27 January 2026

When to Use (and Not Use) “As a Service” for Government Space Requirements

Clayton Swope

Today, government leaders and policymakers emphasize the importance of unlocking private sector innovation, improving the government’s access to new ideas, and modernizing how the government buys and maintains cutting-edge capabilities. Instead of buying a device, piece of equipment, or system from a company, which the government then owns and operates using government personnel, the government is increasingly turning to “as-a-service” models for acquiring certain capabilities from the private sector. This trend is particularly pronounced in space, as government agencies that buy and use space capabilities—like the National Aeronautics and Space Administration (NASA), the Department of Defense (DOD), and the intelligence community, among others—seek to use space startups and innovative space companies to help them accomplish their missions.

To date, however, there is no policy guidance that can be applied across federal agencies to help officials choose between an as-a-service model or a traditional model—where the government owns and operates a system—for carrying out space missions and functions. This choice shapes the acquisition process but is more than an acquisition issue. The decision is essentially between different operating models: (1) government-owned, government-operated; (2) government-owned, contractor-operated; (3) contractor-owned, government-operated; or (4) contractor-owned, contractor-operated. Three of these models—government-owned, contractor-operated; contractor-owned, government-operated; and contractor-owned, contractor-operated—involve buying all or part of a function as a service and are all flavors of an as-a-service model. Existing policies aimed at maximizing the use of commercial solutions generally—and for use in space missions specifically, such as the executive order to ensure U.S. space superiority issued on December 18, 2025—do not provide guidance for operating model selection because commercial solutions can be used as part of any operating model. The specific meaning of the commercial label has also blurred, leading to a lack of clarity on what is specifically meant by the commercial designation.

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