OET Class I Permissive Change Waiver
The FCC Office of Engineering and Technology (OET) temporarily waives prohibitions on certain Class I permissive changes for previously authorized covered uncrewed aircraft systems (UAS) and UAS critical components.
What it does OET applies the waiver to software and firmware updates for Covered UAS and UAS critical components that were authorized before the December 22, 2025, Covered List addition, when the updates mitigate harm to U.S. consumers. Covered updates include those needed to maintain device functionality, patch vulnerabilities, and facilitate compatibility with different operating systems. The waiver addresses prohibitions in 47 CFR §§ 2.932(b) and 2.1043(b), which otherwise exclude Covered List equipment from certification procedures allowing permissive changes.
Who it affects The action affects authorized UAS and UAS critical components subject to the Covered List addition, as well as manufacturers and other parties responsible for providing their software and firmware updates. It does not cover every possible modification; its stated scope is updates that mitigate harm to U.S. consumers.
Why it matters The waiver preserves the ability to issue safety, security, and functionality updates despite the newly applicable Covered List restrictions. OET finds that special circumstances and the public interest justify a limited departure from the general rules, while retaining time to assess the effect of the Commission’s October 2025 rule revisions.
Key dates and numbers
- January 21, 2026: waiver released.
- December 22, 2025: Covered UAS and UAS critical components were added to the Covered List, triggering the issue addressed here.
- January 1, 2027: waiver expiration date, subject to possible extension after OET re-evaluation.
- 47 CFR §§ 2.932(b), 2.1043(b), and 2.903: relevant equipment authorization and Covered List provisions.
- ET Docket No. 21-232; DA 26-69.