For the majority of smartphone's existence no permission was necessary, probably because no one ever considered it. Then it was learned stores, for example Target, were using their mobile app to broadcast Bluetooth signals in order to track shoppers movement around the store. So around 2019 Android added it to the general location permission to use Bluetooth for anything other than audio transmission to/from a paired device if device pairing is handled by the OS, hidden from the app.

In late 2021 Android changed it to a separate "ACCESS_FINE_LOCATION" permission, while Apple still keeps it under the general bluetooth permission (while the popup mentions it can be used to track your location).