government contracts require 50% local content/manufacturing and a purchase preference (usually a 20% margin) over foreign-affiliated firms.
  • Issues with timely access to testing and space-related infrastructure in India.
  • Concerns with India’s protocols protecting US companies’ intellectual property.
  • Difficulties navigating the process for frequency allocation and landing rights in India.
  • Challenges concerning US export control and US tariffs.

Key Areas of Input Sought: OSC seeks feedback on the following issues:

  1. Whether any Indian domestic regulations have demonstrably restricted US participation in the Indian market;
  2. Whether the current Indian regulatory and legal framework permit US organizations to compete equitably with domestic Indian organizations;
  3. Whether specific elements within India’s guidelines (e.g., NGP, DST, or others) present compliance challenges for US organizations;
  4. What challenges do US companies encounter or anticipate when establishing a space-focused subsidiary or co-venture in India;
  5. The India’s Space Venture Capital Fund’s application process;
  6. Comments or observations regarding conducting business operations in India; and
  7. OSC also seeks to understand of US operators’ experiences or challenges with Indian Remote Sensing regulation, including the impact of regulation upon licensing, data access and restrictions, and downstream service provision.

OSC’s Instructions for Communications:

OSC will accept input via a google form with these prompts, or via email: Space.Commerce@noaa.gov, with the subject line: “Call for Input – India” Input is due on January 30, 2026.

Conclusion:

Jenner & Block’s Space Practice is providing this update for interested companies. We stand ready to help respond to this notice, as needed. Our integrated team brings practical insight from years of guiding clients through complex spectrum, export control, contracting, and intellectual property challenges—helping organizations strengthen compliance and accelerate innovation across satellite communications, launch services, Earth observation, and space infrastructure.

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Office of Space Commerce Seeks US Stakeholder Perspectives on Indian Space Operation and Investment

Purpose: The Office of Space Commerce (OSC) seeks industry feedback from operators currently operating in, investing in, or intending to operate or invest in the civil Indian space markets. This feedback will inform OSC’s continued participation in the Commercial Space Sub-Working Group (CSSwG), a subgroup of the US-India Civil Space Joint Working Group (CSJWG). The CSJWG, established in 2005, provides a bi-lateral framework for “structured collaboration, to address challenges promptly, and to pursue mutual goals.” In turn, the CSSwG subgroup focuses on four primary areas of interest: (1) market access, (2) export controls, (3) government procurement, and (4) foreign direct investment. Industry perspectives will assist the US Government identify and prioritize issues for the CSSwG and other US-India government engagements in 2026 and beyond.

Background: Against the backdrop of President Trump’s December 18, 2025 Executive Order on space policy, entitled “Ensuring American Space Superiority,” OSC provides background on India’s domestic space policy, which was reformed in 2023 and 2024. The Indian space policy, comprised predominantly of regulatory guidance, includes guidance on launch, satellite operations (to include remote sensing), and ground station operations.

Additionally, OSC outlines the 2025 Indian framework for Foreign Direct Investment (FDI policy) applicable to Indian civil space activities but also notes that US companies must incorporate an Indian subsidiary or joint venture to take advantage of this policy.

As of 2025, India’s Space FDI Policy allows up to 100% foreign investment, categorized as follows:

  • Manufacturing Components and Systems: 100% FDI is allowed via the automatic route for manufacturing components, systems, or sub-systems related to satellites, ground segments, and user segments.
  • Satellite Manufacturing and Operation: FDI up to 74% is permitted under the automatic route, but anything exceeding this limit requires government approval.
  • Launch Vehicles and Spaceports: Up to 49% FDI is allowed under the automatic route while requiring government approval beyond this threshold.

And, in 2024, India established a $120M Space Venture Capital Fund to co-invest alongside foreign capital in Indian space startups, to be deployed over five years.

Known Challenges:

OSC identifies the following challenges for US companies and investors seeking to operate or invest in India:

  • India Space Policy 2023 and the 2024 Norms, Guidelines, and Procedures (NGP) restrictions on foreign-owned space services, and FDI Policy, requiring the setup of an Indian subsidiary or joint venture to proceed.
  • India’s government contracts require 50% local content/manufacturing and a purchase preference (usually a 20% margin) over foreign-affiliated firms.
  • Issues with timely access to testing and space-related infrastructure in India.
  • Concerns with India’s protocols protecting US companies’ intellectual property.
  • Difficulties navigating the process for frequency allocation and landing rights in India.
  • Challenges concerning US export control and US tariffs.

Key Areas of Input Sought: OSC seeks feedback on the following issues:

  1. Whether any Indian domestic regulations have demonstrably restricted US participation in the Indian market;
  2. Whether the current Indian regulatory and legal framework permit US organizations to compete equitably with domestic Indian organizations;
  3. Whether specific elements within India’s guidelines (e.g., NGP, DST, or others) present compliance challenges for US organizations;
  4. What challenges do US companies encounter or anticipate when establishing a space-focused subsidiary or co-venture in India;
  5. The India’s Space Venture Capital Fund’s application process;
  6. Comments or observations regarding conducting business operations in India; and
  7. OSC also seeks to understand of US operators’ experiences or challenges with Indian Remote Sensing regulation, including the impact of regulation upon licensing, data access and restrictions, and downstream service provision.

OSC’s Instructions for Communications:

OSC will accept input via a google form with these prompts, or via email: Space.Commerce@noaa.gov, with the subject line: “Call for Input – India” Input is due on January 30, 2026.

Conclusion:

Jenner & Block’s Space Practice is providing this update for interested companies. We stand ready to help respond to this notice, as needed. Our integrated team brings practical insight from years of guiding clients through complex spectrum, export control, contracting, and intellectual property challenges—helping organizations strengthen compliance and accelerate innovation across satellite communications, launch services, Earth observation, and space infrastructure.

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

News and Insights

Podcasts

Partner Laurel Loomis Rimon Discusses Fintech Enforcement, Debanking, and Regulatory Risk on Fintech Layer Cake Podcast

Partner Laurel Loomis Rimon was featured on the Fintech Layer Cake podcast, where she discussed how fintech enforcement and prosecution actually work in practice, and what exposes fintechs and banks to regulatory risk.

July 15, 2026

Publications

Supreme Court Clarifies Scope of Private Rights of Action Under the Investment Company Act, Private Equity Law Report

Partners Charles Riely, Todd C. Toral, and Martin Glass authored a guest article for Private Equity Law Report examining the US Supreme Court's June 11, 2026, ruling on the scope of private rights of action under the Investment Company Act of 1940.

July 14, 2026

Publications

Emily Loeb Discusses Congressional Oversight Preparedness in Bloomberg Law

Partner Emily Loeb, co-chair of Jenner & Block's Congressional Investigations Practice, spoke with Bloomberg Law article about how companies can prepare for potential oversight exposure ahead of this fall's midterm elections.

July 7, 2026

Publications

In New York Law Journal, The True Lender Doctrine and the OppFi Decision

Partners Jeremy Creelan, Michael Ross, Megan Poetzel, and Laurel Loomis Rimon, and Associate Molly Oberstein-Allen authored an article for the New York Law Journal examining the "True Lender" doctrine in light of a May 2026 California decision that provides the most detailed judicial framework to date for evaluating bank-nonbank lending partnerships.

July 1, 2026

Event

Partner Michael Vernick to Speak at NACUA's 2026 Annual Conference

On July 1, Partner Michael Vernick will speak on a panel at the National Association of College and University Attorneys (NACUA) 2026 Annual Conference in Nashville.

July 1, 2026