Countdown begins for NZ space bill: who needs authorisation for “Ground-Based Space Infrastructure”?

The Outer Space and High-altitude Activities Amendment Bill¹ is aimed at managing national security and other risks associated with Ground-Based Space Infrastructure (GBSI). The Bill is intended to address these risks by deterring certain entities from undertaking GBSI activities in New Zealand and by supporting the identification and disruption of operations that may not align with national interests. This includes deterring foreign interference in systems used to track and control spacecraft. 

The new regime will take effect on 29 July 2025 with a transitional period running until 29 July 2026 or when new regulations under the regime come into force (whichever comes first). All current operators of GBSI will be considered to hold a transitional authorisation until the end of this period. The regime is likely to be of significance for various businesses beyond traditional space operators, including commercial ground stations, advanced aviation data services, and any businesses with satellite-related infrastructure or capabilities. All operators who fall within scope will be required to apply for authorisation and meet compliance requirements under the regime by the end of the transitional period. 

What is the current regime? 

Prior to the introduction of the new GBSI-specific regime, these activities were governed under a combination of general legal and security frameworks, rather than a dedicated regulatory system. Key legislation includes:

• Outer Space and High-altitude Activities Act 2017 New Zealand’s primary legislation for space activities, focusing on the regulation of launches, launch facilities, and high-altitude vehicles. While it includes licensing and permit requirements for these activities, its coverage of GBSI has been limited to instances where GBSI is directly involved in those regulated operations. Note the new regime will be implemented as an amendment to this Act.
  
  
• Radiocommunications Act 1989 governs the use of radio frequencies. GBSI operators are required to comply with licensing and interference management provisions under this Act when using the radio spectrum.
  
  
• Telecommunications (Interception Capability and Security) Act 2013 requires network operators to engage with the Government Communications Security Bureau on network security and interception capability. Where GBSI involves telecommunications infrastructure, this Act may apply.

What is changing?

The amendment bill specifically deals with GBSI, requiring operators to have in place protective security and due diligence systems as well as obtaining authorisation to operate the GBSI. These standards will be mandatory for all GBSI operators, including for existing GBSI operators.

The new GBSI regime will capture a broad range of commercial and industrial operators while carving out clear exemptions for everyday users. The scope of the new regime includes:

• Telemetry, tracking, and control (TT&C) of spacecraft including systems used to monitor and manage spacecraft, such as satellites, probes, or crewed vehicles from Earth. It includes collecting and transmitting data on spacecraft status, determining its position and trajectory, and sending operational commands. The scope also covers systems with the potential to interfere with or disrupt satellite functionality;
  
  
• Space surveillance and identification of spacecraft including tracking and identifying objects in space, including active and inactive satellites, space debris, and natural celestial bodies such as asteroids. These systems support space traffic management, collision avoidance, and situational awareness; 
  
  
• Satellite data reception, i.e. the process of receiving data transmitted via radio signals from satellites, typically through a ground-based antenna or dish, which is then decoded and processed by receiving equipment; and
  
  
• Other areas of concern, if prescribed in regulations.

The legislation specifically excludes personal, domestic, and household users from these requirements, meaning ordinary consumers using satellite TV dishes, satellite phones, mobile phones, internet terminals, or emergency locator beacons are not caught by the new rules. The exemptions also protect recreational activities like amateur astronomy, emergency services operations, incidental business use (such as hotels or farms using satellite internet), and the use of publicly available systems for navigation or timing services unless those systems are being used to control or support space objects. 

The regime may be relevant to telecommunications providers, who may be affected where they operate satellite ground stations or manage infrastructure that receives or relays satellite data. These activities often involve TT&C functions and direct interaction with spacecraft systems.

In addition, airlines increasingly rely on satellite-based services for real-time aircraft tracking and in-flight connectivity, which may involve receiving satellite data or integrating with surveillance systems. Rocket Lab and other launch providers are directly engaged in TT&C and space surveillance as part of their mission operations, from launch through to satellite deployment and monitoring. Drone operators, particularly those conducting Beyond Visual Line of Sight (BVLOS) operations, may also intersect with the regime when using satellite-based navigation, surveillance, or data reception systems.

When will the changes take effect? 

The legislation will take effect on 29 July 2025 and will be implemented in two stages, with full compliance required by the end of the transitional period.

• Stage 1 grants the Ministry of Business, Innovation and Employment, as the regulator, the authority to shut down operations deemed contrary to New Zealand’s national security. This includes the authority to suspend or revoke a transitional authorisation.
  
  
• Stage 2 will introduce detailed regulations for GBSI registration. All in-scope operators, including those with infrastructure established before 29 July 2025, must implement protective security and due diligence systems and seek authorisation prior to the end of the transitional period. 

Operators who fail to comply may face equipment seizure, fines of up to NZ$50,000 and/or one year imprisonment for individuals, and up to NZ$250,000 for entities. The authority may also issue orders for the disposal of GBSI, the termination of electricity or internet services to the GBSI, or its forfeiture.

Wider changes 

This regulatory shift aligns with broader government efforts to modernise and strengthen New Zealand’s science and innovation ecosystem. On 1 July 2025, three new science organisations were launched:

• New Zealand Institute for Bioeconomy Science

• New Zealand Institute for Earth Science

• New Zealand Institute for Public Health and Forensic Science

These institutes aim to deliver a more connected, commercially focused science system aligned with national priorities.

Simultaneously, the space and advanced aviation sectors are experiencing rapid growth. A recent economic report shows the space sector has grown by 53% since 2019, contributing close to NZ$2.5 billion to the economy in 2023–24, while the advanced aviation sector added nearly NZ$500 million. The Government’s New Zealand Space and Advanced Aviation Strategy 2024 to 2030 aims to double the size of these sectors by 2030, reinforcing the importance of clear and workable regulatory frameworks to support growth.

In light of the regime, businesses operating in or adjacent to the satellite or high-altitude technology sectors should consider auditing systems and assessing exposure. Whether your business is a data receiver, launch support provider, or tracking equipment operator, early preparation for the 29 July 2026 transition could mitigate significant risks and ensure your business is able to meet the compliance requirements and gain registration under the new regime. Please get in touch if you require assistance with ensuring your business’s authorisation application is ready for the end of the transitional period.

If you have any questions about this article, please get in touch with the contacts listed or your usual Bell Gully adviser.

[1] Outer Space and High-altitude Activities Amendment Bill 185-1 (2025), Government Bill Contents – New Zealand Legislation

Disclaimer: This publication is necessarily brief and general in nature. You should seek professional advice before taking any action in relation to the matters dealt with in this publication.