SatDSiG readiness for operators and counsel
Germany does not have a single LOS-style space-activities statute. The Satellite Data Security Act (SatDSiG) is the core published law most operators meet first: it is an Earth-observation data-security regime, not a general licence for every orbital activity. High-resolution EO missions trigger SatDSiG procedures; other German space activities typically run through federal ministries and DLR practice (including UN registry filings). Export of spacecraft parts is a separate stack — BAFA / EU Dual-Use 2021/821 and, where US content is present, ITAR/EAR — handled in Caelex Passage, not as a SatDSiG substitute. The proposed EU Space Act (COM(2025) 335) is not yet in force and would sit alongside SatDSiG if adopted. Software is not legal advice and does not grant a German licence.
National Space Law
Satellite Data Security Act (SatDSiG)
- •SatDSiG focuses on high-resolution Earth observation data security — not a general space-operations licence
- •EO missions above sensitivity thresholds require SatDSiG procedures (see the official text; do not rely on marketing summaries for the cut-off)
- •Data-security concepts and dissemination controls for sensitive imagery
- •UN space-object registration practice via DLR — confirm current process with the agency
- •Space hardware exports are BAFA / EU Dual-Use / ITAR-EAR, not SatDSiG alone
National Competent Authority (NCA)
DLR
German Aerospace Center (DLR) / Federal Ministry for Economic Affairs
Authorization Requirements
- SatDSiG permit for operating a high-grade Earth observation system: written application to the Federal Office for Economic Affairs and Export Control (BAFA) with the documents needed to examine the conditions (SatDSiG §§ 3(1), 24(1), 25(1))
- Operator reliability (§ 4(1) no. 1)
- Command sequences generated in Germany and protected against alteration, and data transmission protected against unauthorised access, each by a procedure the BSI has examined and declared suitable; the BSI is involved early (§ 4(1) nos. 2-3, § 25(2))
- Technical and organisational measures against unauthorised access to command, reception, processing and storage facilities and their premises (§ 4(1) no. 4)
- Simple security clearance of persons with access to those facilities (§ 4(2))
Insurance & Liability
No German space act is in force, and SatDSiG contains no insurance requirement. Key points for a German space act (see BT-Drs. 20/12775) are not law.
Official sources
Caelex products for this jurisdiction
Key Differences from EU Space Act
The proposed EU Space Act (COM(2025) 335) is not yet in force. If adopted it would add a Union authorization and safety layer. SatDSiG would remain the German EO data-security statute. Do not treat the proposal as binding or as a replacement for SatDSiG. Software is not legal advice.
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