IADC Rev. 4, ISO 24113, and the five-year LEO myth
IADC-02-01 Rev. 4 still uses the 25-year LEO disposal guideline. The five-year clock is not an IADC rule. How to read IADC, ISO 24113, FCC, and the proposed EU Space Act without mixing them.
Caelex is software for compliance workflows and legal research. This article is not legal advice and does not replace licensed counsel.
The EU Space Act (COM(2025) 335) is a European Commission proposal. It is not in force. What binds operators today includes NIS2, national space laws, dual-use and export-control rules, spectrum/ITU coordination, and — where a product is in scope — the EU Cyber Resilience Act.
Debris blogs often collapse four different instruments into one sentence. That produces the most common error we see: treating a five-year LEO disposal rule as if IADC adopted it in 2025. It did not.
What IADC actually says
The Inter-Agency Space Debris Coordination Committee guideline IADC-02-01 Revision 4 (January 2025; also circulated at UNCOPUOS as A/AC.105/C.1/2025/CRP.9) keeps, in §5.3.2 for LEO, the long-standing 25-year disposal window and a ≥90% disposal reliability figure. GEO is a different paragraph (§5.3.1). IADC guidelines are consensus guidance from agencies. They become binding only where a state, a licence condition, a standard, or a contract says so.
Do not claim an “IADC 2025 five-year rule.”
What ISO 24113 is
ISO 24113 turns debris-mitigation expectations into an auditable standard that can be written into contracts and design reviews. It is not a substitute for a national licence, and it is not the EU Space Act.
Where a five-year LEO clock actually lives
- United States: FCC orbital debris rules include a five-year post-mission disposal requirement for certain NGSO space stations (see 47 CFR § 25.283(e); showing lives in the application rules around § 25.114). That is FCC law, not IADC.
- European Union: the proposed EU Space Act text is widely discussed as tightening LEO disposal relative to the IADC 25-year guideline. Until the regulation is adopted and in force, that tightening is draft policy, not a Union-wide licence condition.
How to write this in a compliance file
State the instrument. State the status. Example:
- “IADC Rev. 4 §5.3.2 — 25 years / ≥90% — guideline.”
- “ISO 24113 — contractual / design-assurance target if invoked.”
- “FCC § 25.283(e) — five years — if the station is under FCC jurisdiction.”
- “COM(2025) 335 debris module — proposal, not in force.”
If a dashboard card titles IADC as a five-year rule, the card is wrong. Fix the card. Do not copy it into a filing.
Older Caelex newsroom posts compared IADC and ISO in a shorter form. Use this article as the status correction.
Next step
Run the structured assessment for a map of obligation clusters, or book a walkthrough. The result is a file to review with counsel — not a licence and not legal advice.