What is an ITU filing?
An ITU filing is the formal notification submitted by a national telecommunications administration to the ITU's Radiocommunication Bureau (BR) in Geneva on behalf of a satellite operator, documenting the planned or operational satellite network's technical parameters: orbital position (for GEO) or orbital elements (for NGSO), frequency bands, polarisation, EIRP, G/T, and service area. The ITU filing establishes the regulatory existence of the satellite network in the international framework and is a prerequisite for gaining coordination priority and ultimately registering the satellite network in the Master International Frequency Register (MIFR).
Procedural steps
For GEO systems, the process follows ITU Radio Regulation Article 9: (1) Advance Publication Information (API) — submitted up to 9 years before launch, notifying other administrations of intent. (2) Request for Coordination — triggering bilateral coordination with potentially affected networks. (3) Notification for Registration — submitted after coordination is complete (or lapse period), within 7 years of the API. (4) Entry into the MIFR — the final registration providing full international protection. For NGSO systems, a streamlined procedure applies but includes milestone requirements to prevent 'spectrum warehousing'.
Strategic gaming of the system
The ITU filing system, based on first-come-first-served priority, has been exploited by some administrations filing for satellite networks far exceeding their actual deployment intentions — creating a backlog of 'paper satellites' that block genuine operators. Kingdom of Tonga, and later several other small Pacific island nations, became known for filing GEO orbital slot clusters on behalf of commercial operators seeking regulatory priority. The ITU has tightened milestone requirements in response, requiring demonstrable launch progress within defined timeframes to retain filing priority.