FCC Pre-Approval Guidance List v18r09: What Changed
FCC Pre-Approval Guidance List v18r09: New Sub-THz PAG, OVER6G and UWB15F Removed, 6 GHz Narrowed
The FCC Pre-Approval Guidance list changed on 30 September 2026. The Laboratory Division of the FCC's Office of Engineering and Technology posted KDB Publication 388624 D02 Pre-Approval Guidance List v18r09, replacing v18r08 from March 2025. The revision applies as soon as it is posted, and it changes which devices a Telecommunication Certification Body (TCB) must send to the FCC before issuing a grant.
Background: how the FCC Pre-Approval Guidance procedure works
Most US equipment authorizations are granted by TCBs rather than by the FCC itself. For technologies that are new, or where the FCC still wants to review results case by case, the Commission keeps a list of items that need its guidance first. This is the Pre-Approval Guidance (PAG) procedure under 47 CFR § 2.964, formerly known as Permit But Ask. Each item has a six-character code, and when a product falls under one, the TCB has to submit a PAG request and wait for FCC feedback before it can grant.
The procedure itself is described in 388624 D01 (v13), and the list of items is in 388624 D02. Only D02 changed this time. Because the list decides whether an extra FCC review step sits in the middle of a certification, every revision has a direct effect on lead times.
Key Changes in the FCC Pre-Approval Guidance List v18r09
The FCC's change notice sums up the revision in three moves: one item added, two removed and one narrowed.
New SUBTHZ item for devices above 95 GHz
Devices above 95 GHz certifying under Part 15.258 (equipment class THZ) or Part 18 (class 8TZ) now require a PAG. The FCC points applicants to KDB 800303 for sub-THz measurement guidance, and Appendix D of D02 gives an eight-point checklist. It asks for:
the correct equipment class on Form 731, with no modules
emission scans up to the 3rd harmonic (Part 15.258) or 10th harmonic (Part 18), or 750 GHz if lower
a lab accreditation scope that covers the highest measurement frequency, since partial scopes aren't recognized
test reports documenting vibration mitigation, antenna alignment, separation distance and calibrated ambient conditions, with atmospheric attenuation factors per KDB 800303
evidence that conversion-loss tables were applied and image-frequency artifacts were addressed
pulse-desensitization or FMCW correction factors where appropriate, with FMCW and frequency-agile radars tested with their sweep or hop active
cross-references to KDB 842590, KDB 974614 D01, KDB 896810 and ANSI C63.10-2020
OVER6G and UWB15F removed
The OVER6G item, which covered RF exposure evaluation above 6 GHz, and the UWB15F item for ultra-wideband devices have both been removed. Products that used to trigger them no longer need a PAG for those reasons, although every other applicable item still applies.
UN6GHZ limited to GVP devices
For the 6 GHz band, a PAG is now needed only for geofenced variable power (GVP) devices in U-NII bands 5.925–6.425 GHz and 6.525–6.875 GHz, under KDB 987594 guidance "when available". The existing exceptions remain: no PAG for low-power indoor access points (6ID), subordinates (6PP), indoor-only clients (6XD), or a Class II permissive change for a certified 6 GHz module covering RF exposure in a specific host.
What This Means for Manufacturers
Makers of sub-THz radars, sensors and imaging devices above 95 GHz should expect an FCC review step before grant, and should budget time for it.
Test labs need accreditation that reaches the highest frequency measured, possibly up to 750 GHz. It's worth checking your lab's scope before testing starts.
Sub-THz test reports need more detail than many labs provide today, especially on ambient conditions and correction factors.
Products with RF exposure evaluations above 6 GHz, and UWB devices, may now go straight through the TCB, which can shorten certification time.
Most 6 GHz Wi-Fi products, including standard-power devices that aren't GVP, no longer need a UN6GHZ PAG.
Applications already in the queue should be checked with the TCB, as the new list applies from 30 September 2026.
Certification Impact Summary
Area | Before (v18r08) | After (v18r09) | Impact level |
Devices above 95 GHz (Part 15.258 / Part 18) | No dedicated PAG item | SUBTHZ PAG with Appendix D checklist | High |
RF exposure above 6 GHz | OVER6G PAG required | Item removed | Medium |
UWB devices | UWB15F PAG required | Item removed | Medium |
6 GHz U-NII devices | UN6GHZ applied outside the indoor low-power exceptions | UN6GHZ only for GVP devices | Medium |
Lab accreditation | Usual scope checks | Scope must cover the highest frequency measured | High |
Sub-THz test reports | Standard reporting | Ambient conditions, attenuation and correction factors documented | High |
Timeline and Required Actions
Key Dates
Date | Milestone |
31 March 2025 | Previous list, 388624 D02 v18r08, posted |
30 September 2026 | 388624 D02 v18r09 posted and applies immediately |
Required Actions for Manufacturers
List products in your US pipeline that operate above 95 GHz or use 6 GHz GVP operation.
For sub-THz devices, confirm the equipment class (THZ or 8TZ) and the full emission scan range with your lab.
Check that your lab's accreditation covers the highest frequency you'll measure.
Review sub-THz test report templates against the Appendix D checklist and KDB 800303.
Ask your TCB whether pending applications that relied on OVER6G, UWB15F or UN6GHZ can now proceed without a PAG.
Update certification lead-time plans for both the new review step and the removed ones.
Conclusion
The FCC Pre-Approval Guidance list v18r09 takes FCC review away from some mature product types and adds it where the technology is still new. Sub-THz device makers should plan for a tighter test report and an extra review step, while many 6 GHz, UWB and above-6 GHz RF exposure filings get simpler. Contact our team for help with FCC certification planning and TCB filings.
