On September 17, 2026, Saudi Arabia's Communications, Space and Technology Commission (CST) opened a consultation on two draft documents: 'Regulations for Satellite Filings' and 'Regulations for the Use of Radio Spectrum by Earth Stations in Space Radio Services'. One covers ITU filings made in the kingdom's name. The other covers spectrum licensing for an earth station or an earth-station network. Comments are due October 18, 2026, according to New Space Economy's summary of the announcement.
The drafts do not mention net neutrality. That is expected, because they are spectrum and orbital-filing instruments, not consumer-internet rules. The silence still raises a question worth asking now: when internet access is delivered through a satellite and an earth station, which of the kingdom's existing rules apply to it, including Article 33-1 of the Implementing Regulations?
What the draft does and does not do
The consultation is about administrative gatekeeping. Filings with the International Telecommunication Union reserve orbital and frequency rights under a country's name. Earth-station licensing decides who may operate the ground equipment that connects satellites to users. The same coverage notes that these are proposals, not adopted decisions. Nothing in the text we could confirm says who is covered by the open-internet obligations, how traffic on a satellite link must be handled, or whether satellite operators count as internet service providers.
This is not the first time CST has regulated satellite spectrum. In March 2024 it consulted on rules for radio spectrum use in satellite services, covering licence types, technical conditions and frequency assignment, with comments due April 30, 2024. The 2026 drafts add an ITU filing layer and an earth-station layer. Neither consultation set out net neutrality obligations for the services that run over the spectrum.
The case for treating satellite access differently
The strongest argument for a separate regime is physical. Satellite capacity is scarce, shared and expensive, and a beam over a region has a hard ceiling. Operators have a real engineering reason to manage congestion, and a rule written for terrestrial fibre and mobile networks may fit badly. A regulator could reasonably worry that strict equal-treatment rules would stop a new entrant from offering a tiered or specialised product in remote areas, and that no service would then be built at all.
The argument against the opposite approach is just as plain. If satellite access sits outside the rules, a user in a remote region could get a more restricted internet than a user in Riyadh, with no legal recourse. The kingdom's framework is designed to prevent that.
What the existing framework requires
CST's Net Neutrality Regulations, Decision 501/1444, are dated 18/07/2023. According to the regulator's summary, they aim to protect consumer access to lawful content, ensure non-discriminatory market access, promote competition, and still allow providers to differentiate their offers. Consultation material described by Access Partnership shows the main duties:
- Internet service providers must treat internet traffic equally, without technical or commercial discrimination, restriction or interference.
- Packets are processed agnostic to sender, receiver, class of content or device.
- Providers must disclose differential pricing, traffic management practices and their effect on user experience.
- Zero-rating that limits access to content outside the offer is a breach.
We could not retrieve the text of Article 33-1 itself, so this analysis does not characterise its wording. The relevant point is narrower. These duties attach to ISPs and to content and application providers when delivering internet connectivity. Nothing in the satellite drafts says whether a satellite operator or earth-station licensee providing consumer broadband is such a provider. A reasonable reading is that it should be, but the text leaves that unsettled.
A proportionate answer
There is a pro-innovation way to close this gap, and it does not require rewriting the drafts. CST should state, in the final satellite instruments or in a short clarification, that the net neutrality framework applies to any service that gives the public access to the open internet, whatever the transport. It should keep the existing allowance for reasonable, transparent traffic management. That allowance is the right tool for satellite congestion. Operators can manage a saturated beam, as long as they publish how they do it and do not discriminate by content or application.
This approach is preferable to a satellite carve-out for three reasons. A carve-out invites regulatory arbitrage, with terrestrial providers pressing for the same exemption. It leaves users in the places least served by fibre with weaker protections. And it creates the uncertainty that deters investment. Operators deciding whether to seek a Saudi filing or earth-station licence need to know the full set of obligations in advance, not discover them later.
Comparable debates elsewhere show the pressure points. At India's telecom regulator, stakeholders recently argued that 5G network slicing should not dilute net neutrality, because special quality tiers can become paid prioritisation by another name. Satellite broadband raises the same structural question: when a technical feature creates differential treatment, does the open-internet rule still bind?
What stakeholders should do before October 18
The consultation is the cheapest time to ask. Operators, content providers and civil society can submit comments, supported by analysis, asking CST to confirm whether satellite and earth-station-delivered internet access is within the scope of the net neutrality rules. They can also ask which traffic management practices are permitted when capacity is constrained. A single sentence in the final regulations would remove most of the ambiguity, and it would cost far less than a dispute after launch.