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Across 8 modules • Updated Jul 25, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

What counts as test evidence for ETSI EN 303 645?

EN 303 645 is the baseline requirements standard. Annex B classifies provisions as mandatory, recommended, conditional, and feature-dependent and lets the user record Y, N, or N/A. The detail field records implemented measures, reasons for non-support, or the rationale for N/A. Provision 5.0-1 separately requires a justification for each recommendation considered not applicable or not fulfilled.

TS 103 701 is the compatible assessment methodology. It defines the Device Under Test (DUT), Supplier Organization, Test Laboratory, ICS, IXIT, conceptual and functional tests, external evidence, and verdict rules. An evidence pack should therefore identify the DUT and software version, associated services and processes in scope, each ICS claim, supporting IXIT detail, applied test group or accepted external evidence, indications, and verdict.

  • Keep the EN 303 645 provision mapping separate from TS 103 701 assessment records.
  • For each supported provision, retain the ICS support claim and the IXIT information needed to prepare and perform assessment activities.
  • Tie each test result to the specific DUT, software version, associated services, user documentation, and development or management process in scope.
  • Reassess affected claims when the hardware, software, configuration, interface, associated service, supplier process, cited standard edition, or relied-on external evidence changes.
Citations
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

How should ICS and IXIT evidence be prepared?

The Supplier Organization completes DUT identification and the ICS, then supplies the necessary IXIT information for provisions claimed Y. The Test Laboratory checks the IXIT for completeness, consistency, and soundness with the supplier. It also verifies that no mandatory provision is claimed N and tests whether N/A claims match the provision's stated condition or feature.

The IXIT must be specific enough to select test methods, equipment, conditions, and instructions. A referenced document has to be supplied to the laboratory. Missing or insufficient information can produce INCONCLUSIVE at test-case level because the test cannot be properly executed; it should not be recorded as PASS merely because no failure was observed.

  • Record Y, N, or N/A in the ICS, using N/A only where the relevant condition is unsatisfied or the feature, capability, or mechanism does not exist.
  • Do not claim a mandatory provision N: TS 103 701 requires the laboratory to reject that ICS during verification.
  • Complete the required IXIT entries for provisions claimed Y, and make each entry exhaustive, correct, and distinctly referenced.
  • Where the IXIT references existing documentation, provide that documentation to the test laboratory instead of relying on an unsupported assertion.
Citations
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

Can existing certificates or third-party reports replace testing?

Sometimes, but only for the test group covered by the TS 103 701 external-evidence rules. Existing security certifications or third-party evaluations of parts of the DUT can reduce assessment effort. The Supplier Organization must identify the evidence in the relevant ICS detail field and provide the certificate, scope, test reports, and other information needed for verification.

The Test Laboratory decides whether the evidence is adequate for that test group. It checks whether the scope matches the objective, the prior test activities satisfy every test purpose, and the test depth or evaluation assurance level fits the baseline assessment. Evidence accepted for one component or test group does not establish an overall verdict for the whole DUT.

Verdicts roll up in a fixed order. A test group passes when every test case passes or accepted external evidence satisfies clause 4.7. Any failed test case fails its test group. The overall result passes only if the ICS is valid and every test group for a provision claimed Y passes; one failed applicable group produces FAIL, while an inconclusive applicable group produces INCONCLUSIVE when no fail criterion applies.

  • Do not reuse a certificate or report unless its scope covers the same DUT part, feature, software, service, or process needed by the test group.
  • Keep the external evidence reference in the ICS detail field together with the supporting report or certification details.
  • Treat external evidence as a TS 103 701 assessment input, not as a blanket EN 303 645 conformance claim for the whole product.
Citations
ETSI EN 303 645 vulnerability disclosure requirements for consumer IoT

What must the public vulnerability disclosure policy include?

A security mailbox alone is not enough. Provision 5.2-1 says the manufacturer shall make the policy publicly available and include contact information for reporting issues, a timeline for initial acknowledgement of receipt, and timelines for status updates to the reporter until resolution.

For visitors, buyers, researchers, and assessors, the policy should make the reporting path visible without requiring private documentation. TS 103 701 turns that into both a conceptual and functional assessment: the test laboratory checks the publication route described in IXIT 2-UserInfo and verifies that the policy is publicly accessible.

  • Publish a clear external location for the vulnerability disclosure policy, such as a security page or support path that remains reachable without authentication.
  • Include contact information that lets security researchers and other reporters submit potential vulnerabilities.
  • State an acknowledgement timeline and status-update timelines. ETSI allows different ways to express time values, but the policy still has to tell reporters what to expect.
  • Keep product documentation, app help, or support pages aligned with the public policy location if those channels direct users to report security issues.
Citations
ETSI EN 303 645 V3.1.3, clause 5.2

Primary ETSI requirement for publishing a vulnerability disclosure policy with reporting contact information and acknowledgement/status-update timelines.

ETSI EN 303 645 vulnerability disclosure requirements for consumer IoT

How should reported vulnerabilities be handled after disclosure?

Provision 5.2-2 recommends timely action. Its explanatory text says timing varies by incident and describes 90 days as a conventional completion point for a properly documented software vulnerability-management process, including patch availability and notification. It is not a mandatory universal remediation deadline, and hardware fixes or device rollouts can take longer.

Evidence should therefore define the action and time frame for each vulnerability type in IXIT 3-VulnTypes. TS 103 701 asks the laboratory to consider the public policy, severity and criticality, whether the issue affects firmware, hardware, or software, process steps and responsibilities, deployment route, and third-party involvement.

  • Define how reports are triaged, investigated, confirmed, fixed, mitigated, or escalated for the product and its associated services.
  • Separate timelines where firmware, cloud service, mobile app, hardware, operating system, or third-party library vulnerabilities follow different paths.
  • Document who owns each step, including security incident teams, software teams, supplier contacts, and external vendors where relevant.
  • Avoid claiming a fixed universal remediation deadline unless the evidence supports that timeline for the vulnerability type and deployment route.
  • Retain the report, acknowledgement, reporter updates, severity and applicability decision, affected versions, supplier handoffs, remediation or mitigation decision, release evidence, and closure record.
Citations
ETSI EN 303 645 vulnerability disclosure requirements for consumer IoT

What evidence supports vulnerability monitoring and rectification?

Provision 5.2-3 recommends that manufacturers continually monitor for, identify, and rectify vulnerabilities in consumer IoT products they sell, produce, or have produced and in associated services they operate during the defined support period. The recommendation is bounded by that period unless the manufacturer makes a longer commitment.

TS 103 701 maps this to IXIT 5-VulnMon. The assessment asks whether the described monitoring approach systematically gathers vulnerability information that could affect the device under test or its associated services, whether the identification approach determines applicability, and whether the rectification approach addresses or mitigates susceptibility.

  • Maintain a list of software components and sub-components, or an SBOM that supplies that view, so third-party and open-source vulnerabilities can be matched to the product.
  • Record vulnerability sources monitored, the review cadence, how potential matches are assessed for applicability, and how non-applicable findings are documented.
  • Tie monitoring output back into the same vulnerability handling process used for externally reported issues.
  • Keep the evidence bounded to the defined support period unless the manufacturer actually continues monitoring and security updates beyond that period.
  • Reassess the policy and IXIT records when the reporting contact, acknowledgement or update timeline, product scope, component inventory, associated service, supplier route, remediation process, public URL, or defined support period changes.
Citations
ETSI EN 303 645 V3.1.3, provision 5.2-3

Primary ETSI source for continuous monitoring, identification, and rectification during the defined support period and component-list prerequisites for vulnerability monitoring.

How should teams handle constrained devices under ETSI EN 303 645 for consumer IoT products?

How should teams handle constrained devices under ETSI EN 303 645 for consumer IoT products?

Start with the edition. EN 303 645 V2.1.1 defined a constrained device through physical limits in processing, communication, storage, or user interaction. EN 303 645 V3.1.3 no longer defines or uses that category as a general applicability shortcut.

The current edition still recognizes resource limits where a provision says they matter. For example, provision 5.1-5 requires protection that makes successful brute-force attacks through network interfaces impracticable unless a resource constraint determined by the use case prevents implementation. Update provisions 5.3-14, 5.3-15A, and 5.3-15B apply to devices that cannot have their software updated, whether or not a team calls them constrained.

  • Name the exact resource constraint, the use case that creates it, and the provision it affects.
  • Separate an absent feature, an unsatisfied condition, a recommendation not fulfilled, and an implemented control; they lead to different ICS entries.
  • Do not carry a V2.1.1 constrained-device rationale into a V3.1.3 assessment without rechecking the current provision and ICS status.
  • Reassess the decision when the use case, hardware resources, firmware architecture, update path, connected hub or service, or cited ETSI edition changes.
Citations
How should teams handle constrained devices under ETSI EN 303 645 for consumer IoT products?

When can constrained-device status change an ETSI EN 303 645 answer?

A resource constraint changes an answer only where the current provision or ICS condition makes that fact relevant. Provision 5.0-1 separately requires a justification for each recommendation considered not applicable or not fulfilled; it does not authorize a blanket exception from mandatory requirements.

For updates, distinguish three questions. Provision 5.3-2 requires a secure update mechanism unless a resource constraint determined by the use case prevents implementation. Provision 5.3-13 requires every manufacturer to publish the defined security-update support period. If a device cannot have its software updated, provision 5.3-14 recommends publishing the reason and hardware-replacement support period and method, while 5.3-15A and 5.3-15B recommend that the device be isolable and its hardware replaceable.

  • Do not mark a provision N/A merely because the product is small, battery-powered, low-cost, or built on a limited chipset.
  • For authentication, document the use-case resource constraint only if it prevents the provision 5.1-5 brute-force control; the other applicable password and authentication requirements remain.
  • For updates, separate an implemented update mechanism, an individual non-updateable component, and a device that cannot have any software updated.
Citations
How should teams handle constrained devices under ETSI EN 303 645 for consumer IoT products?

What evidence should teams keep for constrained devices?

Keep the evidence close to the ICS and IXIT process used by ETSI TS 103 701. The supplier organization identifies the Device Under Test, completes the ICS, provides necessary IXIT information for provisions claimed as supported, and gives enough information for the test laboratory to check consistency and soundness.

For each resource-constraint or non-updateable-device decision, the evidence should answer four questions: what product fact changes the provision, which ICS condition or feature applies, what support value and detail are recorded, and what public disclosure or replacement procedure is required.

Use a provision-by-provision sequence: test the condition or feature first; record Y, N, or N/A with its rationale; provide the required IXIT detail for claims of support; then check whether a public support-period, no-update rationale, replacement method, isolation procedure, or hardware-replacement procedure is also expected.

  • Document the DUT, model designation, software version assessed, interfaces, associated-service dependencies, and the use-case resource constraint being relied on.
  • Use the ICS detail field to explain implemented measures, reasons implementation is not possible or appropriate, or the rationale for a true N/A determination.
  • When the device cannot have software updated, retain the published rationale, defined support period, hardware-replacement support period and method, and the isolation and replacement procedures.
Citations
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