Post-Brexit UK faces realities of EU Space Act

 

The European Commission’s long-awaited unveiling of the EU Space Act on 25 June 2025 marked a pivotal step towards harmonised space governance across the bloc.

Framed around safety, resilience and sustainability, the proposed regulation aims to streamline market access, strengthen cybersecurity and mitigate orbital debris – all while boosting the EU’s strategic autonomy in space.

Yet for those operating outside the EU’s regulatory orbit – notably post-Brexit UK – the Act presents new uncertainties.

These tensions surfaced during this week’s European Space Forum, held in Brussels on 3-4 July, where 450 delegates gathered to discuss the future of Europe’s space ambitions.

During a panel discussion on ‘Delivering Autonomy’, I asked UK government representative William Smith, how the Act might affect UK space operators, now classed as part of a “third country” under EU law.

“I think it's very early days to comment,” he replied. “The UK Government don't have a formal position yet. We acknowledge what [the Act] is trying to do and support any endeavour that is looking to make the orbital environment and space in general more secure, more resilient and safer. That is a collective good, undoubtedly.”

He went on to emphasise the UK’s own regulatory framework: “The UK's regulatory regime is an outcomes-based, agile regime, which works. It's not perfect but we get good feedback from international stakeholders.”

The EU Space Act, still in draft form, outlines the possibility of recognising third-country regulatory regimes as equivalent – but offers no detail yet on how such equivalence would be determined or negotiated.

This leaves UK-based companies potentially facing a dual compliance burden or limitations on market access unless formal agreements are reached.

Without clarity on equivalence, UK firms hoping to provide services within the EU may face fresh licensing or oversight hurdles. The EU’s detailed rules on debris mitigation, cybersecurity and environmental impact may also diverge from UK approaches.

Still, with the proposed implementation date set for 1 January 2030, a transitional window provides space – and time – for dialogue and potential alignment.

While the UK government assesses the fine print, industry voices are likely to press for early engagement to avoid regulatory friction. If managed well, the situation could still evolve into a constructive regulatory partnership that enables innovation and access on both sides.

But Smith’s response, while diplomatic, underscored a recurring theme of constructive ambiguity that characterised much of the European Space Forum.

With no formal UK stance yet, industry remains in a holding pattern, awaiting clarity on whether the country’s agile, outcomes-based regime will be deemed sufficiently compatible.

In the meantime, the EU’s move should be seen as a positive step. It signals a firm commitment to space sustainability, safety and long-term governance – and a timely reminder that access to orbit increasingly comes with strings attached.

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Links: European Space Forum & EU Space Act