Starlink's users in Uganda lost service on New Year's Day. On 1 January 2026, two weeks before a general election and at the government's request, the company switched on what it called "a new service restriction tool for Uganda" and told the regulator that no active terminals were left, by the company's own account. It had no Ugandan licence and was working to get one. On 13 January the regulator ordered every network in the country to suspend public internet access, two days before the vote. In May Starlink signed a provisional operating licence. Nobody in Geneva had to rule on anything. Space Intel Report drew the contrast with Iran within days.

Iran has been asking for the same thing since March 2023, through every channel the international rules provide. On Sunday 4 October 2026 its foreign ministry summoned the Norwegian ambassador, Paul Bjørnstad, and Mohammad Hassaninejad, the ministry's director-general for international peace and security, handed him a formal note of protest. According to the semi-official Tasnim agency, the complaint was that Norway had failed to stop Starlink terminals operating inside Iran without Iranian permission, as international radio rules expect of it. A board of the International Telecommunication Union has agreed with Iran, in writing, several times. Apart from a handful Iran reported by number, the terminals are still on.

The rules are the same for both countries, and so is the company. Set these cases side by side, Uganda, South Africa, Iran and a request from Ukraine, and one pattern holds across them. On this network, a host country's refusal has been enforced where the operator had a stake in its market and the government able to instruct the operator had no policy against it. Where neither held, no licence, international finding or diplomatic protest has yet made it happen at scale.

A satellite constellation looks stateless. Its spacecraft circle the planet every hour and a half, its terminals fit in a backpack, and its operator is a company in Texas. The rules that govern radio see it differently. Under the ITU's Radio Regulations, every satellite system is filed by a national administration that takes on obligations for it. Article 18 requires transmitting stations to hold a licence from the government to which they are subject. Resolution 22, adopted at the World Radiocommunication Conference of 2019, covers cases like Iran's: terminals of a satellite system transmitting from a country that has not authorized them. It expects the administration that filed the system to cooperate with the affected country and to act to stop those transmissions. An older text, Resolution 25, written in the late 1990s for the first global satellite phone networks, rests on the same principle: a global system operates in a country with that country's consent.

For the filings at issue, the ITU's Radio Regulations Board treats Norway as the notifying administration, and its requests went to Norway from the start. The United States was copied in from mid-2023. In the Board's record it appears under different labels: listed under an appendix item for supporting filings, described at one point as an associated administration, which the Board said carries no obligations under the Radio Regulations, and recorded at the 101st meeting as notifying administration of the STARLINK satellite system. Why the filings at issue sit with Norway is not on the public record. When Iran wanted the terminals on its territory switched off, the formal address in Geneva was Oslo; the government with political weight over the operator was in Washington.

Geneva, 2023 to 2026: What the Board Could Not Do

The Radio Regulations Board took up Iran's complaint at its 92nd meeting, in March 2023, and has returned to it at every meeting since, eleven in all. At the 93rd, Iran's engineers described a terminal inside the country reaching an internet exchange abroad with no Iranian licence, and a letter to Norway that had gone unanswered was sent again, copied to Washington. From there three turning points carry the file.

The first was a finding of fact. In 2023 the Board called transmissions from territory where the service is not authorized "in direct contravention" of the rules, and asked for the terminals in Iran to be disabled. It read a Starlink warning message in English and Persian as a sign that the operator checks where its terminals are, and ruled that administrative, contractual and operational restrictions on Starlink customers did not count as compliance.

The second was a finding of duty. At its 98th meeting, in 2025, the Board concluded that compliance implied that an operator able to geolocate the terminals on its network "was required to disable terminals operating without authorization within a territory," including remotely if necessary. It agreed to Iran's request for a dedicated page on the ITU website and put the matter in its report to the 2027 World Radiocommunication Conference. By the end of that year it was recording that Norway was unwilling to enforce its decisions on its operator "in the absence of an explicit requirement in the regulatory framework."

The third was a finding of impotence. At its 101st meeting, in 2026, the United States argued that the Board was exceeding its mandate under Article 14 of the ITU Constitution; the Board has maintained that it acts within it. The Board found Norway's actions not compliant with Article 18, Resolution 22 and Resolution 25, stated that STARLINK was capable of geolocating terminals and disabling them remotely, and concluded in the same breath that it had no authority to suspend the system's frequency assignments. At its 102nd, Iran reported that unauthorized operation was continuing, asked again for suspension, and was told again that the Board could not. The Board noted that neither Norway nor the United States had answered its latest requests, and it added a limit of its own: the framework another resolution, Resolution 123, sets for earth stations in motion could not be carried into Resolution 22 without an explicit decision by a World Radiocommunication Conference. Its decisions, it had said a year earlier, rest on the rules as they stand, not on what the 2027 conference may change.

The Board found that Norway fell short of its obligations. The Board urged Oslo and Washington to act. The Board published the file on the ITU's own website. None of that could suspend a single frequency assignment. The international system could say who was expected to flip the switch. It could not flip it.

"Neither Required Nor Practicable"

Washington's clearest statement in the file came around the Board's meeting of June 2024. The Federal Communications Commission told the ITU, according to Space Intel Report, that "for global constellations, it is neither required nor practicable to turn off satellite beams over a given geographic area," and that the dispute was a matter of border enforcement, "not a matter for the ITU." American replies said SpaceX had switched off a small number of terminals whose serial numbers Iran supplied, and submissions argued that the operator could not practicably verify where every terminal was.

Part of that is sound. A beam lands on the ground as a footprint, and footprints spill across frontiers; dimming the beams over one country could cut service in its neighbors. Finding every smuggled terminal is hard. But the Board never asked for beams to be dimmed, and the record shows what the operator can do with terminals when it acts. In October 2025 SpaceX said it had disabled more than 2,500 Starlink devices near scam compounds in Myanmar, and the Board soon noted a case of more than 2,500 terminals disabled in one area. Ten weeks later came Uganda, where the restriction covered the whole country, by the company's account.

Neither case proves that every terminal in Iran could be switched off as reliably or without side effects. Myanmar shows targeted disabling at scale; Uganda shows a country-wide restriction, though how its tool worked has not been disclosed. Impracticability is the wrong description of what the operator can do with terminals. It is a fair description of what it has not done in Iran.

Africa: Two Answers, Two Speeds

Uganda's case was simple, and it had a witness who said so in public. In the first days of January, with Starlink dark in his country by the company's account, the opposition leader Robert Kyagulanyi, known as Bobi Wine, posted an appeal addressed to Musk himself. "Here in Uganda your Starlink has disabled citizens' access to its internet just days to the January 15th election," he wrote, and he ended the statement with four words: "Democracy dies in darkness." He addressed the company, not Geneva and not his own regulator. A customs memo of 19 December had already told officers to hold Starlink equipment without military clearance, many Ugandans feared an election-season shutdown, and some activists turned to offline messaging apps. The shutdown came on 13 January. The company was seeking a licence, and in May the licence was signed.

South Africa took longer, and shows the terms. Its regulator, ICASA, said in November 2023 that Starlink was not licensed there. A licence would require historically disadvantaged groups to hold 30 percent of the local entity, a condition SpaceX did not accept; in November 2024 the company asked ICASA to accept equity-equivalent investment programmes instead, and in December 2025 the communications minister issued a policy direction allowing them. Enforcement came in steps. In February 2024 around 350 to 400 reseller-managed accounts in South Africa were deactivated. In April Starlink told roaming customers across Africa that those who had stayed more than two months in places where it was not authorized, South Africa, Ghana, Botswana and Zimbabwe among them, had to change their account country or face limits. Wider disconnections of roaming accounts began around June 2025. Namibia's regulator ordered the company to stop operating without a licence in late 2024.

In South Africa the tool was the account country, the kind of customer-level restriction the Board had ruled was not enough in Iran, and enforcement was slow and partial. Even so, both African refusals counted, at the operator's pace, in markets it was working to enter.

Washington's stance in Africa is on record, and it pointed toward licensing. In May 2025 the Washington Post reported State Department cables showing that Secretary of State Marco Rubio had increasingly instructed officials to push governments for regulatory approvals for Starlink; in Lesotho, which licensed the company soon after tariff talks began, an internal memo hoped the licence would demonstrate goodwill toward American business. The same month, South Africa's presidential spokesperson said Starlink's licensing would "certainly" be discussed when Cyril Ramaphosa met Donald Trump. No American statement on the Ugandan block is on record. The policy reported at the time was to press African governments to license Starlink, and a licence means complying with the government that grants it. In Iran there is no licence to work toward, and Washington's policy pointed the other way.

Iran: A No Without Effect at Scale

That policy was explicit. On 23 September 2022, a week into the protests after the death of Mahsa Amini, the Treasury widened the internet services Iranians could receive despite sanctions. Secretary of State Antony Blinken wrote on Twitter that the licence would give Iranians greater access to digital communications "to counter the Iranian government's censorship." Musk answered that SpaceX was activating Starlink. Naftali Bennett, Israel's former prime minister, said in June 2026 that he had started a process of acquiring and smuggling tens of thousands of terminals into Iran, a claim no one has verified; he said the current government had stopped the effort. In February 2026 the Wall Street Journal reported, citing US officials, that the State Department had bought nearly 7,000 terminals and moved about 6,000 into Iran after the January crackdown, the first time Washington had sent the kits in directly. On 28 February the United States and Israel struck Iran. A ceasefire in April broke down in July, and a June memorandum lapsed without a permanent ceasefire. The government copied on Iran's request to switch the terminals off had been sending them in, and has since fought a war with it.

Tehran's response has been on the ground. Owning a terminal carries six months to two years in prison, importing or distributing them up to five years, and espionage charges can bring the death penalty. In August 2026 the police announced that about 1,000 terminals had been seized and 163 people arrested over four months. In mid-October Mohammad Amin Aghamiri, secretary of the Supreme National Cyberspace Council, called Starlink "a tool of war" and said Iran had "several systems for cutting off Starlink satellite terminals." In September a deputy minister, Mohammad Hafez Hakami, warned that a widespread Starlink could be the last nail in the coffin of the state's control over cyberspace.

Officials disagree about how much the terminals carry. In September Behzad Akbari, who runs the state Telecommunication Infrastructure Company, said around 10 percent of Iran's international traffic, about one terabit per second, had not returned to official gateways after the wartime blackout, and separately estimated Starlink's traffic at about one terabit per second, no longer a potential concern but a reality. In another interview he called Starlink's share of total traffic not a significant figure and the terabit estimate an approximation.

The Iranian state can punish the people under the network and try to jam its signal. The instrument the Radio Regulations give every country over the network itself, a licence the filing administration is expected to back, has had no effect at scale for three and a half years.

Tehran said no in the form the treaty prescribes, and the network stayed.

A Test From Ukraine

Ukraine supplies a check on the pattern, and its October speed cap has its own piece in this archive, linked below. In January 2026 Kyiv's defense ministry asked SpaceX to act against Russian drones carrying Starlink terminals. Within days the company had tightened speed limits and, with the ministry, built a verified list; terminals in Ukraine that were not on it were cut off in early February. It was a host country's request to exclude, the operator acted on it, and there is no record of Washington standing in the way.

October is a different kind of case, and it sits outside the pattern rather than in its "not" column. Military links, reported mainly as Starshield, the service the Pentagon buys from SpaceX, were capped at speeds reported between about 72 and 161 kilometers an hour; sources differ on which system was hit, and whether Ukraine has Starshield access at all is disputed. Musk said limits on Starshield are decided by the US military and ultimately the president; Reuters reported the order came from the White House, which US officials disputed; the Wall Street Journal reported that Musk ordered it. On 20 October, in Oslo, Zelensky said after meeting the American envoy Steve Witkoff that service would be restored within 48 hours. The next day he said it was still restricted. Here Kyiv is not using a host country's power at all. It is asking for a better service on a system it does not run or contract for, and that is what a state looks like when it has no licence lever left: a petitioner.

Where the Decision Sits

The portable version, scoped to these cases and to this network as it is governed today, can be tested. Two conditions, both visible before the outcome, sort the cases. Did the operator have a stake to gain or keep in that market? Did the government able to instruct it have a stated policy against the host? In Uganda and South Africa the company was seeking a licence and Washington's reported policy was to press African governments to grant one; their refusals were enforced. In Ukraine in January the company had a large market already running and Washington backed Kyiv; the request was carried out. In Iran there is no licence to seek and Washington's stated policy was to help Iranians get around their government; the refusal was not enforced at scale. A case where both conditions favored the host and the operator still refused, or where neither did and the host still prevailed, would break the pattern. Iran had the rules on its side and not the operator; Uganda had the operator on its side and needed no rules. A state can keep the operator out, if the operator agrees to be kept out. On everything else, as Kyiv found in October, it petitions.

The Strongest Case for the Way It Works

The strongest objection accepts the record and says the Iranian outcome is right on its merits. Declining to enforce a censoring government's licence protects many people, in line with a policy Washington has held openly since 2022. On this view there is no pattern to explain, only a principle about free information applied where it matters most.

Uganda is the hardest test of that defense. There the operator complied with a government request that left no active terminals in the country two weeks before a national election, twelve days before the government ordered public internet access suspended nationwide, in a market where it was working toward a licence. Whatever one thinks of each decision, they were not made by a single principle about free information. They line up instead with where the operator stood and where Washington stood. Nothing here argues that Iran's licence should have been enforced. The claim is that in each case the decisive step was taken by others, and no international body could change it.

A further objection blames the rulebook. Resolution 22 was written in 2019 for unauthorized terminals, so the gap is not that the rules never imagined the problem; it is that they rely on a filing administration willing to act, and give the Board no remedy when it does not. That is a fair point about the cause. It does not change who held the decision in 2026.

What Would Show This Is Wrong

The pattern makes a prediction: a host country's refusal will be enforced where the operator has a stake in its market and the government able to instruct it has no policy against it, and not enforced at scale where both point the other way. A case that breaks that, in either direction, would count against it. A 2027 conference outcome that gives host countries an enforceable remedy, used successfully against an unwilling operator, would be one. On the historical side, documents showing that Norway in fact required the operator to act in Iran and was ignored, or that Washington pressed the operator to comply, would show the reading of these cases is wrong.

The 103rd Meeting

The Board meets again. If the pattern holds, Iran will report that the terminals are still transmitting, and the Board will again find that it cannot suspend the system's frequency assignments. Meanwhile, the next regulator that writes to the company will get an answer, quickly or slowly or not at all, and the answer will not come from Geneva.

Evidence Map

Facts, interpretations, forecasts, and disconfirming signals.

Core claim. In the cases examined, a host country's wish about the Starlink network was enforced where the operator had a stake in that market and the government able to instruct it had no policy against the host (Uganda, South Africa, Ukraine in January), and was not enforced at scale where neither held (Iran). Ukraine's October request concerns a service level, not a refusal, and shows a state without a licence lever. The licence, the ITU Board and diplomatic protests did not by themselves change any outcome at scale.

Evidence level. Facts, high: RRB decisions from the 92nd to the 102nd meeting and the Board's finding that STARLINK can geolocate and remotely disable terminals (ITU); the FCC's June 2024 statement (Space Intel Report); SpaceX's disabling of more than 2,500 devices in Myanmar (October 2025) and its Uganda restriction of January 2026 (Daily Monitor); South African deactivations and disconnections (Techzim, Techpoint Africa); the WSJ's February 2026 report on State Department terminals; the January and February 2026 measures at Kyiv's request; the October 2026 Starshield cap and the conflicting accounts of who ordered it; Uganda's internet shutdown of 13 January 2026 (Human Rights Watch) and its May 2026 licence (Space in Africa). Interpretation, medium: that the operator's market stake and the instructing government's stated policy are the deciding variables; for Uganda, Washington's stance rests on its general Africa licensing policy, with no Uganda-specific statement on record. Open: why the filings at issue sit with Norway; who ordered the October cap.

Signals to watch. RRB 103rd meeting; WRC-27 and the Board's report under Resolution 80; South Africa's licensing of Starlink under the equity-equivalent direction; Uganda's licence terms; Iran's further steps against Norway; Kyiv's talks with the Pentagon and SpaceX. The disconfirming test is set out in the section above.

Sources. ITU, Provision of Starlink satellite services in the territory of the Islamic Republic of Iran; Space Intel Report via Kratos, FCC to regulators; Daily Monitor, Starlink blocks Ugandan users ahead of polls; AllAfrica, Bobi Wine appeals to Musk; Washington Post via Benton, U.S. pushes nations facing tariffs to approve Starlink; TimesLIVE/Reuters, Ramaphosa and Starlink licensing; Arab News, SpaceX disabled 2,500 devices at Myanmar scam centers; Rudaw, Iran summons Norway's ambassador; Iran International on the WSJ report; Al Jazeera, Iran targets Starlink as 'tool of war'; Techzim, February 2024 deactivations; Techpoint Africa, June 2025 disconnections; Human Rights Watch, Uganda shutdown; Space in Africa, Uganda licence; Al Jazeera, US-Iran fighting escalates again; UNN, Zelensky in Oslo.

Jerry van der Laan writes The Manifest Archive, Forensic Narrative Intelligence Writing on the systems beneath power, money, and history. He traces the structures beneath them.

The questions, the editorial judgments and the responsibility for every published claim are mine. AI assists with the research, the drafting and the source checks.