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Robot radio frequency BNetzA: 2026 duties

Robot radio frequency BNetzA: which bands are licence-free, when a 5G campus network is required, and what the FuAG dossier contains. Plant manager checklist.

Dr. Raphael Nagel (LL.M.)
Investor & Author · Founding Partner
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Robot radio frequency BNetzA: what plant managers must register in 2026

An autonomous patrol robot is, at its core, a rolling radio device with sensors. The moment it passes the plant gate, it falls under the Radio Equipment Act (Funkanlagengesetz, FuAG), and the operator of the plant site is liable for compliance. Anyone procuring a robot in 2026 is not just buying hardware. They are taking on frequency responsibility. This article lists what is licence-free, what is not, and which documents the Federal Network Agency (BNetzA) wants to see in an audit.

Robot radio frequency BNetzA: what requires registration in 2026

A modern patrol robot typically uses four radio technologies in parallel: WLAN for connection to the plant network, LTE or 5G for backup connectivity, and LiDAR for navigation. UWB for precise indoor localisation is an optional addition. Not every one of these technologies requires registration. But every one requires documentation.

The BNetzA works with the instrument of general assignment (Allgemeinzuteilung). For WLAN in the 2.4 GHz, 5 GHz and (since 2021) 6 GHz bands, and for the SRD bands, no individual registration per robot is required. The condition remains CE conformity under the Radio Equipment Act (FuAG).

It is different for 5G campus networks in the 3.7 to 3.8 GHz range. Here the BNetzA requires an individual assignment per site. The administrative fee starts at 1,000 euros (Frequency Fee Ordinance), and the term runs up to 10 years. Passive drone detection via RF scanning is licence-free. Active radar systems or jamming solutions are subject to approval or, for private operators, simply prohibited.

The duty falls on the operator of the plant site, not the manufacturer of the robot. Anyone renting a robot also rents the compliance obligation.

General assignments: what is possible without an application

Most radio bands a patrol robot uses are covered by general assignments. That means: no individual registration, no fee, immediate use. The most important ones:

  • WLAN 2.4 GHz: generally assigned, EIRP limit 100 mW (BNetzA General Assignment Vfg. 7/2019). Suitable for robust, interference-tolerant connections with low bandwidth.
  • WLAN 5 GHz: generally assigned, EIRP up to 200 mW outdoor and 1 W indoor depending on subband (BNetzA General Assignment Vfg. 7/2019). Higher bandwidth, shorter range.
  • WLAN 6 GHz (Wi-Fi 6E): generally assigned for indoor operation in Germany since 2021, 250 mW EIRP (BNetzA Vfg. 34/2021). Relevant for high-bandwidth robot telemetry inside halls.
  • SRD 433 MHz and 868 MHz: usable for telemetry and sensors with duty-cycle restrictions. Typical for outdoor sensor stations.
  • UWB 6 to 8.5 GHz: generally assigned, relevant for indoor localisation and precise docking manoeuvres at the charging station.

The duty to provide a declaration of conformity under FuAG remains in every case. The operator must hold the CE documentation of the robot available at all times and present it on request from market surveillance. Anyone collecting only a folder of delivery notes will fail in an audit.

Next step: review the hardware specification of the QR-2 for 24/7 outdoor operation, where the frequency bands per model are listed.

5G campus network: when the individual assignment pays off

For plant sites over 50,000 m² with multiple robots, AGVs and sensor networks, a dedicated 5G campus network in the 3.7 to 3.8 GHz band is technically superior. Three reasons:

  1. Deterministic latency below 10 ms, plannable and contractually assurable.
  2. Plannable bandwidth without competing with public mobile users.
  3. Sovereignty over the network, including own SIM profiles and local data residency.

The application to the BNetzA contains site data, a frequency utilisation plan, transmission power per antenna, and the purpose of use. Processing time, according to BNetzA, is 6 to 10 weeks (BNetzA campus network information page), provided documentation is complete. The fee follows the Frequency Fee Ordinance and is a function of bandwidth and area.

Where does it not pay off? For plant sites under 20,000 m² with one or two robots, a well-planned WLAN 6 GHz network with overlapping access points is sufficient. The allure of the 5G campus network often exceeds actual demand.

For KRITIS sites with LiDAR streaming, real-time drone correlation and multi-robot swarms, we recommend the campus network. Details on the sensor package in the QR-3 with LiDAR and drone detection.

LiDAR and optical sensors: outside radio law

A common misconception in procurement departments: that LiDAR is relevant under radio law. That is wrong. LiDAR works in the infrared spectrum, typically at 905 nm or 1550 nm wavelength. That is laser technology, not radio technology.

No BNetzA registration is required. Instead, DIN EN 60825-1 for laser classes and the requirements of the occupational safety regulations apply. The QR-3 uses laser class 1, eye-safe under all foreseeable operating conditions, no warning labelling on the robot or on the plant site required.

Thermal cameras in the LWIR range (8 to 14 µm) are also passive and not relevant under radio law. They receive heat radiation, they emit nothing.

A documentation obligation still exists. The EU Machinery Regulation 2023/1230 requires documentation of all radio interfaces and safety-relevant sensors of autonomous machines. The documentation includes laser class, wavelength, beam divergence, and the safety distance under foreseeable malfunction.

In parallel, EN ISO 13482 defines safety requirements for mobile service robots, including requirements for optical sensors and safety functions.

Drone detection: the legal grey zone

Drone defence is a sales argument for many robotics manufacturers in 2026. Plant managers should understand the legal position precisely, otherwise they buy a function they cannot legally operate.

Passive RF sensors that merely receive and classify drone control signals (typically 2.4 GHz and 5.8 GHz for consumer drones, 433 MHz and 915 MHz for telemetry) are licence-free. They only receive, they do not transmit.

Active detection with radar (24 GHz for short range, 77 GHz for longer range) requires a frequency assignment depending on transmission power and band, or falls under the SRD general assignment. The interpretation is not trivial. Clarify the exact operating mode before procurement.

Jamming and spoofing of drones is simply not legally usable in Germany by private operators. Not even by KRITIS operators. Only the police and the Bundeswehr have separate powers. KRITIS operators may detect and alert, but not actively interfere. The response remains a state task.

When selecting drone detection, pay attention to the operating mode: passive is permitted, active requires examination, active countermeasures are prohibited. Anyone offered a solution that "defends against drones" should ask for the precise functional description in writing.

Concrete integration in the perimeter concept: Perimeter protection for industrial parks.

Radio Equipment Act (FuAG): operator obligations

Every radio device in the robot requires a CE marking and an EU declaration of conformity under FuAG. The manufacturer supplies the technical documentation, the frequency usage data, and the declaration of conformity with every robot. At Quarero the pre-filled compliance dossier is part of every delivery, not a follow-up add-on.

The operator must retain the documentation 10 years after placing on the market and present it on request from the market surveillance authority. Market surveillance in Germany is largely with the BNetzA.

Caution with in-house modifications: as soon as the operator modifies the robot (additional antennas, external transmitter, third-party sensors), an own placing-on-the-market obligation arises. The operator then takes on full responsibility for conformity. Practical consequence: avoid in-house modifications on the radio path or coordinate them in advance with the manufacturer.

Violations of the FuAG carry fines of up to 100,000 euros (§ 22 FuAG). For severe violations, distribution stops for the device and site shutdown are possible.

Practice: registration process in four steps

The operational workflow for a plant manager bringing a robot into service in 2026 can be structured in four steps.

Step 1: inventory the frequency requirement. Which bands does the robot use (WLAN, LTE, UWB, SRD, LiDAR)? Which the plant network? Which the detection systems? A simple table with band, transmission power, location and operating mode is sufficient.

Step 2: reconcile against general assignments. What is covered by a BNetzA general assignment, what is not? Request the manufacturer's CE declarations of conformity and file them.

Step 3: if needed, apply for a 5G campus network. Have a frequency utilisation plan drawn up (typically by a radio planner), submit the site georeferenced, file the application with the BNetzA. Plan 6 to 10 weeks of processing time.

Step 4: build a compliance dossier. File declarations of conformity, assignment notices, and operating manual centrally. Market surveillance does not arrive announced. Anyone who has to search will fail.

Quarero delivers steps 1, 2 and 4 pre-filled with every robot. The dossier contains declarations of conformity, the frequency usage table, and the operating manual. Only the 5G campus network application remains a separate decision by the operator, because it is site-dependent. More on the delivery model under Robotics-as-a-Service model.

Costs and timelines at a glance

The relevant cost items at a glance:

  • General assignment WLAN, SRD, UWB: 0 euros administrative fee, immediate use.
  • 5G campus network 3.7 to 3.8 GHz: from 1,000 euros administrative fee plus an annual usage fee by area and bandwidth.
  • Preparation of frequency utilisation plan by a specialist planner: typically 5,000 to 15,000 euros depending on complexity and site size (market benchmark; obtain quotes).
  • BNetzA processing time: 6 to 10 weeks with complete documentation, longer with queries.
  • Manufacturer's compliance dossier: included in the Quarero scope of delivery, no separate item.

For comparison: personnel costs for conventional guarding are, according to BDSW industry data, 15,000 to 25,000 euros per 24/7 post and month. A one-time investment of 16,000 euros for a frequency utilisation plan and campus network application amortises against a single guard post within one month. Detailed breakdown under TCO comparison guard service.

The radio frequency question is no longer an obstacle in 2026. It is homework with a clear list. Anyone who works through the list operates their robot lawfully. Anyone who ignores it risks fines and, in the worst case, shutdown. KRITIS audit practice is clearly documented under KRITIS requirements in detail.

For a concrete site assessment with frequency survey, application preparation and a pre-filled compliance dossier: Start a pilot request.

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