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Artifact GuideUKRequirements

UK PSTI Product Security Requirements

Read the three Schedule 1 security requirements and the surrounding manufacturer, importer, distributor, statement, record, and failure-response duties.

Apply the exact Schedule 1 wording to the released product. Standards and test methods can support evidence, but only the statutory conditions determine compliance with the UK requirement.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

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Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

The in Schedule 1 bind manufacturers to control covered passwords, publish a vulnerability-reporting route and acknowledgment and status-update timings, and publish the minimum security-update period. The regime has applied since 29 April 2024. Part 1 of the Act gives manufacturers, importers, distributors, and authorised representatives separate duties according to product, consumer, role, and knowledge conditions, while the 2025 amendments changed exceptions and limited deemed-compliance routes.

Section 1

The three Schedule 1 requirements

First, each password within paragraph 1's scope must be unique per product or capable of being defined by the user; unique passwords must not be generated from counters, public information, unprotected unique identifiers, or another easily guessable method.

Second, the manufacturer must publish information enabling security issues to be reported and state when a reporter will receive acknowledgement and status updates. Third, the manufacturer must publish the defined support period, including an end date, under the access and prominence conditions in paragraph 3.

  • Password: map every covered hardware and associated-software access path to one compliant branch.
  • Vulnerability reporting: publish contact information, acknowledgement timing, and status-update timing, and maintain the channel.
  • Updates: publish the minimum security-update period and end date; do not shorten it after publication.
  • Apply each requirement's own product and software scope rather than assuming all three cover identical components.
Sources for this answer
PSTI Security Requirements for Relevant Connectable Products Regulations 2023 (current text)
The current consolidated Regulations contain the detailed password, vulnerability-reporting, update-period, statement, deemed-compliance, and exception rules.
Regulations: consumer connectable product security
OPSS and DSIT guidance explains the regime, covered actors and products, the three requirements, statement accompaniment, and enforcement authority.
Section 2

Statements, deemed compliance, and records

Under the ordinary route, a statement of compliance must accompany the product. Schedule 4 sets its required content. The Regulations require manufacturers and importers to retain statement copies for the longer of 10 years from issue or the product's defined support period.

Schedule 2 provides requirement-specific conditions tied to named standards. Since 4 December 2025, Schedule 2A provides limited conditions under which a manufacturer is treated as meeting the statement-accompaniment requirement. These routes apply only when every stated condition is met.

  • Use the current Schedule 4 fields and identify the exact product or product type covered.
  • Evidence how a physical or digital statement accompanies the product.
  • Retain the statement, issue date, signatory, version, and supporting evidence for the required period.
  • Document the exact standard, scheme, level, scope, date, and statutory conditions for any deemed-compliance route.
Sources for this answer
Product Security and Telecommunications Infrastructure Act 2022, Part 1
Part 1 defines product and actor scope, statements, investigations, remediation, notifications, records, and enforcement.
PSTI Security Requirements for Relevant Connectable Products Regulations 2023 (current text)
The current consolidated Regulations contain the detailed password, vulnerability-reporting, update-period, statement, deemed-compliance, and exception rules.
PSTI Security Requirements Amendment (No. 2) Regulations 2025
S.I. 2025/1267 added limited deemed-compliance conditions from 4 December 2025.
Section 3

Manufacturer, importer, distributor, and representative duties

Manufacturers, importers, and distributors each have actor-specific duties. Regulation 3 currently applies the three Schedule 1 requirements to manufacturers. Importers and distributors do not inherit those technical controls as if they were manufacturers, but they must determine their section 7 role and perform their own statement and known-failure duties. Importers also have investigation and record duties; both roles have contact, notification, stop-supply, and remedial duties when the Act's conditions apply.

Authorised representatives do not take over all manufacturer duties. Their express section 13 duty concerns contact with the manufacturer and notification to the enforcement authority when informed of a possible failure and the statutory conditions are met.

  • Classify every legal entity and product route before assigning controls.
  • Give importers and distributors evidence needed to verify statements and known compliance status before supply.
  • Define stop-supply authority and upstream and downstream contact paths.
  • Keep role decisions current after rebranding, import-route, fulfilment, or corporate changes.
Sources for this answer
Product Security and Telecommunications Infrastructure Act 2022, Part 1
Part 1 defines product and actor scope, statements, investigations, remediation, notifications, records, and enforcement.
The UK Product Security and Telecommunications Infrastructure (Product Security) regime
The government policy paper explains the legislative framework, economic-operator duties, statements, and the relationship to ETSI provisions.
Section 4

Investigations, corrective action, and enforcement

The Act requires manufacturers and importers to investigate potential compliance failures in specified circumstances. The role-specific provisions then require reasonable remedial steps, prevention of further supply, contact, records, and notifications when their conditions apply. Manufacturer investigation and compliance-failure records, and importer investigation records, are retained for 10 years from the day the record is made. A vulnerability report can trigger an investigation, but it is not automatic proof of a statutory failure.

OPSS enforces the regime and can use information, compliance, stop and recall notices, monetary penalties, and other powers. Record facts promptly so the business can distinguish a product defect, a statutory compliance failure, and a broader security improvement.

  • Log the report, affected products, scope, evidence, outcome, risks, remedy, and validation.
  • Apply the exact notification recipients and timing language from the actor's Act section.
  • Preserve investigation and compliance-failure records required by the Act.
  • Track OPSS notices, representations, corrective steps, appeal rights, and deadlines.
Sources for this answer
Product Security and Telecommunications Infrastructure Act 2022, Part 1
Part 1 defines product and actor scope, statements, investigations, remediation, notifications, records, and enforcement.
Consumer connectable product security regulations: enforcement actions
OPSS guidance explains compliance failures, investigations, notifications, notices, penalties, representations, and appeals.
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Primary sources

References and citations

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