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Does the use of STATISTICS_LEVEL = ALL require diagnostic or tuning pack license?

We have some databases with 12C Enterprise Edition about to upgrade to 19C and are reviewing parameters. In Non-prod we DO NOT have DIAGNOSTIC and TUNING pack license and have set control_management_pack_access =NONE.

It has been suggested we should set STATISTICS_LEVEL = ALL (as it is in Production) but I cannot do this if this would require DIAG or DIAG and TUNING pack license.

Can you advise?

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