Evidence WorkflowAustraliaSmart devices

Statement of compliance evidence workflow

Use this workflow when a relevant connectable product may be supplied in Australia and the team needs a source-linked statement of compliance record.

The workflow follows the Cyber Security Act 2024 and Cyber Security (Security Standards for Smart Devices) Rules 2025 for scope, required statement fields, security-standard evidence, and five-year retention.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

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 to provide a statement of compliance for covered relevant connectable products, and requires suppliers to supply the product in Australia with that statement when the statutory conditions are met. The Smart Devices Rules make the workflow practical by defining the covered consumer-grade product class, the required statement fields, the security-standard evidence areas, and the five-year retention period.

Section 1

Step 1: confirm the product is in the smart-device statement workflow

Start with a product-scope record, not a generic compliance task. Record whether the product is internet-connectable or network-connectable, whether it will be acquired in Australia by a consumer, and whether the manufacturer is aware or could reasonably be expected to be aware of that Australian acquisition circumstance.

For the Smart Devices Rules, the covered class is consumer-grade relevant connectable products intended, or likely, for personal, domestic, or household use or consumption. Do not put excluded products into the statement workflow without a separate legal review.

  • Product owner records the product type, batch or release identifier, intended use, connectivity model, and Australian supply channel.
  • Legal or regulatory counsel checks whether the Rules' excluded categories apply: desktop or laptop computers, tablet computers, smartphones, therapeutic goods, road vehicles, or road vehicle components.
  • Supply-chain or commercial owner records whether the product will be supplied in Australia and whether the supplier has the manufacturer statement before supply.
  • If the product is out of scope, preserve the scope analysis separately; do not issue a statement of compliance for a product that the evidence record has not classified.
Section 2

Step 2: collect evidence for the security standard before signing

The statement should not be signed until the manufacturer has evidence for the security standard in Schedule 1 of the Smart Devices Rules. Keep the evidence tied to the product type and batch identifier that will appear in the statement.

The evidence pack should show that passwords, security-issue reporting information, and security-update support information were checked for the product and supporting software covered by the manufacturer's intended purpose.

  • Security engineering records whether product passwords are user-defined or unique per product, and if unique per product, why they are not based on incremental counters, public information, or guessable derivations.
  • Vulnerability management records the published security-issue reporting point of contact and the promised acknowledgement and status-update process.
  • Product management records the defined support period for security updates as a period of time with an end date, plus the public location where consumers can see it.
  • Web or ecommerce owner records that required support-period information is published with consumer product information when the manufacturer offers supply through a website under its control.
Section 3

Step 3: prepare the statement with the required fields

The statement of compliance must be prepared by, or on behalf of, the manufacturer. Treat the statement as a controlled release artifact: every required field should be present, traceable to evidence, and approved before the supplier uses it for Australian supply.

The workflow should block release when the product type, batch identifier, manufacturer details, authorised representative details, declarations, support period, signatory information, place of issue, or date of issue is missing.

  • Required identification fields: product type and batch identifier.
  • Required party fields: manufacturer name and address, one authorised representative, and each other authorised representative in Australia if any exist.
  • Required declarations: prepared by or on behalf of the manufacturer; in the manufacturer's opinion the product was manufactured in compliance with the security standard; and the manufacturer complied with other obligations in the security standard.
  • Required support and execution fields: defined support period at the date of issue; signature, name, and function of the manufacturer's signatory; place and date of issue.
Section 4

Step 4: assign role handoffs and retain the evidence for five years

The manufacturer record and supplier record are related but not identical. The manufacturer must provide the statement for supply of the product in Australia and retain a copy for the period specified in the Rules. The supplier must supply the product in Australia with the statement and retain a copy for the same specified period.

For consumer-grade relevant connectable products covered by the Smart Devices Rules, that retention period is five years. The retained record should include the final statement, approval trail, scope analysis, security-standard evidence, public support-period screenshots or page captures, and supplier handoff confirmation.

  • Manufacturer accountable owner: product compliance or regulatory owner who controls statement preparation and signatory approval.
  • Security accountable owner: engineering or product security owner who approves password, vulnerability-reporting, and security-update evidence.
  • Supplier accountable owner: channel, distribution, or commercial owner who confirms the statement accompanies Australian supply.
  • Records owner: compliance operations or legal operations owner who preserves the statement and evidence pack for five years and can retrieve them if requested for examination.
Section 5

Step 5: keep the pack ready for regulator examination

The Cyber Security Act allows an independent examination to assess whether a product complies with the security standard and whether the statement of compliance complies with section 16. The evidence workflow should therefore keep product, statement, and security-standard records aligned by product and batch.

When product design, firmware, bundled software, authorised representatives, security-update support period, or Australian supply channel changes, reopen the workflow and decide whether a new or updated statement and evidence pack is needed before further Australian supply.

  • Index records by product type, batch identifier, manufacturer, supplier, issue date, defined support period, and evidence owner.
  • Preserve the final signed statement separately from draft working papers so the supplied statement is easy to retrieve.
  • Keep test evidence and public disclosure evidence alongside the statement so the product and statement can be reviewed together.
  • Escalate missing statement fields, unsupported security-standard declarations, shortened support-period language, or supplier use of a stale statement.
Primary sources

References and citations

legislation.gov.au
Referenced sections
  • Supports readiness for examination of both product compliance and statement compliance.
"whether the statement of compliance"
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