Artifact GuideUK and AustraliaPSTI vs Australia

UK PSTI vs Australia Smart Device Rules

The two regimes use a similar three-control baseline, but their scope tests, responsible actors, statement rules, publication details, retention periods, and enforcement systems are not identical.

A shared statement and technical evidence can be reused only when it contains every field and supports every duty required in both jurisdictions.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Use this comparison for consumer smart devices supplied under the UK's Product Security and Telecommunications Infrastructure (PSTI) Act 2022 and Australia's Cyber Security Act 2024. Australia's rules call the prescribed class . Assess each market separately, then reuse password, vulnerability-reporting, security-update, and product-identification evidence where the product version and legal requirement align.

Side-by-side comparison

UK PSTI vs Australia's smart-device regime

Compare the binding product-security parts of each framework. Other parts of Australia's Cyber Security Act have different triggers.

Review all sources
First framework
UK PSTI

UK security and statement duties for relevant connectable products made available to consumers.

Second framework
Australia

Part 2 of the Cyber Security Act 2024 and the 2025 Rules for .

Scope test

UK PSTI

Relevant internet-connectable or network-connectable products made available to UK consumers, subject to the Act, Regulations, exceptions, and the actor's intention or awareness.

Australia

Relevant connectable products intended or likely to be used for personal, domestic, or household consumption and acquired in Australia by a consumer under the Rules' Australian Consumer Law test.

Operational implication

Do not use a consumer-product conclusion from one jurisdiction as the conclusion for the other.

Responsible actors

UK PSTI

Manufacturers, importers, and distributors have distinct duties. An authorised representative may perform specified manufacturer functions but does not erase the manufacturer's obligations.

Australia

Manufacturers must manufacture to the standard and meet its other obligations. Suppliers must not supply a product they know or could reasonably be expected to know is non-compliant and must meet statement duties.

Operational implication

Map the actual manufacturer and each supply-chain role; the labels and duties are not identical across the two Acts.

Security baseline

UK PSTI

Passwords must meet the Schedule 1 conditions; manufacturers publish a security-issue reporting route and response-time information; manufacturers publish the minimum security-update period.

Australia

Passwords must be user-defined or unique per product and not guessable by prohibited methods; manufacturers publish a reporting contact and acknowledgement and status-update timing information; manufacturers publish and honour a defined support end date subject to the Rules.

Operational implication

Build to the stricter applicable detail, then keep clause-level evidence showing how each product version meets both texts.

Statement and retention

UK PSTI

Under the ordinary route the statement accompanies the product, and manufacturers and importers keep it for the longer of 10 years from issue or the defined support period. Schedule 2A deems the manufacturer's statement-accompaniment duty satisfied for the exact product with a current, unexpired Japan JC-STAR STAR-1 label or a label at any level of the Singapore Cybersecurity Labelling Scheme. It does not create the same exception for importer duties.

Australia

The manufacturer prepares the statement and suppliers supply the product accompanied by it. Manufacturers and suppliers keep it for five years; the Rules specify Australian content fields.

Operational implication

A single document is possible, but only after a field-by-field and supply-path check for both regimes.

Enforcement

UK PSTI

OPSS can investigate and use compliance, stop, recall, forfeiture, monetary-penalty, and related statutory powers.

Australia

The Australian Secretary can use compliance, stop, and recall notices; the Minister can publish failures to comply with recall notices. The Act also provides examinations and internal review mechanisms.

Operational implication

Keep regulator-ready product, statement, test, publication, supply, and corrective-action records for each jurisdiction.

Dates and reassessment

UK PSTI

The UK security, statement, and supply-chain duties have applied since 29 April 2024. Reassess when the product, actor, consumer-market facts, security controls, support period, or deemed-compliance basis changes.

Australia

The Australian smart-device standard commenced on 4 March 2026. Reassess when the product class, acquisition circumstances, manufacturer or supplier awareness, statement fields, published support period, or product version changes.

Operational implication

Use release and market-entry gates, not a one-time global approval. Record the date, facts, owner, and evidence for each reassessment.

Practical decision rule

How should a dual-market team proceed?

  • Write separate UK and Australian scope findings, including each jurisdiction's excluded-product analysis.
  • Use one technical control set for passwords, vulnerability intake, and updates, but cite and test both legal texts.
  • Prepare a field matrix before deciding whether one statement can serve both markets.
  • Record accompaniment, supplier checks, publication locations, retention dates, and responsible owners for each market.
Section 1

Which regime applies?

UK PSTI applies to relevant connectable products made available to UK consumers, subject to statutory exceptions and actor-specific tests. Its security requirements have applied since 29 April 2024.

Australia's comparison point is Part 2 of the Cyber Security Act 2024 and the Cyber Security (Security Standards for Smart Devices) Rules 2025, not every part of the Act. The Rules cover intended or likely to be used for personal, domestic, or household consumption when acquired in Australia by a consumer. Part 2 of the Rules and Schedule 1 commenced 12 months after the Rules were registered on 4 March 2025, so the smart-device standard commenced on 4 March 2026.

Australia expressly exempts desktop and laptop computers, tablets, smartphones, therapeutic goods, road vehicles, and road-vehicle components from this standard. UK exceptions differ. For example, a connected home camera or smart speaker can be a representative in-scope product in both markets, while an Australian-exempt smartphone still needs a separate UK assessment. The specific design, intended use, supply path, and exception conditions control the result.

The actor tests also differ. An Australian manufacturer must comply when it is aware, or could reasonably be expected to be aware, that the product will be acquired in Australia in the specified consumer circumstances. An Australian supplier must not supply a non-compliant product when the supplier has the same form of awareness and must meet the statement duty. UK manufacturers, importers, and distributors follow the PSTI Act's separate intention, knowledge, and reasonable-belief tests.

Section 2

Where the controls align and where they split

Both regimes address passwords, a public channel for security reports, and publication of a security-update support period. That makes shared engineering evidence practical. The detailed wording still matters. For example, Australia's Rules require publication of when reporters will receive acknowledgements and status updates, set accessibility conditions for the published reporting information, require an end date for the defined support period, and regulate how prominently a manufacturer publishes that period on websites under its control.

The statement rules are materially different. Under UK PSTI, a must accompany the product unless a current statutory deemed-compliance condition applies, and manufacturers and importers generally retain a required statement for the longer of 10 years from issue or the defined support period. Under the Australian Rules, the manufacturer prepares the statement, suppliers must supply the product accompanied by it, and manufacturers and suppliers retain it for five years. The Australian statement identifies the product and batch, the manufacturer, an authorised representative, any of the manufacturer's other authorised representatives in Australia, the manufacturer's declarations, the defined support period at issue, the signatory and function, and the place and date of issue.

The Australian Act requires a supplier to supply the covered product accompanied by the statement. The explanatory statement adds that the statement need not be handed to the buyer at the point of sale and is intended for regulator use; a responsible entity may provide or publish it with the product if it chooses. Information used for another jurisdiction may be reused only if every Australian content requirement is met. The UK accompaniment and content analysis remains separate.

Can the same cover the UK and Australia?

It can be the same controlled document only if it satisfies both regimes in full. The Australian explanatory statement expressly allows information used for a UK PSTI product to be reused when every Australian requirement is met. Check product and batch identification, details of the manufacturer, an authorised representative, and any of the manufacturer's other authorised representatives in Australia, declarations, defined support period, signature, signatory function, and place and date of issue, as well as the separate UK Schedule 4 fields and accompaniment rule.

Do Australia's ransomware-reporting rules apply to every smart-device manufacturer?

Not merely because a manufacturer sells a smart device. Ransomware payment reporting sits in Part 3 of the Cyber Security Act and has its own application and threshold tests. This page compares the smart-device security regime in Part 2 and the 2025 Smart Device Rules. Assess ransomware reporting separately if a payment is made after a qualifying cyber security incident.

Are smartphones covered by both regimes?

Australia's 2025 Smart Device Rules expressly exempt smartphones from the consumer-grade security standard. UK PSTI does not use the same blanket smartphone exception, so a smartphone or related product still needs a separate UK scope assessment. Companion products such as a connected accessory can also require their own assessment.

  • Use a product-and-batch identifier that can connect both statements to the tested hardware, firmware, companion software, and release.
  • Check every password path, including factory reset, preinstalled software, and software needed for all manufacturer-intended purposes.
  • Publish one security-reporting page that meets the stricter applicable content and accessibility conditions, while recording which clauses it satisfies.
  • State a fixed support end date where Australia applies. Do not shorten Australia's published defined support period; record any extension and update the required product pages.
  • Approve a jurisdiction-specific statement checklist before supply. Similar titles do not make the statements legally interchangeable.
  • Reassess both files when a firmware or service release changes credentials, reporting contacts, update delivery, the support end date, product identifiers, manufacturer details, consumer positioning, or the supply route.
Primary sources

References and citations

legislation.gov.au10 citations
Referenced sections
  • Binding Australian Rules for consumer scope, exclusions, statement requirements, retention, passwords, security reports, updates, and support periods.
  • Sections 2, 6, 8, 9, and 10 and Schedule 1 set commencement, consumer scope, exceptions, statement content, retention, and security controls.
  • Schedule 1 clauses 2 to 4 set Australian password, security-reporting, update, support-period, and publication requirements; sections 9 and 10 govern statements.
Show 7 more
  • Sections 6 and 8 set the consumer test, product class, acquisition circumstance, and exclusions.
  • The Rules specify the manufacturer and supplier actions for the prescribed product class.
  • Schedule 1 clauses 2 to 4 contain the Australian security standard.
  • Sections 9 and 10 set statement content and the five-year retention period.
  • Section 11 specifies additional matters that may be published after failure to comply with a recall notice.
  • Provides the 4 March 2026 commencement date and the prescribed product, statement, security, and publication conditions.
  • Binding source for Australian product scope, security, statement, supply, publication, and retention requirements.
legislation.gov.uk7 citations
Referenced sections
  • Binding UK Regulations for the three security requirements, exceptions, statement content, retention, and deemed compliance.
  • Binding UK source for the security requirements, exceptions, statements, retention, and 29 April 2024 commencement.
  • Schedules 1 and 4 and regulations 7 to 9 provide the comparable UK requirements.
Show 4 more
  • Schedule 1 contains the UK password, reporting-channel, and support-period requirements.
  • Regulations 7 to 9 and Schedule 4 set statement content and UK retention.
  • Provides the UK commencement date and the product-security and statement conditions that can change.
  • Binding source for UK security, statement, and retention requirements.
legislation.gov.au4 citations
Referenced sections
  • Binding Australian Act for relevant connectable products, manufacturers, suppliers, statements, notices, examination, and internal review.
  • Part 2 establishes security standards, manufacturer and supplier obligations, statements of compliance, and enforcement.
  • Sections 15 and 16 assign compliance and statement duties to manufacturers and suppliers.
Show 1 more
  • Part 2 Divisions 3 and 4 establish notices, publication, examination, review, and related enforcement mechanisms.
legislation.gov.au4 citations
Referenced sections
  • Explains statement content, cross-jurisdiction reuse, point-of-sale treatment, five-year retention, scope examples, and website publication expectations.
  • Explains the Australian password, reporting, update, and publication conditions.
  • States that cross-jurisdiction information may be reused only when all Australian requirements are met.
Show 1 more
  • Explains how the Australian duties attach to product, actor, acquisition, publication, and statement facts.
legislation.gov.uk3 citations
Referenced sections
  • Binding UK Act for product scope, actor duties, statements of compliance, and enforcement.
  • Sections 4 to 7 and 54 to 55 provide the UK scope definitions and consumer-availability tests.
  • Part 1 Chapters 2 to 4 set manufacturer, importer, distributor, and authorised-representative duties.
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UK PSTI Statement of Compliance Evidence Pack

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UK PSTI Statement of Compliance Template

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UK PSTI Statement of Compliance Workflow

Prepare, approve, provide, verify, retain, and update statement evidence before a relevant connectable product is made available in the UK.

UK PSTI Support Period Evidence Workflow

Set, publish, approve, and preserve the product-specific minimum security-update period and end date, then control changes and customer information against the shipped product.

UK PSTI to ETSI Evidence Mapping

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UK PSTI vs EU Cyber Resilience Act

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UK PSTI vs EU Cyber Resilience Act (CRA)

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UK PSTI Vulnerability Disclosure Workflow

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UK PSTI Default Password Rules

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UK PSTI ETSI Evidence and Deemed Compliance

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UK PSTI Excepted Products and Boundaries

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UK PSTI Importer and Distributor Duties

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UK PSTI OPSS Notices: Compliance, Stop, Recall, and Penalties

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UK PSTI Relevant Connectable Product Scope

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UK PSTI Security Update Support Periods

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UK PSTI Security Update Transparency

Publish the minimum security-update period and end date in English, free of charge, without prior request, and in language understandable without technical knowledge.

UK PSTI Statement of Compliance: Contents, Delivery, and Records

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UK PSTI Vulnerability Disclosure Requirements

Publish a clear reporting route plus expected acknowledgement and status-update times. PSTI requires the information and timescales to be available; it does not prescribe one universal response deadline for every report.