China Files for 193,000 More Satellites at the ITU — and the Spectrum-Priority Race Enters the Coordination Layer
Two December 2025 ITU filings stake out advance-publication and coordination rights for nearly 200,000 next-generation LEO satellites. Once a network is filed, priority runs by date — and the coordination clash with Starlink and Amazon Leo moves from the launch pad to the filing queue.
What happened
In late December 2025, China submitted two large non-geostationary network filings to the ITU — designated CTC-1 and CTC-2 — each describing on the order of 96,700 satellites across thousands of orbital planes, for a combined total near 193,000. CTC-1 carries both advance-publication information and a fuller coordination request; CTC-2 sits, for now, at the advance-publication stage. The filings appear to stake out orbits and frequencies for a next-generation constellation as Starlink and Amazon Leo build out.
ITU priority runs by filing date, not by launch date, but it is not self-executing. A network must be coordinated against earlier filings and then brought into use within set deadlines, or the rights lapse. China's two operational megaconstellations, Guowang and SpaceSail's Qianfan, face the practical edge of that rule: to keep full spectrum rights they must each have roughly ten percent of their filed networks in orbit by the end of 2026 — a target well ahead of the few hundred LEO satellites launched so far.
Why it matters for dispute formation
Spectrum priority is the earliest signal of all: a filing made today shapes who must defer to whom for a decade. The dispute layer is coordination — the ITU process in which later filers must show they will not cause harmful interference to earlier ones, and operators negotiate, or fail to negotiate, sharing arrangements. When a network files for tens of thousands of satellites in bands an incumbent already uses, the coordination burden, and the leverage, shift in measurable ways.
For spectrum and regulatory teams, the work is to read the filings against your own ITU priority and your national authorization (FCC NGSO grants, equivalent-power-flux-density commitments, milestone deadlines), and to track bring-into-use status. Paper satellites that never fly can still encumber a band; networks that miss their milestone deadlines can forfeit it. The record that decides a future interference or priority dispute — the filing dates, the coordination correspondence, the milestone evidence — is being made in the queue right now.
Who's exposed
Exposed as the incumbent first-mover whose Ku/Ka downlinks must be coordinated against later but vast Chinese filings; new networks claiming the same bands raise the interference-coordination burden on an operating constellation.
Exposed as a deploying NGSO operator whose own ITU priority and FCC milestones now sit alongside two filings covering tens of thousands of satellites each in overlapping bands.
Exposed to their own ITU bring-into-use deadlines: to hold full spectrum rights, each must place roughly ten percent of its filed network in orbit by end-2026 — a milestone far ahead of current launch cadence.
Exposed wherever the new NGSO filings press against equivalent-power-flux-density limits protecting geostationary fleets — the coordination point where capacity plans meet interference rules.
The historical parallel · Viasat v. SpaceX / FCC (NGSO authorization challenge, D.C. Circuit)
Viasat and others challenged the FCC's authorization of SpaceX's lower-altitude Starlink deployment, raising orbital-debris, interference, and environmental-review arguments. The litigation showed that NGSO authorizations are contestable on procedural and interference grounds, that incumbents will use the regulatory record to slow a rival's buildout, and that the coordination and authorization paperwork — not the hardware — is where the early fight is won or lost. A filing race for 193,000 satellites runs the same logic at far larger scale.
What to watch
- Whether CTC-2 advances from advance publication to a coordination request, and how the bands map onto Starlink and Amazon Leo priority.
- Guowang and Qianfan bring-into-use status against the end-2026 ten-percent milestone — the line between holding and forfeiting spectrum rights.
- ITU coordination correspondence and any equivalent-power-flux-density disputes with GSO operators in shared Ku/Ka bands.
- Whether national regulators (FCC, MIIT) condition or accelerate domestic authorizations in response to the filings.
Sources
See the disputes forming before the market does.
Signal Watch tracks the developments. The monthly Intelligence Brief synthesizes all four signals into the disputes most likely to crystallize next — free.
Get the Intelligence BriefFor general information only; not legal advice, and no attorney–client relationship is formed through this article. Company names appear because the companies are exposed to a public development — not as a statement of wrongdoing or a predicted outcome. Figures are as reported by the linked sources.