UK’s first space sandbox: clearing the path for in-orbit operations

In-orbit missions are an exciting new phase for the space sector, including in-orbit servicing, docking, refuelling, and debris removal missions. These missions are classed as Rendezvous and Proximity Operations (RPO) and are an emerging area critical to space sustainability and commercial opportunity,

On 20 August 2025, the Stage 1 Independent Public Report for the UK's first space-focused regulatory sandbox, dedicated to RPO, was released by the RPO Operators Consortium. 

The RPO Operator's Consortium includes Astroscale, ClearSpace and D-Orbit, the Department for Science, Innovation and Technology (DSIT), with the participation of the Civil Aviation Authority (CAA) and the United Kingdom Space Agency (UKSA).

Purpose & Background

Stage 1 aimed to evaluate and enhance the UK’s licensing framework for novel RPO missions, partly via a simulated licensing process under the Space Industry Act 2018, the Space Industry Regulations 2021, and relevant guidance. This builds directly on the UK’s Space Regulatory Review 2024, which emphasised the need for regulatory clarity and flexibility to support new mission types.

Results

Existing framework is permissive, but not designed with RPO in mind

The Sandbox Report concluded that RPO missions are not explicitly addressed by current laws (including the Outer Space Act 1986, Space Industry Act 2018, and Space Industry Regulations 2021). Those provisions were crafted with traditional satellite launches and operations in mind, not dynamic, multi-phase proximity operations. This mismatch generates ambiguities and operational friction for applicants. 

Fragmentation and uncertainty

Operators must navigate a fragmented regulatory landscape where multiple government bodies intersect, leading to unclear guidance, inconsistent expectations, and a higher administrative burden. The Sandbox Report highlighted a lack of cohesive regulatory ownership: even though the CAA is formally the licensing authority, clarifications from other agencies are needed.

This patchwork approach presents certain challenges for operators to navigate and interpret, particularly for operators of innovative missions, such as RPO, which do not neatly fit into the existing definitions, licences, and regulatory requirements.  These challenges can lead to delays and additional costs, which can be detrimental to the operators and to the UK's global competitiveness.

Regulatory gaps across key areas

Gaps for RPO missions specifically surfaced with respect to:

• Liability regimes (e.g., how damage or collision risks are covered across RPO phases).
• Insurance demands for indefinite-duration operations.
• Safety requirements, such as demonstrating As Low As Reasonably Practicable (ALARP) in complex contexts.
• Spectrum management, particularly allocation consistency and access for proximity operations.
• Security oversight, especially in missions involving cross-border elements.
• Sustainability considerations aligned with orbital debris norms.

Recommended reforms

The Sandbox Report flags 61 recommendations. Legally focused recommendations include:

• Clearer statutory and guidance language tailored to RPO/ISAM (In-Orbit Service and Manufacture) scenarios.
• Cohesive, consolidated guidance across regulatory bodies to reduce ambiguity.
• Defined liability frameworks and insurance guidance for RPO operations.
• Standardised safety demonstration processes suitable for multi-stage missions.
• Streamlined licensing workflows and templates for predictable approvals.
• Enhanced provisions for spectrum coordination and long-term sustainability criteria.

Next steps

Stage 1 establishes a blueprint for Stage 2, which will dive deeper into licensing specifics and implementation of the recommendations. The insights also underpin the UK’s upcoming active debris removal mission by 2028, providing the legal footing needed for such a high-profile launch. 

Our analysis

The space sector faces similar regulatory challenges to any fast moving and innovative industry, where the evolution of technology and opportunities invariably outpaces the evolution of the applicable regulations.

The Sandbox Report offers a comprehensive legal and regulatory diagnosis, and prescription, for a nascent but strategically critical segment of the UK’s space future. It confirms that, while licensing such missions is legally feasible, the existing regime can be confusing, leading to inefficiency and risk.

This is not the first time UK space licensing requirements have come under criticism of this nature. The space sector sits at a complex juncture of various regulatory bodies and necessarily has international aspects woven throughout. The recommendations from the Sandbox Report aim to simplify this for RPO missions by enhancing clarity, cohesion, and predictability.

From a legal perspective, the return on a coherent and streamlined regulatory process isn’t just financial: it includes improved regulatory trust, enhanced sustainability, international credibility, and strengthened positioning for the UK in global RPO licensing and standards. Paving the way for a robust, competitive UK space ecosystem capable of deploying complex RPO missions with confidence.

Given the broad application and rapid evolution of RPO and ISAM missions, the real challenge here will be to quickly implement regulatory improvements that benefit current and future missions, which work alongside and compliment other non-regulatory focused industry drivers (such as industry best practice and sustainability goals) without causing unforeseen consequences which could impact future technologies and opportunities. Not an easy task, but a worthwhile one.

Our team of space lawyers continues to be involved in this emerging market – contact us to discuss how we can support your space business.