In this work, we introduce an electro-absorption (EA)-based retro-modulator for effective realization of free-space optical communications via passive downlinks. Demands for deep modulation and broad directionality in such links are met by its corner-cube assembly of EA-modulators. The EA-modulators use semi-insulating InP as its band edge absorption exhibits an Urbach tail near the 980-nm wavelength of the laser light. This enables Urbach-edge-assisted EA, which allows the field-induced absorption to be optimized via temperature. The theory, from a uniting of the Einstein model and Franz–Keldysh effect, and experiments, from a prototype, show good agreement with deep (greater than 15%) modulation depths. Such functionality can meet the key demands of emerging free-space optical communication links.