ChecklistAustraliaSmart Devices

Cyber Security Act 2024 Smart Device Compliance Checklist

Use this checklist to test whether a product is a covered consumer-grade relevant connectable product, verify the three smart-device security-standard controls, prepare the statement of compliance, and retain evidence for the required record period.

This is implementation support for product, security, legal, compliance, and supply-chain teams. It is supporting implementation planning and should be validated against jurisdiction-specific legal, contractual, and policy requirements before implementation.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

The Cyber Security (Security Standards for Smart Devices) Rules 2025 apply the Cyber Security Act 2024 smart-device regime to consumer-grade relevant connectable products acquired in Australia by a consumer, unless an exclusion applies. Part 1 of the Rules commenced on 4 March 2025, and Part 2 and Schedule 1 commence on 4 March 2026. A useful compliance checklist should therefore start with scope, then test passwords, vulnerability-reporting publication, security-update support-period publication, statement contents, retention, and enforcement evidence.

Section 1

1. Confirm the product is in smart-device scope

Start every checklist record with the product facts that decide whether the Security Standards for Smart Devices Rules 2025 apply. The Rules cover relevant connectable products that are intended by the manufacturer for personal, domestic or household use or consumption, or are of a kind likely to be used that way, when the products will be acquired in Australia by a consumer.

Record any exclusion before testing controls. The Rules exclude desktop computers and laptops, tablet computers, smartphones, therapeutic goods, road vehicles, and road vehicle components from the consumer-grade relevant connectable product standard.

  • Record the product type, model, batch or SKU identifier, manufacturer, supplier, Australian acquisition channel, and intended personal, domestic or household use.
  • Confirm that the product can connect directly or indirectly to the internet and therefore may be a relevant connectable product under the Act.
  • Document the consumer-acquisition basis under the Rules rather than assuming that every connected business or industrial device is covered.
  • If relying on an exclusion, keep the exclusion category, supporting product evidence, reviewer, and approval date with the checklist record.
Section 2

2. Check the three mandatory smart-device security controls

For in-scope products, test the product against the three Schedule 1 control areas. The checklist should produce evidence that passwords, security-issue reporting, and security-update support-period publication have been reviewed for the product hardware and relevant software.

The password check should cover passwords used with the product hardware, pre-installed software, and software that must be installed for the manufacturer's intended purposes. Passwords must be unique per product or defined by the user, and unique-per-product passwords must not be based on incremental counters, public information, serial numbers unless protected by accepted encryption or keyed hashing, or otherwise guessable in a way unacceptable as good industry practice.

  • Password evidence: factory-default state description, account and setup flows, password-generation method, uniqueness evidence, and reviewer confirmation that no banned derivation method is used.
  • Security-issue reporting evidence: public point of contact, acknowledgement timing, status-update timing, and proof the information is accessible, clear, transparent, in English, free of charge, available without prior request, and available without requesting personal information.
  • Security-update evidence: the defined support period expressed as a period with an end date, the affected update-capable hardware and software, and the place where the support period is published.
  • Website evidence: when the manufacturer offers the product on a website it controls, retain screenshots or page exports showing the support-period information with acquisition information and with equal prominence where main product characteristics appear.
Section 3

3. Prepare and retain the statement of compliance

The statement of compliance must be prepared by, or on behalf of, the manufacturer. Suppliers should not treat it as a marketing claim; it is the statutory record that accompanies supply and may be examined for compliance.

The statement should be checked against each required field before supply: product type and batch identifier, manufacturer and authorised-representative names and addresses, manufacturer declaration, compliance declaration, defined support period at issue date, signatory signature, signatory name and function, place of issue, and date of issue.

  • Retain the statement of compliance for five years, because the Rules set a five-year retention period for statements under the consumer-grade relevant connectable product standard.
  • Keep the statement with the product-scope assessment, Schedule 1 control evidence, source URLs, reviewer approval, supplier handoff record, and any exception note.
  • When a product or batch changes, re-check whether the existing statement still matches the product type, batch identifier, support period, software state, and manufacturer declaration.
  • If using a statement prepared for another comparable market, verify every field required by the Australian Rules is still present.
Section 4

4. Add enforcement and recall evidence before release

A release-ready checklist should make it easy to respond if the Secretary or Minister uses the Act's compliance, stop, recall, publication, or examination powers. Keep evidence in a form that can show both product compliance and statement-of-compliance accuracy.

For recall readiness, the Rules allow publication of recall-notice details and consumer actions if an entity fails to comply with a recall notice. Product, support, and communications teams should therefore keep a current consumer-action draft for each covered product family.

  • Assign one product owner for technical remediation, one compliance owner for statement records, one security owner for vulnerability-reporting intake, and one communications owner for consumer-facing recall language.
  • Keep an audit packet containing product samples or access instructions, statement copies, support-period publication evidence, vulnerability-reporting page evidence, and password-control test results.
  • Escalate before launch if the product scope is uncertain, the defined support period lacks an end date, security-issue reporting is not publicly accessible, or the statement does not match the current product batch.
  • Review the checklist after firmware changes, companion-app changes, support-period extensions, supplier changes, Australian channel changes, vulnerability-process changes, or regulator notices.
Primary sources

References and citations

legislation.gov.au
Referenced sections
  • Provides compliance notice, stop notice, recall notice, public notification, and examination powers for Part 2 smart-device obligations.
"Examination to assess compliance"
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