Every existing lunar data framework governs spacecraft telemetry and object registries. None of them governs compute. That's the gap this framework closes before someone builds the orbital data infrastructure first.
Every existing lunar data framework governs spacecraft telemetry and object registries. None of them governs compute. That's the gap this framework closes before someone builds the orbital data infrastructure first.
Launch access to orbit is consolidating into the hands of one company faster than anyone is writing the rules for what gets built once it gets there. As commercial actors begin eyeing orbital and lunar sites for AI and data infrastructure, a domain the Artemis Accords and the Outer Space Treaty never anticipated, the window to establish multilateral governance comes down to months and years, not decades.
I am the principal researcher on this X-risk governance framework. I am a Fellow at the Tech Diplomacy Global Institute and will be using this as part of my Capstone project. I am also a member, since 2021, of LSIC, the Lunar Surface Innovation Consortium (JHUAPL) as well as LOGIC, the Lunar Operational Guidelines Infrastructure Consortium (DARPA).
As a NASA subcontractor since 2022, I will be drawing from my professional contacts in the space, data and AI governance fields to help inform this working policy framework. Lunar data governance is not an empty field. COPUOS's ATLAC and GEGSLA's working groups, as well as Open Lunar Foundation's Lunar Ledger, have built multilateral infrastructure for sharing mission telemetry, object registries and spectrum filings. What none of that apparatus addresses is a different layer entirely which is jurisdiction over compute and AI infrastructure sited off-world.
In other words, an entire multilateral apparatus exists for lunar data governance and it has no compute/AI jurisdiction component. Because it was built for a pre-AI infrastructure threat model. This is the gap this research and AI governance policy will address.
Off-world compute infrastructure is a loophole that doesn't yet have a name in any existing AI governance regime. Every current mechanism for monitoring frontier AI development, the EU AI Act, US Export Controls on advanced chips, the UK/US Safety Institutes, and any compute-threshold reporting regime now under discussion assumes that the compute is on Earth. Which would put it under some state's jurisdiction.
Orbital and lunar data/AI infrastructure would sit outside all of it. No treaty body currently has standing to monitor, license or even observe compute deployed off-world. And the Artemis Accords are silent on data and compute governance entirely. That gap becomes exploitable the moment it's economically viable to operationalize. And our current diplomatic process is not even close to addressing it.
At the same time, launch access is concentrating around a single commercial provider fast enough that the physical pre-condition for off-world compute which is heavy, frequent, affordable payload delivery, is arriving even before the governance conversation is starting. SpaceX controls roughtly 80+% of global mass-to-orbit as of 2026. And it just announced it is closing its payload ride share services as of late 2028-29. This means that the infrastructure buildout window and the governance window are on a colllision course. This represents a potential of concentration of power of off-world compute, a clear X-risk. A framework produced now, before any actor has operationalized off-world compute, is a pre-emptive closing of the loophole. A framework produced after is a response to a fait accompli, with none of the leverage to shape terms.
Team Member
Lead Research & Drafting Time @20 Hours per week
$18,000
Paid Expert Consultations - Space Law, AI / Compute Governance, Artemis Accord Reps
$5000
Presentation & Travel - LSIC/ LOGIC
$4000
Research Support - COPUOS / GEGSLA document review, citation checking, prior art-mapping
$3000
Thank you, Mark. I appreciate your comment and endorsement. Indeed, LSIC & LOGIC are working groups well placed in which to raise awareness of this existing gap in regulatory oversight.
I endorse this approach - regulation of off-world data and AI infrastructure appears to be a completely neglected field (so far as I'm aware). Paige has a strong technical background in this area and would appear well placed to research this issue, and also to advocate for existing space and lunar working groups to be aware of the potential risks arising from this gap in regulatory oversight.