Abstract
The rapid deployment of commercial satellite mega-constellations in low Earth orbit (LEO) has fundamentally transformed the orbital environment, exponentially increasing the probability of catastrophic collision cascades and elevating the urgency for active debris removal (ADR). However, the existing international space law framework—principally anchored in the 1967 Outer Space Treaty, the 1972 Liability Convention, and the 1975 Registration Convention—was drafted during the dawn of the space age and exhibits critical normative and jurisdictional ambiguities when applied to contemporary multi-satellite architectures and autonomous remediation operations. This paper presents a comprehensive comparative analysis of national regulatory frameworks across leading spacefaring jurisdictions, including the United States, the European Union member states (notably France and Germany), the United Kingdom, Japan, and China. We evaluate how these jurisdictions reconcile property rights under Article VIII of the Outer Space Treaty, fault attribution under Article III of the Liability Convention, and evolving domestic post-mission disposal (PMD) mandates such as the United States Federal Communications Commission five-year deorbit rule. The study demonstrates that fragmented national licensing regimes, ambiguous definitions of space object fault, and unresolved consent requirements for non-cooperative target removal severely impede scalable remediation initiatives. We propose a harmonized multilateral model based on an international debris remediation fund, strict liability presumptions for non-compliant constellation operators, and an inter-operator consensus protocol to operationalize sustainable orbital stewardship while safeguarding commercial innovation.
