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Artifact GuideUKChecklist

UK PSTI Product Security Checklist

Use a release checklist with scope, role, security-control, statement, records, and compliance-failure evidence for UK consumer connectable products.

Binding duties come from Part 1 of the 2022 Act and the current 2023 Regulations. Office for Product Safety and Standards (OPSS) guidance explains administration and enforcement; European Telecommunications Standards Institute (ETSI) materials are standards evidence, not a substitute for applying the UK rules.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections5 primary sources
Overview

Use this checklist before a is first made available in the United Kingdom and repeat it after material product or supply-chain changes. The regime has applied since 29 April 2024. A checked box should point to evidence for the exact model and release; policy text without implementation evidence is not enough.

Section 1

1. Scope and role gate

Stop here if the product has not been classified. The checklist applies after the team has tested sections 4 to 6, current Schedule 3 exceptions, section 54 UK-consumer status, and the relevant manufacturer, importer, or distributor conditions.

  • Product owner: record model, hardware, firmware, associated software, intended purpose, connectivity, and direct connections.
  • Regulatory owner: record the exact exception considered and why every condition is or is not met.
  • Commercial owner: record UK consumer and non-consumer channels, identical product lines, earlier supplies, returns, reconditioning, installation contracts, and the first UK supply facts.
  • Legal-entity owner: assign manufacturer, importer, distributor, and authorised-representative roles for this route.
Section 2

2. Manufacturer security-requirement gate

Schedule 1 contains three requirements for manufacturers. Importers and distributors do not become responsible for those technical controls merely because they handle the product, but their direct statement and known-failure duties still require reliable manufacturer evidence. Test each requirement's detailed scope, keep deemed-compliance analysis separate, and use only a route whose stated conditions are fully met.

  • Engineering: show that each in-scope password is user-defined or unique per product and that a unique password is not based on counters, public information, an unprotected product identifier, or another easily guessable method.
  • Security response: publish a report channel, when the reporter will receive acknowledgement, and when the reporter can expect status updates until resolution.
  • Product support: publish the defined support period with an end date, without prior request, in English, free of charge, without requiring personal information, and in language understandable without technical knowledge.
  • E-commerce: where the manufacturer controls a qualifying online invitation to purchase, give the support-period information the required prominence.
Section 3

3. Statement and supply-chain gate

Under the ordinary route, the statement of compliance must accompany the product and contain the information required by Schedule 4. Section 9 allows a summary only if regulations prescribe its form and content; the current Regulations do not provide a general informal short form. The Act does not require paper, but each actor must show that its chosen digital or physical method accompanies the product. Since 4 December 2025, Schedule 2A has provided limited alternative conditions.

  • Manufacturer: approve the statement or document every condition of the Schedule 2A route used.
  • Importer and distributor: verify the statement, summary, or applicable Schedule 2A evidence before making the product available.
  • Records owner: retain each manufacturer and importer statement copy for the longer of 10 years from issue or the product's defined support period; preserve distributor pre-supply evidence without mislabeling it as the regulation 9 retention duty.
  • Release owner: block supply if the required statement route or security evidence is missing.
Section 4

4. Post-release and failure-response gate

Manufacturers and importers must investigate potential compliance failures in the circumstances set out in the Act. Manufacturers, importers, distributors, and authorised representatives have role-specific duties to contact other actors, remedy failures, prevent further supply, keep records, and notify OPSS or others when the statutory conditions apply. Retain manufacturer investigation and compliance-failure records, and importer investigation records, for 10 years from the day each record is made.

  • Security owner: log reports, investigation scope, outcome, affected versions, risk, remedy, and whether the remedy succeeded.
  • Supply-chain owner: identify affected stock and decide whether the Act requires a stop-supply step or contact with upstream and downstream actors.
  • Regulatory owner: prepare notifications with the failure, known risks, remedial steps, and outcome information required by the applicable section.
  • Response owner: preserve evidence for OPSS information requests, notices, representations, appeals, and corrective action.
Recommended next step

Apply this guide to a product assessment

Use the page for one product model, UK route, and legal entity, with named owners, evidence requests, and review points.

Assessment workflow
Open Assessment Autopilot for UK PSTI Product Security

Create scoped questions, evidence fields, and review tasks from this guide.

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Research workflow
Review UK PSTI Product Security source evidence

Use Research Copilot to answer follow-up questions with cited source material.

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Talk to Sorena
Talk through implementation

Review scope, evidence, owners, and the next compliance actions with Sorena.

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Primary sources

References and citations

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