Governance and Decision6 min readAnalysis
Who decides the next decade of connectivity
Anatel decided that satellites may only talk to phones in partnership with whoever holds the spectrum, and extended the experimental environment to April 2029. The definitive rules will be written now, and whoever is not in the room will live with them for a decade.

In July 2026, Anatel made a decision that looks technical and is not. In approving the bands for direct communication between satellite and handset — D2D —, it determined that the service may only be offered in partnership with the mobile operator holding primary usage rights over that band.
This is not a radio specification. It is a market structure decision, and it defines who takes part in building that market for the next decade.
What was actually decided
Four regulatory moves, chained between July and August 2026, show what is at stake.
Spectrum entered the plan, in a subordinate position. The Mobile Satellite Service was included in Brazil’s frequency band attribution, allocation and distribution plan for 2025-2026 on a secondary basis, in the 700 MHz, 850 MHz, 900 MHz, 1.8 GHz, 1.9/2.1 GHz and 2.5 GHz bands. Secondary status means: it operates as long as it does not interfere with the primary holder, and it cannot complain about interference.
Partnership became a condition of existence. A D2D system does not operate on its own. Satellite operation has to take place in partnership with the Personal Mobile Service (SMP) provider that holds primary use of the band.
The regulator took the decision upon itself. Anatel’s Board resolved to define the service’s conditions of use directly, and gave the Licensing Superintendence 90 days to propose the technical specifications.
The experimental environment gained more time. In August, Anatel extended the D2D regulatory sandbox to April 2029, or until the definitive rule takes effect — whichever comes first.
That experimental environment, however, was not born in August. It was created by Act No. 5,322, of April 18, 2024, which allows SMP providers to temporarily use their own service’s bands to test satellite systems. It predates the agency’s general rule on experimentation: the Experimental Regulatory Environment only gained a regulation with Resolution No. 776, of April 28, 2025.
Mobile operators have already begun to position themselves, and suggested a spectrum auction for D2D.
In plain terms: there are roughly two years and seven months until April 2029 to consolidate a rule capable of steering the market for the following decade. And the contest over that wording has already begun.
The market this rule will meet
Six indicators are enough to place who is already in this market and what it still lacks. Two of them depend on one term: backhaul is the transport network that links local infrastructure to the network core — where it does not exist, there is no fixed broadband at scale, however much fiber there may be in the next town.
| Indicator | Number | Date |
|---|---|---|
| Fixed broadband accesses in Brazil | 56.8 million | July 2026 |
| Accesses over optical fiber | 44.4 million | July 2026 |
| Share of the market served by regional and small providers | about 60% | May 2026 |
| Starlink’s share of fixed broadband | about 1.5% | May 2026 |
| Localities with no fiber backhaul and no coverage obligation | 30,031 | July 2026 |
| Municipalities in that same condition | 652 | July 2026 |
Composition matters more than the total. The Brazilian fixed broadband market is not organized around four large groups alone. There are thousands of regional and small providers which, taken together, account for the majority of accesses.
At the same time, that segment has begun to feel a shift in competitive dynamics. In June 2026, net additions were led by Vivo, with 57 thousand accesses, Starlink, with 45 thousand, and Claro, with 21 thousand. Among the regionals the picture split: Brasil TecPar and Unifique gained two thousand accesses each and Brisanet one thousand, while Giga+ lost 16 thousand, Vero 6 thousand and Alares 4 thousand.
The satellite presence is still small against the market as a whole, but the direction of travel matters as much as the current size.
And the queue of entrants is growing. China’s SpaceSail obtained authorization for up to 324 satellites by 2031. Amazon Leo expects commercial operation in the country through distribution partnerships, starting in the South region.
The numbers show a market that is at once large, fragmented and still incomplete in infrastructure coverage. It is precisely that combination that makes D2D regulation a question of market structure, and not merely of radio engineering.
The incentives the rule itself creates
If partnership with the primary holder of the band is a condition for D2D, the satellite operator has three routes: strike agreements with those who already hold spectrum, bid for frequencies that may come to be offered, or seek an equity combination with a Personal Mobile Service provider.
These are very different paths, and none of them is automatic. Acquisitions and concentrations depend on regulatory and antitrust review; radiofrequency use remains subject to the conditions and limits Anatel sets.
That caveat made, the structure of incentives is clear.
The mobile operators’ suggestion of taking D2D to auction is, for that reason, a double-edged sword. An auction is the mechanism that converts capital into primary spectrum usage rights, and financial capacity is not the scarce resource for groups operating global constellations.
A rule designed to make the satellite dependent on the terrestrial network creates the economic incentive for the satellite operator to buy its own independence.
Consolidation in SMP enters the same analysis, by another path: acquiring a stake in or control of a provider holding radiofrequencies delivers, in a single transaction, spectrum, network, customers, commercial channels and regulatory standing. An auction delivers the spectrum alone.
The partnership obligation, therefore, does not organize today’s offering alone. It steers the investment, consolidation and vertical integration decisions of the coming years.
The claim I stand behind
By December 31, 2028, Anatel will not have brought the definitive D2D rules into force, and the service will still be operating under the extended experimental environment.
It is verifiable in the agency’s own acts. If I am wrong, the window for building the rule will have closed earlier than I project.
Four questions to take to the operator’s or the provider’s board now
Is satellite a competitor, an input, or both? With more than 30 thousand localities lacking fiber backhaul and carrying no coverage obligation, low-orbit capacity may represent a threat to revenue in some markets and a network cost component in others. These are different strategies and need to be treated as such.
What is the spectrum we already hold worth? The D2D rule added a new economic dimension to usage rights over certain bands. Spectrum no longer serves only to build a terrestrial network; it now also shapes bargaining power with satellite operators.
Does the contract with today’s partner survive tomorrow’s market structure? If consolidation, new auctions or vertical integration are possible routes, partnership contracts need to weigh term, exclusivity, access to commercial information, confidentiality and change of control with the same care devoted to price.
Who represents us while the rule is being written? Public consultations, industry associations and technical filings are instruments of corporate strategy when a regulatory decision can alter the structure of an entire market.
Ultimately, D2D does not merely place satellites and handsets on the same network. It brings together sectors that grew under distinct regulatory, economic and technological structures. The architecture that emerges from that convergence will depend less on choosing between terrestrial or space infrastructure and more on defining how spectrum, networks and obligations will be distributed among players that can be, at one and the same time, partners, suppliers and competitors.
Opinions published here are my own and do not represent Telebras, CelgPar, Banese or any other organization I work or have worked for. Nothing here is investment advice.
