ITAR and EAR
Classification is your export lawyer's call. Holding the data is ours.
Where most payloads sit#
Most commercial spacecraft and remote sensing payloads sit under the EAR as 9A515, and licence requirements for many of those items to Australia were removed in 2024 under AUKUS.
A hosted payload performing a Category XV(a) function stays on the munitions list, and so does launch integration.
The line between the two questions#
Classification is your export lawyer's call. Holding the data is ours.
Neither regime is a cybersecurity standard. Both assume you can show that technical data never reached a person who was not authorised to see it — and that assumption is the part that is assessable.
What gets assessed#
The ITAR 126.7 exemption runs off the Authorized User List and the Excluded Technology List, and your engineering network has to hold the line those lists assume.
Access control, segregation, and personnel screening are assessed here.
Start a conversation if you are carrying export-controlled technical data and have not shown that the network holds.