As consumers have embraced “smart home” technology and specifically advanced locks and entryway security systems, some door lock companies have asked permission from the Federal Communications Commission (“FCC”) to use ultra-wideband technology (“UWB”) in their devices. UWB technology has unique characteristics that can be used to enhance entryway security systems by working with low-power Bluetooth technology to ensure system integrity and guard against “man-in-the-middle” attacks. The FCC has granted several such waiver requests in recent years. To help smooth incorporation of UWB technology and reduce the regulatory burden, some trade associations recently filed a petition for rulemaking urging the FCC to update its rules to allow UWB in new use cases, thus obviating the need for individual requests. The FCC’s Office of Engineering and Technology (“OET”) recently released a Public Notice on this Petition for Rulemaking requesting changes to the FCC’s Part 15 rules to allow for more flexible operations of UWB devices. Comments were due January 30, 2026, and reply comments are due February 27, 2026.
The FCC’s Part 15 rules govern the operation of radio devices and permit operation without a license so long as the devices comply with applicable technical and operational requirements. The rules currently permit UWB devices but restrict their use to “hand held” UWB systems and prohibit fixed outdoor infrastructure uses. These restrictions reflect interference-related concerns that were prominent when the Part 15 rules were adopted more than two decades ago.
The Petition for Rulemaking—filed by the Ultra-Wideband Alliance, the Alliance for Automotive Innovation, and others—asks the Commission to revise its rules to reflect the significant evolution of UWB technology over the past two decades and to eliminate the need for time-consuming waivers. Over the past few years, OET has granted waiver requests for UWB-enabled access control/lock systems, including to Schlage Lock Company LLC and Xthings Industry LLC (formerly U-Tec Group Inc.), among others.
In response to the Public Notice, three comments were filed by the January 30, 2026 deadline:
- Qualcomm Incorporated urged the FCC not to “blanket adopt” waiver conditions into general rules, emphasizing the need for technical interference studies and highlighting broader spectrum policy implications of adopting generally applicable UWB rule changes.
- Covington & Burling LLP filed comments in support of the Petition, emphasizing that reliance on ad hoc waiver requests to bring UWB technology to market is inefficient and costly, and thus does not serve the public interest.
- GPS Innovation Alliance (GPSIA) does not oppose updating the UWB rules but urges the FCC to move forward only after developing a “robust technical record” to ensure protection of satellite-related operations in spectrum bands in or adjacent to UWB operations from harmful interference.
Parties interested in supporting the proposed amendments to Part 15 of the FCC’s rules should consider filing reply comments, which are due on February 27, 2026. More information about the process for submitting reply comments can be found here.
After the reply comment period closes, the Commission may decide to initiate a rulemaking by issuing a Notice of Proposed Rulemaking, which would seek public comment on proposed amendments to the Part 15 Rules. Interested parties would again have the opportunity to file comments and reply comments on the proposed changes. After reviewing the record, the Commission may adopt rule changes in a Report and Order, seek further comment, or terminate the proceeding without adopting changes to the rules. This entire process often takes several months (and frequently longer), and until the rule changes, parties whose UWB devices do not comply with existing Part 15 requirements must rely on the waiver process for authorization.