2025 Space Wrap-Up: Two Space Executive Orders and a New NASA Administrator

2025 marked the issuance of two space-related executive orders with major effects on the commercial space industry. This client alert summarizes these changes and their likely impact on stakeholders such as satellite operators, launch providers, in‐space service firms and spaceport developers.

Enabling Competition in the Commercial Space Industry (EO 14335)

On Aug. 13, 2025, President Donald Trump signed EO 14335, “Enabling Competition in the Commercial Space Industry,” directing agencies to streamline launch licensing, spaceport approvals and new space-activity authorizations. Our prior client alert, found here, summarizes the EO’s principal directives and timelines. As 2026 begins, several of EO 14335’s early deadlines have passed, and others are imminently approaching. We outline the most impactful changes that remain pending and how commercial space participants can participate in the regulatory process:

• PAST DUE — DOT Deadline to Reevaluate Launch and Reentry Licensing Regulations: The EO required the Department of Transportation (DOT) to reevaluate its commercial launch and reentry licensing regulations, including 14 C.F.R. Part 450, within 120 days of issuance (Dec. 11, 2025). No notice of proposed rulemaking or other formal action related to Part 450 has appeared in the Federal Register or FAA rulemaking dockets.
• PAST DUE — Environmental Review Streamlining for Commercial Space Activities: The EO directs federal agencies to expedite environmental reviews for commercial space activities and identify opportunities to establish categorical exclusions under the National Environmental Policy Act (NEPA). DOT and the Federal Aviation Administration (FAA) implemented broad NEPA reforms in mid-2025, yet no agency has published space-specific NEPA categorical exclusions or guidance implementing the EO’s commercial space directives.
• ONGOING — Department of Commerce Initiates Mission Authorization Process for Novel Space Activities: The EO directed the Department of Commerce, through the Office of Space Commerce (OSC), to propose a regulatory framework to authorize and supervise novel space activities within 150 days of the EO. In December 2025, OSC released a draft mission authorization concept to expedite separate regulatory reviews required for certain space activity and initiated a stakeholder engagement process to solicit industry feedback. Stakeholders seeking to give feedback are encouraged to fill out the following form here.
• UPCOMING (Feb. 9, 2026) — Deadline for Interagency Spaceport Coordination: The EO requires DOT, the Department of Defense (DOD), NASA, and Commerce to coordinate regulatory reviews related to spaceport development and to execute an interagency memorandum of understanding aligning those reviews.

Ensuring American Space Superiority (EO 14369)

On Dec. 18, 2025, President Trump signed EO 14369, “Ensuring American Space Superiority,” which sets an ambitious U.S. space strategy with lasting effects on the commercial space industry. Of the specific policy goals articulated in the order, the following aim to have the largest impact on commercial space stakeholders:

• Cost-Effective Launches: The EO seeks to enhance the sustainability and cost-effectiveness of launch and exploration architectures, explicitly “enabling commercial launch services” and “prioritizing lunar exploration[.]”
• National Security in Space: The EO directs creation of a responsive, adaptive national security space architecture via accelerated acquisition reform, increased commercial integration and engagement with “new market entrants[.]” It also urges U.S. allies to increase collective contributions to space security overall, through additional operational cooperation, basing agreements and increased investment in “America’s space industrial base[.]”
• Commercial Space Economy: The EO seeks to increase economic growth of the American space industry by attracting “at least $50 billion of additional investment” in U.S. space markets by 2028. It emphasizes increasing launch/reentry “cadence” via new/upgraded facilities and efficiency, and urges improving spectrum management for competitiveness. Notably, the EO calls for a “commercial pathway to replace the International Space Station by 2030,” aligning with NASA’s plan to deorbit the ISS and procure commercial space stations.
• Advanced Capabilities and Infrastructure: The EO also directs investment in cutting-edge technologies to enable “the next century of space achievements[.]” Agencies must optimize R&D to meet near-term objectives and “enable scientific discovery[.]” A centerpiece is space nuclear power: The EO instructs the deployment of nuclear reactors on the Moon and in orbit, with a lunar surface reactor ready for launch by 2030. It also calls for the U.S. to become the leader in “space traffic management; orbital debris mitigation and remediation; and terrestrial and cislunar positioning, navigation, and timing[.]” Finally, the EO emphasizes the establishment of “ground, space, and lunar infrastructure and standards” to implement these goals.

Section 3 of the EO directs Michael Kratsios, the current assistant to the president for science and technology (APST), to coordinate implementation of the order. Of the upcoming deadlines, the following have the greatest likelihood to impact relevant stakeholders:

• UPCOMING (April 17, 2026) — Spectrum Sharing/Reapportionment Revisions: Within 120 days of the date of this EO, the secretary of commerce shall coordinate with the APST, the assistant to the president for economic policy, the assistant to the president for domestic policy and the heads of relevant agencies to assert spectrum leadership, which shall include considering opportunities for reapportioning and sharing spectrum, as appropriate.
• UPCOMING (April 17, 2026) — NASA Agreement Alignment: Within 120 days of the date of this order, the administrator of NASA, in coordination with the secretary of state and the APST, shall align NASA’s international civil space cooperation arrangements to support the EO’s policy priorities, including modifying or terminating existing arrangements.
• UPCOMING (June 16, 2026) — DOC and NASA Reform Implementation: Within 180 days of the date of this EO, the secretary of commerce and the administrator of NASA shall each reform their respective agency’s space acquisition processes to support the space priorities in this order, and to further President Trump’s April 15, 2025, Executive Order 14271, “Ensuring Commercial, Cost-Effective Solutions in Federal Contracts.” These reforms include using existing authorities to improve and expedite space acquisitions, as well as detailed reviews of each functional support role within the agency and its contractors. The EO specifically tasks the Department of Commerce with “strengthening capabilities for conducting space acquisition and sustainment activities in a manner that supports collaboration with, but does not require acquisition assistance from, NASA, including by recommending legislative reforms as necessary[.]” The EO also provides specific guidance for NASA, directing the agency to improve efficiency by aligning space-focused acquisition and procurement processes across NASA centers and activities.
• UPCOMING (June 16, 2026) — Plan to Increase Ally Contributions: Within 180 days of the date of the EO, the secretary of state, in coordination with the secretary of war and the director of national intelligence, are directed to also implement a plan to strengthen ally and partner contributions to United States and collective space security.

Looking Ahead

Several deadlines associated with Executive Orders 14335 and 14369 are approaching in early 2026, and how agencies react to their mandates will likely shape the commercial space industry for years to come. We will continue to monitor developments and provide updates as agencies take further action to implement these EOs. If you would like guidance regarding how these EOs might affect you and your business, do not hesitate to contact the Paul Hastings team.