Artifact GuideUKETSI Evidence Mapping

UK PSTI ETSI Evidence Mapping

Map and TS 103 701 evidence to the three UK legal requirements without treating the wider voluntary ETSI baseline as if every provision were mandatory under PSTI.

The guide separates binding duties from OPSS guidance, ETSI good practice, internal controls, and the limited deemed-compliance routes introduced in 2025.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Map the UK rule first and ETSI evidence second. Schedule 1 contains the three statutory security requirements. Schedule 2 creates a standards-based deemed-compliance route by referring to V2.1.1 provisions 5.1-1, 5.1-2, 5.2-1, and 5.3-13, subject to its additional conditions. The rest of EN 303 645 remains useful security guidance but is not automatically a PSTI requirement. V1.1.1 supplies assessment methods and evidence fields; it does not certify legal compliance or replace the product-specific statement and supply-chain duties.

Section 2

Use TS 103 701 as an evidence method

TS 103 701 distinguishes conceptual checks from functional checks and uses Implementation eXtra Information for Testing () to describe the implementation under test. A conceptual check reviews the documented design or publication; a functional check examines the device or live resource. Reuse those fields to make evidence reviewable, but keep the legal conclusion in a separate PSTI decision record.

Keep ETSI verdicts at the level they were assigned. TS 103 701 can produce PASS, FAIL, or INCONCLUSIVE results for test cases, test groups, and the overall assessment. A PASS based on external evidence still needs the evidence identity and applicability recorded, and an INCONCLUSIVE result cannot support a legal "met" conclusion without resolving the missing evidence.

  • Product scope: model, batch, hardware, software, configuration, network path, intended purpose, UK supply facts, and role.
  • 1 authentication: password mechanism, generation or user-definition path, and relevant security parameters.
  • 2 user information: public vulnerability policy, support period, publication paths, and model designation.
  • 3 to 5: vulnerability types, response actions, monitoring, owners, and confirmations where the wider process is assessed.
  • Test record: test objective, environment, release, inputs, expected result, actual result, evidence file, assessor, date, exception, and retest.
  • Traceability: legal paragraph, ETSI provision, TS 103 701 test group and case, product evidence, ETSI verdict, legal conclusion, owner, limitation, and approval.
Section 3

Do not overstate what the mapping proves

A passed ETSI assessment does not by itself decide whether the product is in scope, whether it will be supplied to UK consumers, who is the manufacturer, whether the statement accompanies the product, or whether importer and distributor duties are met. Those are separate legal and supply-chain records.

Version control matters. The 2023 Regulations specify EN 303 645 V2.1.1 dated 19 June 2020 for the relevant deemed-compliance references. Evidence against V3.1.3 or another edition may still be useful engineering evidence, but it does not silently replace the specified edition. The mapping must identify the tested edition and show how the evidence satisfies the current legal condition.

  • Do not mark every EN 303 645 provision mandatory under PSTI.
  • Do not treat TS 103 701 as a certification scheme or an OPSS approval.
  • Do not reuse evidence across variants unless the mapping proves the relevant implementation is identical.
  • Do not convert an ETSI recommendation using "should" into a UK legal "must."
  • Reassess after password provisioning, firmware, public policy, support period, branding, manufacturer, supplier, or market-route changes.
Section 4

Approval output

Approve a mapping only when each legal row has a product-specific conclusion, current evidence, an owner, and a stated limitation. The final record should let a reviewer move from the UK rule to the relevant ETSI provision, assessment step, and evidence without assuming that the standard decides the law.

  • Result per row: met, not met, deemed met under a stated condition, not applicable with rationale, or unresolved.
  • Record gaps and compensating evidence without changing the wording or force of the legal requirement.
  • Link the approved mapping to the exact product release and statement of compliance.
  • Set review triggers for product, evidence, standard, scheme, and regulatory changes.
Primary sources

References and citations

etsi.org2 citations
Referenced sections
  • Specified baseline standard containing the aligned provisions.
  • Specified standard containing the aligned password, vulnerability-disclosure, and support-period provisions.
etsi.org2 citations
Referenced sections
  • Assessment specification and IXIT evidence model.
  • Assessment methods, conceptual and functional test groups, and IXIT evidence fields.
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