Cellular networks cover 96 per cent of people but only 15 per cent of land. Direct-to-device (D2D) connectivity makes satellite service more accessible and, as a result, addresses growing connectivity needs in rural, remote and underserved areas.
The D2D market has expanded rapidly, with immediate applications in disaster support, IoT (internet of things) connectivity for low-bandwidth devices and seamless coverage for travellers. As D2D connectivity grows to include more data services, it will help fill coverage gaps rather than compete with traditional networks. The future lies in integrating satellite and terrestrial networks to leverage their combined strengths in scale, cost, reach and reliability.
Figure 1: Direct-to device partnerships. Source: Access Partnership
The socio-economic benefit is substantial. Extending meaningful connectivity to people currently outside mobile broadband coverage, estimated at more than 360 million people, could generate tens of billions of dollars in GDP gains. Additionally, D2D-enabled communications could help reduce the impact of disasters by enabling faster, more reliable emergency response and coordination. Put simply, D2D’s value proposition is not only about coverage; it is also about human progress and resilience: keeping people and systems connected when terrestrial networks fail, are damaged or lacking. However, the D2D commercial market outlook remains uncertain as projections vary due to technology maturity, adoption trends and regulation. Initial growth will likely come from premium consumer connectivity and IoT, followed by broader adoption as performance, standards and affordability improve. Policymakers play a vital role as they can either support innovation or hinder scale and welfare through restrictive frameworks.
The policy test: D2D challenges existing assumptions
D2D does not fit neatly into conventional regulatory categories. It blurs the boundaries between terrestrial mobile services (IMT) and mobile-satellite services (MSS), as it introduces cross-border operational realities that many national frameworks were not designed to handle at consumer scale. The core regulatory challenges can be grouped into seven main areas.
Cross-border interference and coordination
Satellite communications are inherently global but D2D, particularly when using IMT spectrum, introduces novel interference considerations because terrestrial frequencies and technical parameters previously coordinated for ground-based use are now applied from space. Early authorisations have relied on mechanisms such as power flux density limits to respect existing coordination agreements, but as more bands and devices are brought into the fold, this approach may become overly complex. Regulators may need to revisit bilateral and regional coordination agreements and consider how satellite network operators (SNOs) are incorporated more directly into interference and spectrum management.
Licensing, authorisation and enforcement
Regulators understand how to license terrestrial mobile networks and how to authorise MSS, but D2D expands both models. MSS user terminals are often covered through blanket licences, based partly on assumptions about low interference risk and relatively limited terminal volumes. D2D could scale terminal numbers dramatically, raising questions about whether those assumptions still hold. Similarly, satellite spectrum has often been assigned administratively where supply exceeds demand, but growing demand for D2D could push regulators towards more market-based assignment methods.
Emergency service obligations
D2D can potentially bypass traditional emergency call routing and location determination systems used by terrestrial networks. Where D2D is partnered with an existing mobile network operator (MNO), it is more likely to integrate into established emergency routing. However, D2D-MSS may not have historically been subject to the same emergency obligations and regulators may not have imposed equivalent requirements on MSS providers. Which network ensures emergency calls are routed correctly and that responders can locate users quickly?
Quality of service and user expectations
Frequently, regulators require MNOs to report quality of service (QoS) metrics and publish them to support informed consumer choice. Satellite QoS has historically been less visible and its data less routinely collected. As D2D becomes widely available to consumers, regulators must determine which QoS metrics should be measured and disclosed and what users can realistically expect given bandwidth, latency and line-of-sight constraints. Empirical data, including speeds, failure rates, latency and connection time, should drive these conversations.
Consumer rights, transparency, and billing
As D2D expands, users may not clearly know when their device switches to satellite mode or what costs are involved. This creates consumer protection concerns around contract clarity, billing transparency and interface signs, made more complex by dynamic switching and bundled services. Regulators may need to review whether current rules are adequate or whether updates are needed.
D2D’s value proposition is not only about coverage; it is also about human progress and resilience
Data privacy and lawful interception in cross-border operations
D2D connectivity may route traffic through foreign ground stations, risking compliance with national interception and privacy laws. D2D-IMT can keep traffic domestic, but D2D-MSS could bypass controls if local gateways are absent. Operators must ensure compliance to secure licences and regulators should provide clear, harmonised requirements to avoid deployment delays.
Universal service/access and coverage definitions
Universal service obligations (USOs, commonly tied with universal access) have traditionally focused on population coverage, often leaving remote unpopulated areas uncovered. D2D could close those gaps without requiring costly terrestrial buildout, but whether D2D counts for USO compliance is questionable. Some stakeholders argue D2D strengthens emergency resilience but is not equivalent to terrestrial networks on performance or cost, particularly indoors or in obstructed areas; others are moving towards requiring geographic-area coverage via D2D. Regulators will need to clarify whether and how D2D contributes to universal service objectives and whether new performance/availability standards should accompany any such recognition, for instance when addressing play-or-pay obligations.
How to maximize the D2D opportunity? Agile policymaking that enables innovation
Given the pace of development, the most pragmatic regulatory posture is neither laissez-faire nor overly prescriptive. The emerging lesson is that regulation will determine the pace of adoption. Hence frameworks should be designed to enable market testing and evidence gathering early, then provide scalable certainty as services mature. Key policy considerations are:
- Adopting phased authorisation/licensing models. Countries are currently split between light-touch waivers (often by amending existing licences or granting case-by-case permissions) and comprehensive frameworks designed specifically for D2D. A hybrid pathway using waivers as a stepping stone towards a fuller framework once evidence is available offers a pragmatic balance.
- Anchoring spectrum rules in non-interference principles, while modernising coordination. When using IMT spectrum, the principle of non-interference and non-protection is central. Regulators should maintain this discipline while updating cross-border coordination tools to reflect the reality that terrestrial parameters are now being applied from space, potentially requiring new coordination processes that involve SNOs more clearly.
- Outlining realistic QoS and coverage expectations. Regulators should begin collecting, publishing, and analysing real-world D2D usage data to set baselines for the hybrid-network consumer experience and enable fair competition. This evidence should inform what coverage and service availability mean in a hybrid, new environment.
- Updating emergency service obligations. Policymakers should clarify responsibility for emergency call routing and location services when devices can access multiple networks, ensuring D2D complements (rather than complicates) public safety infrastructure.
- Strengthening consumer transparency. Regulators should ensure consumers understand when satellite connectivity is being used, the conditions and the pricing implications.
- Pushing for interoperable, harmonised compliance on privacy and lawful interception. D2D will scale faster where obligations are consistent across borders. Regulators and industry would benefit from more harmonised approaches that preserve legitimate law enforcement needs while avoiding fragmented requirements that raise costs and slow rollouts.
Our view
Ultimately, the success of D2D will hinge less on which spectrum band prevails and more on interoperability, fit-for-purpose regulation and whether services meet the practical needs of diverse users across geographies. D2D should not be understood as a replacement for terrestrial networks, but as a critical capability within a single hybrid network future that can extend meaningful connectivity and resilience if policy choices keep pace with technology, building the future of connectivity one D2D connection at a time.
This article is based on Access Partnership’s white paper: The Future of Networks: Direct-to-Device for Universal Meaningful Connectivity.
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