Does the New White House Executive Order Reframe Artemis Accountability?

Dec. 19, 2025 by Kimberly Siversen Burke

SpaceX received ~$216M in milestone payments in 2025 under its Starship HLS contract. Roughly $3B of a $4.5B potential award has been obligated to date, with ~$2.7B disbursed, reflecting a contract front-loaded with early- and mid-phase milestones.

On Dec. 18, 2025, the White House issued an Executive Order titled “Ensuring American Space Superiority.”

Its headline goals are ambitious but familiar: returning Americans to the Moon by 2028, establishing the early elements of a sustained lunar presence by 2030, and accelerating the integration of commercial capabilities across both civil and national security space. The order also sharply elevates space’s role in missile defense, threat detection from vLEO through cislunar space, and allied space security cooperation.

What makes the order consequential isn’t the vision, but rather the way it formalizes accountability.

Tucked into Section 3(b) is a requirement that directs NASA, alongside OMB, to flag major space acquisition programs that are materially off track on schedule, cost, or performance, or misaligned with White House priorities, and explain how they plan to correct course.

It’s tempting to read this as a shot across Artemis’ bow.

It isn’t.

Under any plausible political or institutional scenario, the EO does not place SpaceX’s Starship HLS award in its crosshairs.

SpaceX is too embedded in the administration’s space agenda, and with Jared Isaacman – a longtime Elon Musk ally and SpaceX customer – now at the helm of NASA, there will be little to no appetite inside either the White House or NASA to penalize SpaceX for schedule slips that are already treated as the expected cost of ambition.

Starship isn’t just an Artemis contract – it’s a strategic asset. NASA retains ample flexibility to rebaseline schedules, contextualize delays, and frame progress in ways that keep HLS well clear of any failing grades.

What is interesting is the precedent the EO establishes and how unevenly it may be applied when you consider Artemis as an example.

Why HLS Sits Awkwardly Inside the EO’s Framework

As painful as this is to admit, HLS now drives the Artemis III schedule, not SLS. Even if SLS and Orion were ready tomorrow, there is no crewed landing without a lander. Besides, SLS is a jobs program sustained by congressional districts and protected through key authorization and appropriations committees. Canceling or disciplining it requires Congress to cooperate, something an EO cannot ensure.

Now, whether Starship HLS is technically 30% behind depends on which acquisition baseline NASA chooses to use. The EO measures slippage against those baselines, and NASA can adjust them enough to avoid tripping the threshold if it wants to. The higher hurdle to clear is timing.

Artemis III has drifted from its original mid-2020s ambitions into the late 2020s, with government watchdogs and NASA’s own advisors warning that HLS delays could push a crewed landing back by years. At the same time, the EO hard-codes a goal of returning Americans to the Moon by 2028.

Those two realities now coexist uncomfortably on the same page.

Even if Starship HLS never formally crosses the 30% threshold, it’s still straddling the order’s broader intent.

The administration is not trying to police schedule math — especially in space, where timelines inevitably push to the right. The order does lock in a political endpoint and requires agencies to account for when risk is retired, deferred, or absorbed along the way. By anchoring lunar return to 2028 and demanding mitigation efforts when programs drift out of alignment, the EO puts pressure on development plans that postpone confronting risk until the very end. Simply put, the EO is structured to ensure Dec. 31, 2027, is not the first time reality intervenes.

And unlike SLS or Orion, which have already flown or are deep into final integration, HLS must still prove out the capabilities that actually make a crewed lunar landing possible. NASA has been explicit about what those capabilities are. Before Artemis III can proceed, SpaceX must execute orbital cryogenic propellant transfer at scale and complete a full uncrewed lunar landing demonstration.

SpaceX has yet to validate either.

The refueling requirement is foundational. Starship HLS relies on launching multiple tanker vehicles, storing cryogenic propellant in orbit for extended periods, and transferring it reliably to the lander. This is not a paper milestone or a design review. It is the first-ever operational capability never executed in orbit.

The uncrewed lunar demo is equally non-negotiable.

NASA requires proof that Starship can autonomously descend to the lunar surface, operate there, and return to lunar orbit, closing risks around navigation, propulsion, thermal performance, communications, dust, and ascent.

Taken together, these are not incremental tasks. They are the moments where innovation either survives contact with reality or it doesn’t. Until they are in the program’s rearview, Artemis III remains exposed, no matter how much progress accumulates elsewhere.

So, in that sense, Starship HLS is the textbook example of the serial-risk architecture the EO is trying to avoid. If any one of those milestones slips, the entire mission slips.

That doesn’t mean the program will get dinged. It does mean that it conflicts with the EO’s risk philosophy.

The administration may tolerate that for Starship, but the EO is written to ensure agencies can no longer pretend that kind of risk stacking is sustainable.

Selective Enforcement May be the Footnote Here

The most consequential effect of this EO is not what it does to Starship HLS. It’s what it does to everyone else.

By codifying a formal process to identify lagging programs and demand mitigation, the administration creates a standard it may selectively invoke. If Starship continues to push to the right while other programs are flagged or terminated under similar language, NASA and OMB will be forced to provide increasingly elaborate explanations for why one set of delays is tolerable, and another is not.

Starship will get patience. Others may not.

That asymmetry is already visible in the unspoken middle bits this EO introduces into the broader space ecosystem, and Artemis is the marquee test case.

Why This Could Help Blue Origin

This EO might also give Blue Origin a chance to gain ground, even without SpaceX losing any.

Blue’s lunar lander is not suddenly ahead of Starship, nor has it become low-risk overnight. What has changed is its institutional utility.

NASA selected Blue as a second HLS provider under the sustained lunar exploration track specifically to avoid a single-provider failure mode. Until now, that redundancy largely existed in the future tense — a hedge NASA could point to without needing to deploy.

This EO effectively shortens the maturity on that hedge.

By forcing NASA to document lagging programs and articulate mitigation strategies, the EO gives the agency political cover to elevate alternatives earlier than planned. Blue doesn’t need to replace Starship HLS for Artemis III to benefit. It simply needs to exist as a credible, fundable backup option that NASA can point to when explaining how it is managing exposure against a 2028 mandate.

In this environment, Blue’s value is not measured by speed or cost. It lies in helping NASA demonstrate prudence under a policy framework that now demands visible, defensible contingency planning.

The Takeaway

This EO is unlikely to be applied uniformly across government-funded space programs. And that’s partly because Starship HLS occupies a category of its own. Its strategic value to U.S. space leadership, the absence of a like-for-like alternative at a comparable scale, and its deep integration across civil, national security, and commercial space architectures afford SpaceX a level of institutional latitude that few, if any, others will enjoy.

That latitude should not be mistaken for a general tolerance standard.

The order establishes a review framework that will be applied far more strictly to programs lacking Starship’s strategic value and economic centrality. Other space sector players should not assume that the flexibility extended to SpaceX will be available to them. The resulting asymmetry is deliberate, reflecting an effort to reassert control over which programs get the ball and which get benched.

Starship sets a precedent — but not a safe harbor.

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