The Use of Satellite to Supplement Mobile Coverage October 2025 The GSMA is a global organisation unifying themobile ecosystem to discover, develop and deliverinnovation foundational to positive businessenvironments and societal change. Our vision isto unlock the full power of connectivity so thatpeople, industry and society thrive. Representingmobile operators and organisations across themobile ecosystem and adjacent industries, theGSMA delivers for its members across three broadpillars: Connectivity for Good, Industry Servicesand Solutions, and Outreach. This activity includesadvancing policy, tackling today’s biggest societalchallenges, underpinning the technology andinteroperability that make mobile work, and providingthe world’s largest platform to convene the mobileecosystem at the MWC and M360 series of events. We invite you to find out more at gsma.com Contents Introduction2 GSMA positions on spectrum for D2D4D2D in IMT spectrum4D2D in mobile satellite (MSS) spectrum7 International coordination and the ITU8 Introduction Direct-to-Device (D2D) describes connectivitybetween satellites and mobile handsets. The use ofsatellite connectivity as part of a mobile network cansupplement a terrestrial operator’s network coverage.Providing this broader coverage layer can help mobileto reach further into sparsely populated or inaccessiblelocations. D2D infrastructure can also provide an addedlayer of network resilience: signals from satellites canstill be received in the event of terrestrial networkoutage, including support for emergency serviceswhere terrestrial networks fail. D2D can provideconnectivity after natural disasters and it can digitallyempower crisis-affected communities during times ofhumanitarian intervention. or national parks. It can also help connect part of theunconnected who live outside coverage of mobilebroadband networks (the coverage gap), estimatedat 4% of the global population. However, policies onsupplemental satellite services should go hand in handwith other policy reforms to connect the 38% of theglobal population that live within the mobile footprintand are not connected (the usage gap). The usage gapis caused by lack of affordability and digital literacy,among other things. Regulation which focuses on bothissues can deliver the industry vision of connectingeveryone. D2D can provide a valuable supplemental technology forthe mobile industry, new business for the satellite andmobile sectors, improve resilience and extend accessto services for end-users. Governments should allowmobile operators to deploy D2D services in partnershipwith satellite operators. Today, 58%1of the world population is connected tomobile broadband and D2D can add resilience and alsosupplement their services when they travel to areas withno connectivity, such as deserts, oceans, mountains D2D spectrum and services D2D operations can use two spectrum categories:frequency bands identified for IMT and allocated tothe mobile service, and bands already allocated tothe mobile satellite service (MSS). Both types of D2Doperations are available today. They currently bothprovide SOS and SMS capabilities, while D2D using IMTspectrum also offers data. D2D is a new and rapidlyevolving technology and, with the correct regulation,has the potential to offer improved services in thefuture. The larger footprint of satellite beams compared toterrestrial cells limits the amount of data that can bedelivered in any area. As such, outside areas of very lowpopulation density, D2D use will be limited. Although to the consumer D2D services may be similarusing both types of spectrum, they are different in termsof regulatory framework. GSMA positions on spectrum for D2D D2D in IMT spectrum 01. D2D using mobile spectrum should be provided through mobile networkoperator (MNO) licences D2D operating in IMT spectrum bands provides asupplemental service to terrestrial networks andenables MNOs to collaborate, under commercialarrangements with satellite network operators (SNO),to extend the MNO’s coverage. With the regulator’spermission, this should be done through the spectrumlicence of the MNO; i.e., the rights of use by satellitefor any given terrestrial band should derive fromthe exclusive rights on MNO licences, through leaseagreements or other authorisation tools as applicable ineach country. original licence, depending on how the authorisationof satellite use of the mobile spectrum is framed. Inthis case, the MNO may also remain responsible forcompliance with other regulations. This approach will allow MNOs to decide how best touse their licensed mobile spectrum bands to enablesatellite connectivity for subscribers. Such market-led choices will support the most efficient and optimaluse of mobile licensed spectrum as MNOs are best-positioned to determine how to leverage spectrum tobetter-support customers in remote, rural, suburbanor urban settings. This includes determining whichlicences or portions of licences might