New Space Challenges: Rethinking How to Do Satellite Defense in an Era of Increasing Commercial Actors

By Trent Teyema, DSc and David Bray, PhD

How can the United States develop a coherent defensive strategy for space that encompasses both commercial and government activities, without imposing prohibitive costs or regulatory burdens that would undermine the very innovation driving the New Space economy? The space operations around Earth orbits are undergoing a fundamental transformation. We are witnessing the shift from “Old Space” to “New Space”. Specifically, we are seeing the volume and activities of satellites in space transition from a domain once dominated by government and military actors to one increasingly populated by commercial activities.

Just a decade ago, in 2013, there were approximately 1,165 active satellites in orbit. Today, as of mid-April 2026 that number has exploded to more than 15,000 active satellites. A vast majority of the 2026 number are commercial, with over 10,000 of them from SpaceX alone with the company aspiring to have as many as 42,000 satellite as a part of the Starlink constellation. In January 2026, SpaceX also applied with the U.S. Federal Communications Commission to launch a constellation of one million satellites dwarfing the combined total of 200,000 planned futured satellites the People’s Republic of China applied for with the International Telecommunications Union. This paradigm shift demands a complete rethinking of our approach to space security, policy frameworks, and defensive strategies.

U.S. military and civilian activities increasingly depend on space-based assets, to include precision in military operations, essential intelligence endeavors, global communications, global positioning, and economic growth. While the Artemis Accords represent an important diplomatic tool that establishes norms and consensus around responsible space behavior, it may not be realistic to expect all state actors let alone non-state actors to comply with the Accords. Specifically, while the Artemis Accords now have 60 nation-states signatories agreeing to international cooperation on space endeavors, China and Russia’s rival International Lunar Research Station (ILRS) has 17 signatories separate from the Accords. The Accords are not global in nature.

Also, there exists tension between the Accords and the Outer Space Treaty adopted by the United Nations in 1967. The U.S. from the onset of the Accords has advanced the position that resources in space are subject to private ownership reflected in the U.S. Commercial Space Launch Competitiveness Act of 2015. Other nations disagree with the commercialization of space stance. Furthermore, neither the Outer Space Treaty nor the Artemis Accounts address what to do if bad actors outside the remit of a nation-state cause harm to space assets.

Application of the “law of the sea” framework to commercial satellites in Earth orbit, while on the surface seems attractive, there are reasons to doubt this approach’s effectiveness. Nowadays law of the sea paradigm struggles even in its original maritime domain, where non-state actors increasingly attack commercial shipping with impunity. Space’s unique characteristics likely require entirely new governance frameworks rather than borrowed terrestrial analogies.

Consequently, the U.S. may need to identify solutions where it can use Earth-based projections of power to deter state and non-state actors from cyber, physical, or other disruptive attacks on U.S. space assts, to include commercial satellites. This becomes even more important given the increasing risk of a Kessler Syndrome event where a collision of space material with an object starts a runaway cascade of even more space material colliding with space options that result in all of Earth being unable to use orbits around the Earth for one hundred or more years.

The Vulnerability Paradox

The proliferation of commercial satellites presents a paradox for U.S. national security. Projections estimate as many as 100,000 low-Earth orbit satellites could be in orbit 2030, or potentially much more given recent SpaceX and China satellite filings. While these systems enhance our technological capabilities and economic competitiveness, they simultaneously create unprecedented vulnerabilities. Unlike military satellites designed with security as a primary consideration, commercial systems often prioritize cost-efficiency, rapid deployment, and market accessibility. Adversaries can target these less-hardened systems as a means of degrading U.S. capabilities without directly confronting military assets.

As the number of commercial satellites increase, this will also increase the number of undefended targets in space that  will be especially attractive to state and non-state actors with adversarial relationships relative to the United States. Compared to the terrestrial domain, space presents a fundamentally different environment where root cause attribution becomes significantly more complex. A commercial satellite experiencing unexpected behavior could be suffering from a technical malfunction, environmental damage, or a deliberate attack through kinetic, directed energy, or cyber means. Low-Earth Orbit (LEO) satellites generally operate 200-2000 kilometers above the Earth at speeds of 7.8 kilometers per second (approximately 17,500 miles per hour). Physical forensics would be extremely difficult to do given both the distances and speeds at which space-based assets operate.

Already most satellites in orbit are commercial in origin, with SpaceX’s StarLink satellites currently comprising more than 9,300 of the approximately 14,000 active satellites in orbit. During the Ukraine conflict, SpaceX leadership made a call to cut off service for certain key times. Yet such a decision also raises the questions does SpaceX identify itself as a U.S. company or a global, transnational one? After all, the contractual terms for StarLink include a special clause for different legal provisions tied to Mars.

This attribution challenge creates a “gray zone” that adversaries can exploit, conducting operations below the threshold of clear aggression especially if directed at a commercial asset without immediate U.S. military recourse. Imagine 200 SpaceX satellites stop responding, is it a solar storm, an adversarial anti-satellite weapon’s effects, a cyberattack from a non-state actor or something else? Identifying this in a timely manner – let alone identifying an effect response – would be difficult.

Moreover, while the Artemis Accords represent a major step toward establishing norms of responsible behavior in space, the Accords primarily focus on civil space exploration rather than security concerns. China’s and Russia’s partners with the International Lunar Research Station project follow different rules and standards. Non-state actors aren’t bound by either agreement. To final complicate matters: in early 2026, SpaceX filed plans for an additional one million satellites in the future.

The Sovereignty Question

Circling back to a potential near-future scenario where 200 SpaceX satellites suddenly stopped responding. Response would require rapid attribution of what happened, and if caused by a bad actor, whom?

Satellites in space are vulnerable to cyber exploits from all sides, given that they are visible from above the Earth and accessible to both radio-frequency and line-of-sight attacks from other space assets both in orbit as well as on the Moon. If it turns out that U.S. commercial, non-governmental satellites were impacted by  a cyberattack of unknown origin, what legal and operational frameworks should guide a U.S. response?

The absence of clearly defined “borders” in space and major powers competition for dominance complicates the application of conventional defense doctrines and requires new thinking about how to establish and enforce rules of engagement that protect commercial assets without triggering unintended escalation.

The distributed nature of the commercial space sector, with companies operating internationally and serving global markets, necessitates a collective approach to defense, especially to events that might be difficult to assign attribution. Unlike military space assets that operate within classified national security frameworks, commercial systems often involve international partnerships, foreign customers, and global supply chains. This interconnectedness creates both vulnerabilities and opportunities.

The U.S. could leverage its alliances and partnerships to establish a collective defense framework for commercial space assets by expanding the Artemis Accords. This could include security provisions and incentivizing commercial operators to adopt resilient architectures, thereby distributing the burden of security while preserving commercial advantages. However, tensions already exist between the U.S. and other Accord members, going back to 2015, over the privatization of space resources.

Updating the Accords could involve specific clarifications for the defense of commercial assets from disruptive attacks, potentially tied to the “flag” of a given nation as well as clarification of what actions member nations could do if a commercial satellite was presenting hostile actions in space. However, it might be that current signatories of the Artemis Accords prefer the current nation-state focus of the Accords and do not want to extend them to address the increasing number of private-sector, commercial activities in space.

If so, the U.S. should consider updating arrangements through bilateral and possibly regional alliances to include explicit defense provisions that cover multinational aid to address cyber, physical, and other disruptive attacks on commercial space assets including significant interruptions of essential services provided by these assets. The U.S. also should detail pre-defined thresholds for activation of national security assets, space-related exercises, and tests of response plans to deter aggression from state actors.

The Commercial Resilience Requirement

Separate from agreements between nations, the U.S. also needs to encourage U.S. companies to improve the security and defense of commercial satellites – while not making such improvements onerous or prohibitively expensive.

The sheer number of commercial satellites now creates opportunities for distributed resilience previously was not possible in the era of fewer, more expensive government systems. However, this potential resilience is not automatic, it would require deliberate architectural decisions, regulatory frameworks, and incentive structures. Commercial operators, driven by profit motives and shareholder interests, may independently decide not to prioritize the redundancy and hardening measures necessary for national security.

U.S. companies can be encouraged to exceed baseline security requirements and demonstrate advanced resilience capabilities in their satellite systems, as well as associated ground infrastructure, through strategic incentives, including tax benefits, preferential government contracting, and liability protections. In parallel, the U.S. could encourage public-private partnerships to develop and deploy innovative security technologies for commercial space assets, with government providing funding for dual-use security research and commercial entities contribute agility and innovation, creating a hybrid approach akin  to successful cybersecurity models in critical infrastructure sectors.

Additionally, a hybrid AI-human “red team” approach, drawing from national security best practices, should be implemented to continuously identify potential vulnerabilities in commercial space systems before they can be exploited by adversaries, ensuring that resilience measures evolve alongside emerging threats while maintaining commercial competitiveness.

A Call to Action to Upgrade Our Approaches to New Space

How then could the U.S. government extend its national capabilities to help deter cyber, physical, and other disruptive attacks on commercial satellites in space beyond the international and multi-national approaches already discussed?

DIME, Diplomatic, Information, Military, and Economic, represents a traditional framework used by the U.S. military for thinking through challenging issues associated national power projection. Given the increase in commercial space assets, combined with the increasing state- and non-state actors contesting the space domain, necessitates the expansion of this framework to include Space as a fifth dimension of national power.

We think incorporating Space into U.S. deterrence doctrine is necessary to advance U.S. strategic thinking to address the realities of 21st-century great power competition juxtaposed with the space-based commercial assets. Extending DIME to become “DIMES” would recognize that space capabilities now fundamentally underpin and enable the other four dimensions. More importantly, it would permit the U.S. government to use Earth-based defense, information, military, and economic measures to establish clear consequences if a space-based disruption occurs to a U.S. flag satellite.

The U.S. stands at a critical juncture in the evolution of space as a domain of human endeavors, to include the rapid commercialization of space activities. This presents unprecedented opportunities for economic growth and technological advancements. However, these same developments create new vulnerabilities that adversaries are already moving to exploit.

We cannot afford to apply Old Space thinking to New Space challenges. The time for decisive action focused on meaningful deterrence is now: before we witness the space equivalent of Pearl Harbor or 9/11. By explicitly incorporating space into our deterrence doctrine, the United States can ensure that the final frontier remains a domain where free societies can safely operate, innovate, and prosper.

Dr. David A. Bray is a Distinguished Fellow and Chair of the Accelerator with the Alfred Lee Loomis Innovation Council at the non-partisan Henry L. Stimson Center. He is also a CEO and transformation leader for different “under the radar” tech and data ventures seeking to get started in novel situations. He is Principal at LeadDoAdapt Ventures, Inc. and has served in a variety of leadership roles in turbulent environments.  He previously served as a non-partisan Senior National Intelligence Service Executive, as Chief Information Officer of the Federal Communications Commission, and IT Chief for the Bioterrorism Preparedness and Response Program. Business Insider named him one of the top “24 Americans Changing the World” and he has received both the Joint Civilian Service Commendation Award and the National Intelligence Exceptional Achievement Medal. David accepted a leadership role in December 2019 to direct the successful bipartisan Commission on the Geopolitical Impacts of New Technologies and Data that included Senator Mark Warner, Senator Rob Portman, Rep. Suzan DelBene, and Rep. Michael McCaul. From 2017 to the start of 2020, David also served as Executive Director for the People-Centered Internet coalition Chaired by Internet co-originator Vint Cerf. Business Insider named him one of the top “24 Americans Who Are Changing the World” and he was named a Young Global Leader by the World Economic Forum. For twelve different startups, he has served as President, CEO, Chief Strategy Officer, and Strategic Advisor roles. The U.S. Congress invited him to serve as an expert witness on AI in September 2025.

Dr. Trent Teyema (FBI Special Agent – SES ret.), advises governments and companies on cybersecurity, blockchain, infrastructures, national security, and space. He has served in numerous senior leadership positions, to include the Director of Cybersecurity Policy for the White House’s National Security Council, the SAC of the Cyber and Counterintelligence Division for FBI Los Angeles, the FBI Cyber Division’s COO / Chief of Cyber Readiness. Mr. Teyema founded and led the National Cyber Investigative Joint Task Force (NCIJTF) which is one of the seven US cybersecurity centers. Dr. Teyema recently defended his dissertation on the cybersecurity of space-based assets successfully at Marymount University.