Evidence GuideAustraliaSmart-device statements

Australia Cyber Security Act Statement of Compliance Evidence

For consumer-grade relevant connectable products, the evidence record should prove that the right product is in scope, the manufacturer prepared the statement, the required statement fields are complete, and the manufacturer or supplier can retain and produce the statement.

Use this page to structure records for product launches, imports, supplier onboarding, retailer checks, and regulator examination readiness. This guidance is practical, source-linked, and should be validated against current legal 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

Australia's Cyber Security Act 2024 requires manufacturers and suppliers to handle statements of compliance for relevant connectable products when the product is in a regulated class and is expected to be acquired in Australia in the specified circumstances. The Smart Devices Rules set the statement fields and make the retention period five years for consumer-grade relevant connectable products.

Section 1

What statement-of-compliance evidence is in scope?

Keep this evidence file focused on Part 2 smart-device duties, not ransomware reporting, critical-infrastructure obligations, privacy breach records, or general cyber controls. The trigger is a relevant connectable product that falls within the consumer-grade class covered by the Smart Devices Rules and will be acquired in Australia by a consumer.

The minimum evidence set should tie one product type and batch identifier to the manufacturer, any authorised representatives, the applicable security standard, the manufacturer's compliance opinion, the defined support period at issue, and the signed place and date of issue.

  • Record the product type, batch identifier, model or SKU, intended consumer use, and any scope exclusion considered.
  • Identify whether the business is acting as manufacturer, supplier, importer, distributor, retailer, or marketplace for the Australian supply.
  • Keep the statement prepared by or on behalf of the manufacturer with the product launch or supplier onboarding record.
  • Store the statement beside the password, vulnerability-reporting, and defined-support-period evidence used to support the manufacturer's declaration.
Section 2

Which statement fields should the evidence pack prove?

The Smart Devices Rules specify the content of the statement of compliance. A useful evidence pack should therefore be field-by-field, rather than a generic compliance memo.

For each statement, capture the source record that proves the field value, the person who approved it, and the version of product or support-period information used when the statement was issued.

  • Product identifiers: product type, batch identifier, model references, and the internal release or purchase-order record that links them.
  • Entity details: manufacturer name and address, authorised representative details, and each Australian authorised representative if any exists.
  • Declarations: confirmation that the statement was prepared by or on behalf of the manufacturer and records supporting the manufacturer's compliance opinion.
  • Support-period field: the defined support period for security updates at the date of issue, with evidence that the period was published and not shortened.
  • Execution fields: signature, signatory name and function, place of issue, date of issue, and approval workflow record.
Section 3

What technical evidence should support the manufacturer's declaration?

The statement says whether, in the manufacturer's opinion, the product was manufactured in compliance with the security standard and whether the manufacturer met the other obligations in that standard. That opinion should be backed by technical records for the three security-standard areas in Schedule 1.

The technical file does not need to be public, but it should be understandable to product security, legal, compliance, and supplier-management reviewers who may need to explain why the statement was accepted.

  • Password evidence: configuration records showing passwords are user-defined or unique per product and not guessable from public or product-identifier data.
  • Security-issue reporting evidence: the published reporting contact, acknowledgement and status-update process, language, access, fee, and personal-information checks.
  • Security-update evidence: the defined support period expressed with an end date, publication proof, and controls preventing unsupported shortening.
  • Release evidence: product firmware, companion app, software dependency, test, and approval records aligned to the batch or version named in the statement.
  • Exception evidence: a documented reason when a device, component, or software item is outside the covered consumer-grade smart-device class.
Section 4

How long should manufacturers and suppliers retain records, and how should they prepare for examination?

For consumer-grade relevant connectable products covered by the Smart Devices Rules, the statement-of-compliance retention period is five years. The Act applies retention duties to both the manufacturer that provides the statement and the supplier that supplies the product with it.

Examination readiness matters because the Secretary may arrange an independent examination of the product, the statement, or both. Evidence should be retrievable by product and batch so the business can respond without rebuilding the file after a request arrives.

  • Manufacturer record: final statement, source technical file, signatory authority, defined-support-period evidence, issue date, and any authorised-representative details.
  • Supplier record: copy of the statement received, product and batch mapping, Australian supply channel, supplier acceptance check, and retention owner.
  • Retailer or distributor record: supplier communication, system field showing statement availability, and escalation route when a statement is missing or incomplete.
  • Five-year clock: retain the statement for the period specified in the Rules and avoid deleting supplier/manufacturer copies during product, vendor, or system migrations.
  • Examination pack: product sample or location, statement copy, manufacturer identity, tested security-standard requirements, and contact for notices or regulator requests.
Primary sources

References and citations

legislation.gov.au
Referenced sections
  • Supports manufacturer and supplier retention duties and the Secretary's power to request a product, statement, or both for examination.
"provide the product, or the statement"
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