Paper: Geolocation and Starlink
slides-ipgeows-paper-geolocation-and-starlink-00

Geolocation and Starlink

                                                              September 2025

Geoff Huston
Chief Scientist, APNIC



At APNIC Labs we have been investigating if the collection of data that we
have assembled as part of the measurement work can be used to track the ISP
market share within each national economy. We are interested in trying to
measure the effective level of inter-ISP competition within each national
economy. The base of this derived competition measurement is a notional
count of end users that are served by each ISP that operates in a national
economy.

The measurement process starts with the estimated current population in each
country. The data we use is sourced from the United Nations Population
Division. We use the mid-year population estimate from 2024 and apply the
2023-2024 growth rate to the period from mid 2024 to the present day to get
an estimate of the current population of each country for this day.

The second data set we use is the proportion of the population of each
country that are classed as Internet users. There are three possible sources
for this data, the World Bank, the International Telecommunications Union
(ITU) and the CIA World Factbook. We use the ITU data by preference, but the
three data sets are well correlated in most cases.

The combination of these data sets gives us an estimate of the current
Internet user population per country. It should be noted that this is not
the number of “subscriptions” to a service, as it attempts to include the
number of users behind each subscription. It also is supposed to avoid
“double counting”, so where a user is part of a broadband service and also
has a mobile service, then the user is still only counted once as an
“Internet user”.

The third component of the data is the ad presentation data of the APNIC
measurement program. We use Google Ads to deliver some 35M individual ad
impressions per day. We use a geolocation database to map each user who
received an ad impression to a country, and use a local default-free BGP
routing table to also map each user to their "home" network. At this point
we have now assembled a set of "home" networks (origin AS numbers) and the
geo-located country for each presented ad.

Assumptions

In this work we are making some pretty sweeping assumptions. These
assumptions are somewhat questionable, but we've been forced to make them in
the absence of generally available per-country data that is published by all
countries in a timely and mutually consistent manner.

The first assumption is that Google's ad placement algorithms apply to all
users within a given country uniformly. In defining the ad campaigns, we
attempt to make the placement definitions as generic as possible, so that
within each country the ad placements are roughly equivalent to a random
sampling drawn from all users in that country. The implication of this
assumption is that if an ISP has twice the number of users than another ISP
in the same country, then its users will receive twice the number of ad
impressions. This could be stated as: "The distribution of ad placement and
the distribution of users across ISPs within any country are assumed to
correlate."

The second assumption is that each user uses a single ISP for Internet
access. This is not necessarily the case. For example, a user may use a
local mobile service provider for their mobile Internet access and Starlink
for their broadband access. We also have a user in their workplace using
their workplace's ISP and using a consumer ISP when they are at home. These
days many users have multiple mobile connections, and it is unclear how
these multiple access methods correlate to ad placement, and through that to
our measurements. The conclusion is that we can’t account for such
situations and in uniquely assigning each user to a single ISP in a country
we tend to underestimate the user count for each ISP in consequence.

Due to the uncertainties the follow from these two major assumptions, the
results we generate have an inevitable level of uncertainty. Some individual
comparisons of this data against other sources where we have access to ISP
market share data in individual countries point to an overall level of
uncertainty of up to 15% or so in our estimates of users per ISP. Large
consumer ISPs are still reported as having a large user population in the
generated data, but the data for small networks is very uncertain.

The assumption of uniform distribution of ad placements across all ISPs
within each country tends to fail where the number of placed ads in relation
to the per-country user population is low. The best current example of this
can be seen with the Russian Federation, where ad placement in this country
has plummeted since February 2023 (a consequence of the hostilities between
the Russian Federation and the Ukraine and associated western sanctions
being placed on Russia).

Another general assumption is that all users exist within a country. This
does not hold for users on international flights using onboard Internet
services, nor for ships at sea. In general, this factor should be
insignificant for this exercise, given that as a proportion of the world's 4
billion users (or thereabouts!) this category of users is very small and
should not distort the results to any significant extent beyond the already
noted estimate of 15% uncertainty. But this general assessment does not hold
when the ISP in question operates a service that is not constrained to any
single country, such as a satellite-based service. Even so, when the
satellite service operates as a wholesale service and provides connections
as a service to ISPs, then this is not relevant to this form of measurement.
If an ISP provides service in a country using IP addresses that are assigned
to that ISP, then the conventional geolocation function will still provide
usable results. The situation is different when the satellite operator
provides its own retail services, using IP addresses that have been assigned
to that satellite operator. This is the case for Starlink.

Starlink Data

The basic assumption here is that all IP addresses are used within a
national realm. But this is not necessarily the case with users who are
connected by a satellite service. What is the country when the IP service is
provided to a ship on the high seas?

There are always exceptions to any generalisation, and some country views
that are generated in this manner just stretch credibility too far.

Take Yemen, for example. A country with an estimated population of 10M
people and 3.4M Internet users. The method described above generate a result
that 6.2M users in Yeman using Starlink services.

This measurement result is highly unlikely. It has been generated because
over the past 60 days some 321,000 measurement advertisements originated
from IP addresses that have been assigned to Starlink and Starlink's
geodatabase geolocates these addresses to Yemen. The other three services
providers appear to be the incumbent telco, Yemen Net, and a local ISP in
Aden, Aden Net. The Cloudflare measurement is likely due to a combination of
the local use of Apple's Private Data Relay and the Cloudflare's Warp
product. Together, these three providers accounted for some 210,000 ad
presentations over the same period. The result is that the algorithm we use
assigned some 6M users in Yemen (or 60% of the country’s Internet user
population) to Starlink!

What factors might be at play here that would contribute to this anomalous
result?

One potential factor is the volume of shipping in the Red Sea. These days it
appears that the use of Starlink at sea is pretty much pervasive. A Starlink
service is evidently a faster and cheaper communications service than that
provided by Inmarsat and it has truly global reach. Given that the Starlink
geolocatation data attempts to map every Starlink IP address into one
country or another, even ships at sea using Starlink get assigned an IP
address that is mapped to some piece of land. Some 60 ships a day use the
Suez Canal, and while the transit time from the Indian Ocean to the
mediterranean sea is a few days, it's still a stretch to claim that shipping
crew use of Starlink services alone accounts for some 50,000 ad impressions
per day. These numbers imply that the use of Starlink by shipping may be
part of the factors at play here, but it may not be the only contributary
factor.

Another potential factor is that it's possible that Starlink's geolocation
data does not reflect reality. The Starlink availability map indicates that
Starlink has obtained national regulatory approval to operate in Yemen,
Oman, Qatar, Bahrain, Israel, Jordan and Somalia, but not in Saudi Arabia,
Egypt, Sudan, Eritrea, and Ethiopia. There have been persistent stories in a
number of markets of Starlink resellers that set up a service in a country
that has the necessary national regulatory approvals to use Starlink and
then they ship the dish to a nearby location in a different country. It's an
open question as to the extent this is taking place, and if so then it's
certainly plausible to guess that users in Saudi Arabia are using Starlink
services that are registered in Yemen.

Does Yemen really have 6M Starlink users? That is extremely unlikely. How
many Starlink users is the country likely to have? In neighbouring Oman,
Starlink has a far more modest 0.08% market share, according to this same
measurement technique. I would be surprised if the actual figure for
in-country Yemen users is all that different. For the Yemen data, the high
number might well be the result of a high count of Starlink-using passing
maritime traffic being attributed to Yemen, and also some component of
cross-country usage from perhaps Saudi Arabia and the United Arab Emirates,
nearby countries where Starlink appears not to have local regulatory
approval as yet.

Are there other countries with a similar problem of apparent
over-representation of Starlink users? The ad placement data, assigned to
countries using the Starlink geolocatation data maps to 152 countries. In 21
instances, listed in Table 1, Starlink is used in more than 10% of the ad
placement volumes, which looks to be somewhat questionable.

 CC     60 Day   Est. Starlink   % CC Users     CC Name
      Ad Count       Users
 SJ       726           0          100%      Svalbard and Jan Mayen Islands
 BL       620       6,008           98%      Saint Barthelemy
 TV     7,980       5,799           92%      Tuvalu
 KI    42,234      1,7955           81%      Kiribati
 PN        16          19           72%      Pitcairn
 YE   321,673   6,256,291           59%      Yemen
 NR     6,864       4,071           56%      Nauru
 CK    16,220       4,802           50%      Cook Islands
 MH     7,857       7,805           34%      Marshall Islands
 SS    60,296     369,566           32%      South Sudan
 MF     1,412       4,468           24%      Saint Martin
 VU       214      22,423           22%      Vanuatu
 NE   140,318   1,076,585           21%      Niger
 SD   348,986   3,517,776           19%      Sudan
 TD    78,690     292,985           17%      Chad
 ZW   311,093     801,754           15%      Zimbabwe
 SB     9,916      14,946           14%      Solomon Islands
 MM   237,004   2,899,276           14%      Myanmar
 FM     9,824       6,164           14%      Micronesia
 MG    67,755     612,408           12%      Madagascar
 TO     4,881       5,304           11%      Tonga

    Table 1 – Countries where Starlink attribution is greater than 10%

In the case of Svalbard other geolocation databases geolocate to Norway,
whereas only the Starlink data set uses the SJ two-letter country code

Saint Barthelmy, located in the Caribbean, is an overseas “collectivity” of
France, with a population of some 9,000 people. Its former status was a
commune as a part of Guadeloupe. While the Starlink geolocation database
distinguishes between Guadeloupe and Saint Barthelmy, it appears that other
databases do not draw a distinction between the two, hence the very high
proportion of as placement in this country.

It is likely that the relatively high numbers of Starlink ad presentations
in Tuvalu, Kiribati, Cook Islands. Marshall Islands, Saint Martin, Vanuatu,
the Solomon Islands and Micronesia are due to shipping and yachting traffic.
The relatively low GDP per capita in these island nations would tend to
indicate that Starlink services are unaffordable by such high percentages of
the domestic population.

Starlink operates a Community Gateway service in Naru, and a traceroute to
the IP address prefixes announced by this ISP (Cenpac, AS 5722) reveals a
Starlink connection, presumably using inter-satellite laser link. The
connections using Starlink’s own IP addresses are presumably not part of
Cenpac service, and these are likely to be an anomaly, presumably due to
global roaming used by ships at sea. An examination of the routing tab le
shows a similar community gateway has been deployed for the Tuvalu
Telecommunications Corporation, Tamaani in Northern Quebec in Canada and the
Federated States of Micronesia Telecommunications Corporation.

It's also possible that these additional ad placements could include an
aircraft element, as there have been reports of Starlink selling a mobile
access service to aircraft in flight, but as with ships at sea there is no
published data on the uptake of this class of Starlink users.

There are a number of other anomalies in Table 1. Sudan and Myanmar both
have a high ad placement rate, yet the Starlink access map indicates that
the Starlink service is not available in either of these countries. If that
is the case, then why does the Starlink geo data have IP address entries for
both of these countries and why are so many ad placements being recorded
from these IP addresses? In the case of Sudan, the Starlink gateway
announcing these IP addresses is located in Mombasa in Keyna, and for
Myanmar the relevant Starlink Gateway is located in Singapore. There are
also high counts of ad placements for Starlink services that geolocate to
Zimbabwe, Niger and Chad. The situation in the Cook Islands is potentially
relevant here, where prior to regulatory approval to operate in the Cook
Islands it was reported that domestic enterprises and some users were
purchasing a Starlink service in New Zealand under a Roam Unlimited plan,
and then shipping the equipment to the Cook Islands. There is no regulatory
approval for Starlink to operate in South Africa, Namiba, Angola, and all of
the countries in northern Africa and much of western Africa, and it’s likely
that there is a similar use of Starlink’s roaming services to circumvent
these local regulatory issues and purchase a roaming service elsewhere and
use in in these countries.

For 20 of these 21 countries (the sole exception appears to be Pitcairn
Islands) it’s highly likely that the inferred level of use of Starlink
within these countries is inflated by these factors, and the resultant view
of the domestic ISP market is skewed as a result.

What is the role of Geolocation?

With the rise of the use of satellite services for these global roaming
services this raises some basic questions about IP geolocation and its role.

Is this about the end user's physical location on the surface of the planet?
In this case do we need to use a new geolocation code (or codes) for
locations at sea? Is "at sea" defined by the conventional 12 nautical mile
sea boundary? Or is some other interpretation of a margin where a country
has a territorial sea claim?

What about ships in international waters? The conventional approach to ships
at sea assert that the ship (and its crew) are subject to the laws of its
flag state in international waters. What about aircraft in flight? It might
appear that a similar situation to ships at sea may apply to aircraft in
flight, but a more commonly applied convention (the Tokyo Convention) is
that the lows of the country of aircraft registration apply to an aircraft
in flight for international flights.

So what is the geolocation of the occupants of that ship or flight when
accessing that Internet?

- Is it the location of the earth station used to pass packets to the
spacecraft that relays the packet back to the ship or the aircraft?

- Or is it the location of the earth station used to receive the relayed
packets and re-inject them into the terrestrial Internet?

- Should the geolocation be a reflection of the legal conventions of whose
legal code applies to the ship or aircraft while travelling on an
international journey.

- Should the geolocation reflect the country who is is operating the
satellite constellation that is performing the packet carriage function?

- In the case of ships travelling in territorial waters or aircraft flying
over territorial airspace should the geolocation reflect the territory in
question? In which case what should be do for those parts of the earth's
surface that are not encompassed by accepted territorial claims?

There is a deeper assumption here concerning the behaviour of IP addresses.
Does it even make sense to statically assign a geographic location to an IP
address when the addressed device is in motion? What are the motivations for
performing the location attribute assignment, and how can we implement the
dynamic nature of such an assignment? There are no clear unambiguous answers
to such questions, and perhaps that ambiguity reflects a common uncertainty
that there is no clearly defined purpose for geolocation assignment in the
first place.