Artifact GuideUKPSTI Statement Of Compliance Template

UK PSTI Statement of Compliance Template

Build a statement record with the prescribed Schedule 4 information and evidence that it accompanied the product, while checking whether a current deemed-compliance route applies.

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

Use this template only after confirming that the ordinary section 9 statement route under the Product Security and Telecommunications Infrastructure (PSTI) Act 2022 applies. Schedule 4 prescribes the information, but it does not prescribe an official form. The manufacturer prepares and signs the statement; the importer checks and retains it; the distributor checks it before making the product available. A valid, unexpired Japan JC-STAR STAR-1 or Singapore Cybersecurity Labelling Scheme label can satisfy the separate accompaniment route from 4 December 2025, so record that route instead of creating a misleading ordinary statement.

Section 1

Required Schedule 4 fields

A is the manufacturer's declaration, not an OPSS approval or third-party certificate. Schedule 4 sets minimum information but no official layout, certificate number, or OPSS filing step. Complete every applicable field against the product as first supplied. If several manufacturers meet the Act's definition, list each manufacturer and resolve who signs the statement on behalf of the relevant manufacturer.

Use the type and batch fields as the product-to-statement key. A trade name alone is weak where hardware, firmware, region, or production batches differ. The compliance-basis field records the manufacturer's opinion and the applicable Schedule 1 or Schedule 2 route; it does not turn voluntary testing into regulatory approval.

  • Product: state the product type and batch so the statement can be matched to the supplied unit or production group; add model, hardware, and release identifiers when needed to remove ambiguity.
  • Responsible entities: give the name and address of each manufacturer and, where applicable, each authorised representative.
  • Authority: declare that the statement was prepared by or on behalf of the manufacturer.
  • Compliance basis: declare that, in the manufacturer's opinion, it complied with the applicable Schedule 1 security requirements or the Schedule 2 deemed-compliance conditions.
  • Standard details: when Schedule 2 reliance refers to a specified standard, include the identification number, version, and issue date where applicable.
  • Support: state the defined support period that was correct when the manufacturer first supplied the product. This is the minimum security-update period expressed as a duration with an end date, not a warranty or expected product lifetime.
  • Execution: include the signatory's signature, name and function, plus the place and date of issue.
Section 2

Evidence kept behind the statement

Schedule 4 does not require the statement to reproduce the full technical file. Keep a controlled evidence index behind it so each declaration can be checked against the released product. Separate legal statement fields from engineering evidence and from optional ETSI assessment material. The index should show the evidence owner, version, location, review date, result, limitation, and exact product mapping.

  • Scope record: connectivity diagram, intended purpose, UK consumer facts, exception check, role classification, product type, batch, and release identifiers.
  • Password evidence: provisioning design, uniqueness or user-definition method, guessability review, and tests for the shipped configuration.
  • Vulnerability-reporting evidence: public reporting route, English and free-access checks, acknowledgement timing, status-update timing, and archived publication.
  • Support-period evidence: approved duration, end date, covered software and variants, publication URL, accessibility check, and dated capture.
  • Approval evidence: signatory authority, legal and security review, issue date, version history, distribution or digital-accompaniment method, and importer receipt.
  • Retention deadline: manufacturer and importer keep the statement for the longer of 10 years from issue or the defined support period stated in it.
Section 3

Release, accompaniment, and change control

Approve the statement before the relevant product is made available. The Act allows a statement or a summary in a form later specified by regulations; do not invent a summary route without checking that the required form has been specified. GOV.UK says the statement can be digital because the Act does not require a physical document, but the chosen method still must amount to accompaniment.

A later product or evidence change does not automatically rewrite a statement that correctly described the product when issued. Reassess whether a new product type, batch, manufacturer, compliance basis, support-period statement, or scheme-label status requires a new issue or a route change, and stop supply if a role-specific compliance-failure duty is triggered.

For a route, verify the exact labelled product against the version of the scheme named in the Regulations: Japan JC-STAR STAR-1 based on JST-CR-01-01-2024R1 (December 2024), or the Singapore Cybersecurity Labelling Scheme specified through CCC SP-151-2 CLS(IoT) Scheme Specifications (version 1.4, April 2025). Preserve the current label and expiry evidence; a supplier certificate for another product does not establish the condition.

  • Test the physical or digital delivery path from the customer's product to the exact statement; a general corporate compliance page is not enough unless it reliably accompanies and identifies the product.
  • Give importers the statement and product mapping early enough to complete their pre-supply check and retention setup.
  • Give distributors a check that identifies the expected statement or the exact label route before supply.
  • Archive the issued file, hash or version, delivery-path evidence, publication capture, recipients, and withdrawal or supersession decision.
Primary sources

References and citations

gov.uk2 citations
Referenced sections
  • Official guidance on economic-operator duties and physical or digital accompaniment.
  • Official guidance that a statement may be digital, but the business must determine and evidence how it accompanies the product.
legislation.gov.uk2 citations
Referenced sections
  • Schedule 2A alternatives to the ordinary accompaniment route.
  • Binding source for the Schedule 2A label-based accompaniment routes effective from 4 December 2025.
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