As the measuring head of a fetal pulse oximeter must be attached to the head of the fetus inside the mother’s uterus during labor, testing, and developing of fetal pulse oximeters in real environment have several difficulties. A fetal phantom could enable evaluation of pulse oximeters in a simulated environment without the restrictions and difficultness of medical experiments in the labor room. Based on anatomic data we developed an adjustable fetal head phantom with three different tissue layers and artificial arteries. The phantom consisted of two arteries with an inner diameter of 0.2 and 0.4 mm. An electronically controlled pump produced pulse waves in the arteries. With the phantom we investigated the sensitivity of a custom-designed wireless pulse oximeter at different pulsation intensity and artery diameters. The results showed that the oximeter was capable of identifying 4% and 2% changes in diameter between the diastolic and systolic point in arteries of over 0.2 and 0.4 mm inner diameter, respectively. As the structure of the phantom is based on reported anatomic values, the results predict that the investigated custom-designed wireless pulse oximeter has sufficient sensitivity to detect the pulse waves and to calculate the R rate on the fetal head.