Comparison GuideUK and EU Product Security

UK PSTI vs EU Cyber Resilience Act

The UK PSTI regime and the EU Cyber Resilience Act overlap, but they do not ask the same questions in the same way.

A manufacturer selling into both markets should reuse evidence carefully while keeping separate legal mappings for UK consumer product duties and the broader EU framework.

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Sorena AI
Published
Feb 22, 2026
Updated
Feb 22, 2026
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Sorena AI
Published Feb 22, 2026
Updated Feb 22, 2026
Overview

The UK PSTI regime is deliberately narrow and focused on consumer connectable products with three mandatory security requirements plus statement and supply-chain duties. The Cyber Resilience Act is broader, uses a different conformity and documentation structure, and reaches further into lifecycle and vulnerability-management obligations. Cross-market teams should therefore reuse evidence where it fits, not merge the laws into one unchecked program.

Section 1

PSTI is narrower and more explicit at the core control level

PSTI focuses on relevant connectable products made available to consumers in the UK and on three mandatory security requirements. This makes the first compliance question very product-specific and channel-specific.

The CRA takes a broader lifecycle and conformity route across connected products placed on the EU market.

  • Keep a UK product-scope file separate from the EU conformity file
  • Reuse engineering evidence only after checking the legal test on each side
  • Do not assume a UK statement satisfies EU conformity documentation
Section 2

Statements and conformity documents are not interchangeable

For most products, PSTI relies on the section 9 statement of compliance and related summary and retention rules, but the current law also includes Schedule 2A cases where the section 9 accompaniment requirement is deemed to be met without that statement route. The CRA uses a different EU documentation and conformity structure. The practical result is that one evidence backbone can be shared, but the outward legal document set should remain jurisdiction-specific.

This is especially important for support-period and post-market records.

  • Reuse product architecture, testing, and vulnerability evidence where valid
  • Draft UK and EU outward legal documents separately
  • Keep market-specific record-retention, deemed-compliance, and update workflows visible
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