ETSI EN 303 645 V2.1.1 (2020-06)

EUROPEAN STANDARDCYBER;
Cyber Security for Consumer Internet of Things:
Baseline Requirements

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ETSI EN 303 645 V2.1.1 (2020-06)

Reference
REN/CYBER-0048

Keywords
cybersecurity, IoT, privacy

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ETSI EN 303 645 V2.1.1 (2020-06)

Contents
Intellectual Property Rights ................................................................................................................................4
Foreword.............................................................................................................................................................4
Modal verbs terminology....................................................................................................................................4
Introduction ........................................................................................................................................................4
1

Scope ........................................................................................................................................................62

References ................................................................................................................................................6

2.1
2.2

3
3.1
3.2
3.3

Normative references ......................................................................................................................................... 6
Informative references ........................................................................................................................................ 7

Definition of terms, symbols and abbreviations .......................................................................................9
Terms.................................................................................................................................................................. 9
Symbols ............................................................................................................................................................ 11
Abbreviations ................................................................................................................................................... 124Reporting implementation ......................................................................................................................12

5

Cyber security provisions for consumer IoT ..........................................................................................13

5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
5.10
5.11
5.12
5.13

6

No universal default passwords ........................................................................................................................ 13
Implement a means to manage reports of vulnerabilities ................................................................................. 14
Keep software updated ..................................................................................................................................... 15
Securely store sensitive security parameters .................................................................................................... 18
Communicate securely ..................................................................................................................................... 19
Minimize exposed attack surfaces .................................................................................................................... 20
Ensure software integrity.................................................................................................................................. 21
Ensure that personal data is secure ................................................................................................................... 22
Make systems resilient to outages .................................................................................................................... 22
Examine system telemetry data ........................................................................................................................ 23
Make it easy for users to delete user data ......................................................................................................... 23
Make installation and maintenance of devices easy ......................................................................................... 24
Validate input data............................................................................................................................................ 24

Data protection provisions for consumer IoT .........................................................................................24

Annex A (informative):

Basic concepts and models ............................................................................26

A.1

Architecture ............................................................................................................................................26

A.2

Device states ...........................................................................................................................................28

Annex B (informative):

Implementation conformance statement pro forma ...................................31

History ..............................................................................................................................................................34

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ETSI EN 303 645 V2.1.1 (2020-06)

Intellectual Property Rights
Essential patents
IPRs essential or potentially essential to normative deliverables may have been declared to ETSI. The information
pertaining to these essential IPRs, if any, is publicly available for ETSI members and non-members, and can be foundin ETSI SR 000 314: "Intellectual Property Rights (IPRs); Essential, or potentially Essential, IPRs notified to ETSI in
respect of ETSI standards", which is available from the ETSI Secretariat. Latest updates are available on the ETSI Web
server (https://ipr.etsi.org/).
Pursuant to the ETSI IPR Policy, no investigation, including IPR searches, has been carried out by ETSI. No guarantee
can be given as to the existence of other IPRs not referenced in ETSI SR 000 314 (or the updates on the ETSI Web
server) which are, or may be, or may become, essential to the present document.
Trademarks
The present document may include trademarks and/or tradenames which are asserted and/or registered by their owners.
ETSI claims no ownership of these except for any which are indicated as being the property of ETSI, and conveys noright to use or reproduce any trademark and/or tradename. Mention of those trademarks in the present document does
not constitute an endorsement by ETSI of products, services or organizations associated with those trademarks.

Foreword
This European Standard (EN) has been produced by ETSI Technical Committee Cyber Security (CYBER).

National transposition dates
Date of adoption of this EN:

19 June 2020

Date of latest announcement of this EN (doa):

30 September 2020

Date of latest publication of new National Standard
or endorsement of this EN (dop/e):

31 March 2021

Date of withdrawal of any conflicting National Standard (dow):

31 March 2021

Modal verbs terminology
In the present document "shall", "shall not", "should", "should not", "may", "need not", "will", "will not", "can" and"cannot" are to be interpreted as described in clause 3.2 of the ETSI Drafting Rules (Verbal forms for the expression ofprovisions).
"must" and "must not" are NOT allowed in ETSI deliverables except when used in direct citation.

Introduction
As more devices in the home connect to the Internet, the cyber security of the Internet of Things (IoT) becomes a
growing concern. People entrust their personal data to an increasing number of online devices and services. Products
and appliances that have traditionally been offline are now connected and need to be designed to withstand cyberthreats.
The present document brings together widely considered good practice in security for Internet-connected consumer
devices in a set of high-level outcome-focused provisions. The objective of the present document is to support all
parties involved in the development and manufacturing of consumer IoT with guidance on securing their products.

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The provisions are primarily outcome-focused, rather than prescriptive, giving organizations the flexibility to innovate
and implement security solutions appropriate for their products.
The present document is not intended to solve all security challenges associated with consumer IoT. It also does not
focus on protecting against attacks that are prolonged/sophisticated or that require sustained physical access to thedevice. Rather, the focus is on the technical controls and organizational policies that matter most in addressing the mostsignificant and widespread security shortcomings. Overall, a baseline level of security is considered; this is intended toprotect against elementary attacks on fundamental design weaknesses (such as the use of easily guessable passwords).
The present document provides a set of baseline provisions applicable to all consumer IoT devices. It is intended to becomplemented by other standards defining more specific provisions and fully testable and/or verifiable requirements for
specific devices which, together with the present document, will facilitate the development of assurance schemes.
Many consumer IoT devices and their associated services process and store personal data, the present document canhelp in ensuring that these are compliant with the General Data Protection Regulation (GDPR) [i.7]. Security by design
is an important principle that is endorsed by the present document.
ETSI TS 103 701 [i.19] provides guidance on how to assess and assure IoT products against provisions within thepresent document.
The provisions in the present document have been developed following a review of published standards,
recommendations and guidance on IoT security and privacy, including: ETSI TR 103 305-3 [i.1], ETSITR 103 309 [i.2], ENISA Baseline Security Recommendations [i.8], UK Department for Digital, Culture, Media andSport (DCMS) Secure by Design Report [i.9], IoT Security Foundation Compliance Framework [i.10], GSMA IoT
Security Guidelines and Assessment [i.11], ETSI TR 103 533 [i.12], DIN SPEC 27072 [i.20] and OWASP Internet ofThings [i.23].
NOTE:

Mappings of the landscape of IoT security standards, recommendations and guidance are available in
ENISA Baseline Security Recommendations for IoT - Interactive Tool [i.15] and in Copper Horse
Mapping Security & Privacy in the Internet of Things [i.14].

As consumer IoT products become increasingly secure, it is envisioned that future revisions of the present document
will mandate provisions that are currently recommendations in the present document.

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ETSI EN 303 645 V2.1.1 (2020-06)

Scope

The present document specifies high-level security and data protection provisions for consumer IoT devices that areconnected to network infrastructure (such as the Internet or home network) and their interactions with associatedservices. The associated services are out of scope. A non-exhaustive list of examples of consumer IoT devices includes:•connected children's toys and baby monitors;•

connected smoke detectors, door locks and window sensors;•

IoT gateways, base stations and hubs to which multiple devices connect;•

smart cameras, TVs and speakers;•

wearable health trackers;•

connected home automation and alarm systems, especially their gateways and hubs;•

connected appliances, such as washing machines and fridges; and•smart home assistants.

Moreover, the present document addresses security considerations specific to constrained devices.
EXAMPLE:

Window contact sensors, flood sensors and energy switches are typically constrained devices.

The present document provides basic guidance through examples and explanatory text for organizations involved in thedevelopment and manufacturing of consumer IoT on how to implement those provisions. Table B.1 provides a schema
for the reader to give information about the implementation of the provisions.
Devices that are not consumer IoT devices, for example those that are primarily intended to be used in manufacturing,
healthcare or other industrial applications, are not in scope of the present document.
The present document has been developed primarily to help protect consumers, however, other users of consumer IoT
equally benefit from the implementation of the provisions set out here.
Annex A (informative) of the present document has been included to provide context to clauses 4, 5 and 6 (normative).
Annex A contains examples of device and reference architectures and an example model of device states including data
storage for each state.

2

References

2.1

Normative references

References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of thereferenced document (including any amendments) applies.
Referenced documents which are not found to be publicly available in the expected location might be found athttps://docbox.etsi.org/Reference/.
NOTE:

While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee
their long term validity.

The following referenced documents are necessary for the application of the present document.
Not applicable.

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ETSI EN 303 645 V2.1.1 (2020-06)

Informative references

References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of thereferenced document (including any amendments) applies.
NOTE:

While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee
their long term validity.

The following referenced documents are not necessary for the application of the present document but they assist theuser with regard to a particular subject area.
[i.1]

ETSI TR 103 305-3: "CYBER; Critical Security Controls for Effective Cyber Defence; Part 3:
Service Sector Implementations".

[i.2]

ETSI TR 103 309: "CYBER; Secure by Default - platform security technology".

[i.3]

NIST Special Publication 800-63B: "Digital Identity Guidelines - Authentication and Lifecycle
Management".

NOTE:
[i.4]
NOTE:
[i.5]
NOTE:

Available at https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-63b.pdf.
ISO/IEC 29147: "Information technology - Security techniques - Vulnerability Disclosure".
Available at https://www.iso.org/standard/45170.html.
OASIS: "CSAF Common Vulnerability Reporting Framework (CVRF)".
Available at http://docs.oasis-open.org/csaf/csaf-cvrf/v1.2/csaf-cvrf-v1.2.html.

[i.6]

ETSI TR 103 331: "CYBER; Structured threat information sharing".

[i.7]

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on theprotection of natural persons with regard to the processing of personal data and on the freemovement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

[i.8]

ENISA: "Baseline Security Recommendations for IoT in the context of Critical Information
Infrastructures", November 2017, ISBN: 978-92-9204-236-3, doi: 10.2824/03228.

NOTE:
[i.9]
NOTE:
[i.10]NOTE:

Available at https://op.europa.eu/en/publication-detail/-/publication/c37f8196-d96f-11e7-a50601aa75ed71a1/language-en/format-PDF/source-117211901.
UK Department for Digital, Culture, Media and Sport: "Secure by Design: Improving the cybersecurity of consumer Internet of Things Report", March 2018.
Available at https://www.gov.uk/government/collections/secure-by-design.
IoT Security Foundation: "IoT Security Compliance Framework", Release 2 December 2018.
Available at https://www.iotsecurityfoundation.org/wp-content/uploads/2018/12/IoTSF-IoT-SecurityCompliance-Framework-Release-2.0-December-2018.pdf.

[i.11]

GSMA: "GSMA IoT Security Guidelines and Assessment".

NOTE:

Available at https://www.gsma.com/iot/iot-security/iot-security-guidelines/.

[i.12]ETSI TR 103 533: "SmartM2M; Security; Standards Landscape and best practices".

[i.13]

Commission Notice: The "Blue Guide" on the implementation of EU products rules 2016 (Textwith EEA relevance), 2016/C 272/01.

NOTE:

Available in the Official Journal of the European Union, https://eur-lex.europa.eu/legalcontent/EN/ALL/?uri=OJ:C:2016:272:TOC.

[i.14]

Copper Horse: "Mapping Security & Privacy in the Internet of Things".

NOTE:

Available at https://iotsecuritymapping.uk/.

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[i.15]
NOTE:[i.16]
NOTE:[i.17]ENISA: "Baseline Security Recommendations for IoT - Interactive Tool".
Available at https://www.enisa.europa.eu/topics/iot-and-smart-infrastructures/iot/baseline-securityrecommendations-for-iot-interactive-tool.
IoT Security Foundation: "Understanding the Contemporary Use of Vulnerability Disclosure inConsumer Internet of Things Product Companies".
Available at https://www.iotsecurityfoundation.org/wp-content/uploads/2018/11/VulnerabilityDisclosure-Design-v4.pdf.
F-Secure: "IoT threats: Explosion of 'smart' devices filling up homes leads to increasing risks".

NOTE:

Available at https://blog.f-secure.com/iot-threats/.

[i.18]

W3C: "Web of Things at W3C".

NOTE:[i.19]NOTE:ETSI EN 303 645 V2.1.1 (2020-06)

Available at https://www.w3.org/WoT/.
ETSI TS 103 701: "CYBER; Cybersecurity assessment for consumer IoT products".
It is under development.

[i.20]DIN SPEC 27072: "Information Technology - IoT capable devices - Minimum requirements for
Information security".

[i.21]

GSMA: "Coordinated Vulnerability Disclosure (CVD) Programme".

NOTE:

Available at https://www.gsma.com/security/gsma-coordinated-vulnerability-disclosure-programme/.

[i.22]

IoT Security Foundation: "Vulnerability Disclosure - Best Practice Guidelines".

NOTE:

Available at https://www.iotsecurityfoundation.org/wp-content/uploads/2017/12/VulnerabilityDisclosure_WG4_2017.pdf.

[i.23]
NOTE:[i.24]NOTE:OWASP Internet of Things (IoT) Top 10 2018.
Available at https://www.owasp.org/index.php/OWASP_Internet_of_Things_Project#tab=IoT_Top_10.
IEEE 802.15.4™-2015: "IEEE Standard for Low-Rate Wireless Networks".
Available at https://standards.ieee.org/content/ieee-standards/en/standard/802_15_4-2015.html.

[i.25]ETSI TS 102 221: "Smart Cards; UICC-Terminal interface; Physical and logical characteristics".

[i.26]

GSMA: "SGP.22 Technical Specification v2.2.1".

[i.27]

ISO/IEC 27005:2018: "Information technology - Security techniques - Information security risk
management".

NOTE:[i.28]
NOTE:[i.29]

Available at https://www.iso.org/standard/75281.html.
Microsoft® Corporation: "The STRIDE Threat Model".
Available at https://msdn.microsoft.com/en-us/library/ee823878(v=cs.20).aspx.
ETSI TR 121 905: "Digital cellular telecommunications system (Phase 2+) (GSM); Universal
Mobile Telecommunications System (UMTS); LTE; Vocabulary for 3GPP Specifications (3GPP
TR 21.905)".

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3

Definition of terms, symbols and abbreviations

3.1

Terms

For the purposes of the present document, the following terms apply:
administrator: user who has the highest-privilege level possible for a user of the device, which can mean they are able
to change any configuration related to the intended functionality
associated services: digital services that, together with the device, are part of the overall consumer IoT product and thatare typically required to provide the product's intended functionality
EXAMPLE 1:

Associated services can include mobile applications, cloud computing/storage and third party
Application Programming Interfaces (APIs).

EXAMPLE 2:

A device transmits telemetry data to a third-party service chosen by the device manufacturer. This
service is an associated service.

authentication mechanism: method used to prove the authenticity of an entity
NOTE:

An "entity" can be either a user or machine.

EXAMPLE:An authentication mechanism can be the requesting of a password, scanning a QR code, or use of abiometric fingerprint scanner.

authentication value: individual value of an attribute used by an authentication mechanism
EXAMPLE:When the authentication mechanism is to request a password, the authentication value can be acharacter string. When the authentication mechanism is a biometric fingerprint recognition, theauthentication value can be the index fingerprint of the left hand.

best practice cryptography: cryptography that is suitable for the corresponding use case and has no indications of afeasible attack with current readily available techniques
NOTE 1: This does not refer only to the cryptographic primitives used, but also implementation, key generation andhandling of keys.
NOTE 2: Multiple organizations, such as SDOs and public authorities, maintain guides and catalogues ofcryptographic methods that can be used.
EXAMPLE:The device manufacturer uses a communication protocol and cryptographic library provided with
the IoT platform and where that library and protocol have been assessed against feasible attacks,
such as replay.

constrained device: device which has physical limitations in either the ability to process data, the ability tocommunicate data, the ability to store data or the ability to interact with the user, due to restrictions that arise from its
intended use
NOTE 1: Physical limitations can be due to power supply, battery life, processing power, physical access, limited
functionality, limited memory or limited network bandwidth. These limitations can require a constrained
device to be supported by another device, such as a base station or companion device.
EXAMPLE 1:

A window sensor's battery cannot be charged or changed by the user; this is a constrained device.

EXAMPLE 2:

The device cannot have its software updated due to storage limitations, resulting in hardware
replacement or network isolation being the only options to manage a security vulnerability.

EXAMPLE 3:

A low-powered device uses a battery to enable it to be deployed in a range of locations.
Performing high power cryptographic operations would quickly reduce the battery life, so it relies
on a base station or hub to perform validations on updates.

EXAMPLE 4:

The device has no display screen to validate binding codes for Bluetooth pairing.

EXAMPLE 5:

The device has no ability to input, such as via a keyboard, authentication information.

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NOTE 2: A device that has a wired power supply and can support IP-based protocols and the cryptographic
primitives used by those protocols is not constrained.
EXAMPLE 6:

A device is mains powered and communicates primarily using TLS (Transport Layer Security).

consumer: natural person who is acting for purposes that are outside her/his trade, business, craft or profession
NOTE:

Organizations, including businesses of any size, use consumer IoT. For example, Smart TVs are
frequently deployed in meeting rooms, and home security kits can protect the premises of small
businesses.

consumer IoT device: network-connected (and network-connectable) device that has relationships to associatedservices and are used by the consumer typically in the home or as electronic wearables
NOTE 1: Consumer IoT devices are commonly also used in business contexts. These devices remain classified asconsumer IoT devices.
NOTE 2: Consumer IoT devices are often available for the consumer to purchase in retail environments. Consumer
IoT devices can also be commissioned and/or installed professionally.
critical security parameter: security-related secret information whose disclosure or modification can compromise thesecurity of a security module
EXAMPLE:

Secret cryptographic keys, authentication values such as passwords, PINs, private components ofcertificates.

debug interface: physical interface used by the manufacturer to communicate with the device during development or toperform triage of issues with the device and that is not used as part of the consumer-facing functionality
EXAMPLE:

Test points, UART, SWD, JTAG.

defined support period: minimum length of time, expressed as a period or by an end-date, for which a manufacturer
will provide security updates
NOTE:

This definition focuses on security aspects and not other aspects related to product support such as
warranty.

device manufacturer: entity that creates an assembled final consumer IoT product, which is likely to contain the
products and components of many other suppliers
factory default: state of the device after factory reset or after final production/assembly
NOTE:

This includes the physical device and software (including firmware) that is present on it after assembly.

initialization: process that activates the network connectivity of the device for operation and optionally setsauthentication features for a user or for network accessinitialized state: state of the device after initialization
IoT product: consumer IoT device and its associated services
isolable: able to be removed from the network it is connected to, where any functionality loss caused is related only tothat connectivity and not to its main function; alternatively, able to be placed in a self-contained environment with otherdevices if and only if the integrity of devices within that environment can be ensured
EXAMPLE:A Smart Fridge has a touchscreen-based interface that is network-connected. This interface can beremoved without stopping the fridge from keeping the contents chilled.

logical interface: software implementation that utilizes a network interface to communicate over the network via
channels or ports

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manufacturer: relevant economic operator in the supply chain (including the device manufacturer)
NOTE:

This definition acknowledges the variety of actors involved in the consumer IoT ecosystem and thecomplex ways by which they can share responsibilities. Beyond the device manufacturer, such entities
can also be, for example and depending on a specific case at hand: importers, distributors, integrators,
component and platform providers, software providers, IT and telecommunications service providers,managed service providers and providers of associated services.

network interface: physical interface that can be used to access the functionality of consumer IoT via a network
owner: user who owns or who purchased the device
personal data: any information relating to an identified or identifiable natural person
NOTE:

This term is used to align with well-known terminology but has no legal meaning within the present
document.

physical interface: physical port or air interface (such as radio, audio or optical) used to communicate with the device
at the physical layer
EXAMPLE:Radios, ethernet ports, serial interfaces such as USB, and those used for debugging.

public security parameter: security related public information whose modification can compromise the security of asecurity module
EXAMPLE 1:

A public key to verify the authenticity/integrity of software updates.

EXAMPLE 2:

Public components of certificates.

remotely accessible: intended to be accessible from outside the local network
security module: set of hardware, software, and/or firmware that implements security functions
EXAMPLE:A device contains a hardware root of trust, a cryptographic software library that operates within atrusted execution environment, and software within the operating system that enforces security
such as user separation and the update mechanism. These all make up the security module.

security update: software update that addresses security vulnerabilities either discovered by or reported to the
manufacturer
NOTE:

Software updates can be purely security updates if the severity of the vulnerability requires a higher
priority fix.

sensitive security parameters: critical security parameters and public security parameters
software service: software component of a device that is used to support functionality
EXAMPLE:A runtime for the programming language used within the device software or a daemon that
exposes an API used by the device software, e.g. a cryptographic module's API.

telemetry: data from a device that can provide information to help the manufacturer identify issues or information
related to device usage
EXAMPLE:A consumer IoT device reports software malfunctions to the manufacturer enabling them toidentify and remedy the cause.

unique per device: unique for each individual device of a given product class or typeuser: natural person or organization

3.2

Symbols

Void.

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3.3

ETSI EN 303 645 V2.1.1 (2020-06)

Abbreviations

For the purposes of the present document, the following abbreviations apply:
API
ASLR
CVD
CVRF
DDoS
DSC
ENISA
EU
GDPR
GSM
GSMA
IEEE
IoT
IP
ISO
JTAG
LAN
LoRaWAN
MAC
NIST
NX
OTP
QR
SBOM
SDO
SE
SSID
STRIDE
SWD
TEE
TS
UART
UI
UK
USB
WAN

4

Application Programming Interface
Address Space Layout Randomization
Coordinated Vulnerability Disclosure
Common Vulnerability Reporting Framework
Distributed Denial of Service
Dedicated Security Components
European Union Agency for Network and Information Security
European Union
General Data Protection Regulation
Global System for Mobile communications
GSM Association
Institute of Electrical and Electronics Engineers
Internet of Things
Internet Protocol
International Organization for Standardization
Joint Test Action Group
Local Area Network
Long Range Wide Area Network
Media Access Control
National Institute of Standards and Technology
No execute
One-Time Password
Quick Response
Software Bill of Materials
Standards Development Organization
Secure Elements
Service Set IDentifier
Spoofing, Tampering, Repudiation, Information disclosure, Denial of service, Elevation ofprivilege
Serial Wire Debug
Trusted Execution Environment
Technical Specification
Universal Asynchronous Receiver-Transmitter
User Interface
United Kingdom
Universal Serial Bus
Wide Area Network

Reporting implementation

The implementation of provisions in the present document is informed by risk assessment and threat modelling (such as
ISO/IEC 27005:2018 [i.27] and STRIDE Threat Model [i.28]); this is performed by the device manufacturer and/or
other relevant entities and is out of scope of the present document. For certain use cases and following risk assessment,
it can be appropriate to apply additional provisions as well as those contained within the present document.
The present document sets a security baseline; however, due to the broad landscape of consumer IoT it is recognizedthat the applicability of provisions is dependent on each device. The present document provides a degree of flexibility
through the use of non-mandatory "should" provisions (recommendations).
Provision 4-1 A justification shall be recorded for each recommendation in the present document that is considered to
be not applicable for or not fulfilled by the consumer IoT device.
Table B.1 provides a schema to record these justifications in a structured manner. This is to allow other stakeholders(e.g. assurance assessors, members of the supply chain, security researchers or retailers) to determine whether
provisions have been applied correctly and appropriately.

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EXAMPLE 1:

The manufacturer publishes a completed version of table B.1 alongside the product description on
their website.

EXAMPLE 2:

The manufacturer completes table B.1 for internal record keeping. Sometime later, an external
assurance organization assesses a product against the present document and requests information
relating to the product's security design. The manufacturer can easily provide this information as it
is contained within table B.1.

Cases where a provision is not applicable or not fulfilled by the consumer IoT device can include:•

when a device is a constrained device in such a way that implementation of certain security measures is notpossible or not appropriate to the identified risk (security or privacy);•

where the functionality described in the provision is not included (e.g. a device that only presents data without
requiring authentication).

EXAMPLE 3:

A window sensor with a limited battery life sends alerts via a remote associated service when
triggered and is controlled via a hub. Due to its limited battery life and processing power comparedto other consumer IoT devices, it is a constrained device. In addition, because the user controls thedevice via a hub, the user does not need to use passwords, or other authentication mechanisms, todirectly authenticate to the device.

5

Cyber security provisions for consumer IoT

5.1

No universal default passwords

Provision 5.1-1 Where passwords are used and in any state other than the factory default, all consumer IoT device
passwords shall be unique per device or defined by the user.
NOTE:

There are many mechanisms used for performing authentication, and passwords are not the only
mechanism for authenticating a user to a device. However if they are used, following best practice on
passwords is encouraged according to NIST Special Publication 800-63B [i.3]. Using passwords formachine to machine authentication is generally not appropriate.

Many consumer IoT devices are sold with universal default usernames and passwords (such as "admin, admin") for userinterfaces through to network protocols. Continued usage of universal default values has been the source of many
security issues in IoT [i.17] and the practice needs to be discontinued. The above provision can be achieved by the useof pre-installed passwords that are unique per device and/or by requiring the user to choose a password that follows bestpractice as part of initialization, or by some other method that does not use passwords.
EXAMPLE 1:

During initialization a device generates certificates that are used to authenticate a user to thedevice via an associated service like a mobile application.

To increase security, multi-factor authentication, such as use of a password plus OTP procedure, can be used to better
protect the device or an associated service. Device security can further be strengthened by having unique and immutable
identities.
Provision 5.1-2 Where pre-installed unique per device passwords are used, these shall be generated with a mechanismthat reduces the risk of automated attacks against a class or type of device.
EXAMPLE 2:

Pre-installed passwords are sufficiently randomized.

As a counter-example, passwords with incremental counters (such as "password1", "password2" and so on) are easily
guessable. Further, using a password that is related in an obvious way to public information (sent over the air or withina network), such as MAC address or Wi-Fi® SSID, can allow for password retrieval using automated means.
Provision 5.1-3 Authentication mechanisms used to authenticate users against a device shall use best practice
cryptography, appropriate to the properties of the technology, risk and usage.

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Provision 5.1-4 Where a user can authenticate against a device, the device shall provide to the user or an administrator
a simple mechanism to change the authentication value used.
EXAMPLE 3:

For biometric authentication values the device manufacturer allows this change in authentication
value through retraining against a new biometric.

EXAMPLE 4:

A parent in a household creates an account on the device for their child and selects and manages
the PIN or password that the child uses. The parent is an administrator on the device and can
restrict the child from changing the PIN or password.

EXAMPLE 5:

To make it simple for the user to change a password, the manufacturer designs the password
change process in a way that it requires a minimal number of steps. The manufacturer explains theprocess in a user manual and in a video tutorial.

An authentication mechanism used for authenticating users, whether it be a fingerprint, password or other token, needs
to have its value changeable. This is easier when this mechanism is part of the normal usage flow of the device.
Provision 5.1-5 When the device is not a constrained device, it shall have a mechanism available which makes bruteforce attacks on authentication mechanisms via network interfaces impracticable.
EXAMPLE 6:

A device has a limitation on the number of authentication attempts within a certain time interval. It
also uses increasing time intervals between attempts.

EXAMPLE 7:

The client application is able to lock an account or to delay additional authentication attempts after
a limited number of failed authentication attempts.

This provision addresses attacks that perform "credential stuffing" or exhaust an entire key-space. It is important thatthese types of attacks are detected by the consumer IoT device and defended against, whilst guarding against a related
threat of "resource exhaustion" and denial of service attacks.

5.2

Implement a means to manage reports of vulnerabilities

Provision 5.2-1 The manufacturer shall make a vulnerability disclosure policy publicly available. This policy shall
include, at a minimum:•

contact information for the reporting of issues; and•information on timelines for:1)

initial acknowledgement of receipt; and2)status updates until the resolution of the reported issues.

A vulnerability disclosure policy clearly specifies the process through which security researchers and others are able toreport issues. Such policy can be updated as necessary to further ensure transparency and clarity in the dealings of the
manufacturer with security researchers, and vice versa.
Coordinated Vulnerability Disclosure (CVD) is a set of processes for dealing with disclosures about potential security
vulnerabilities and to support the remediation of these vulnerabilities. CVD is standardized by the International
Organization for Standardization (ISO) in the ISO/IEC 29147 [i.4] on vulnerability disclosure and has been proven tobe successful in some large software companies around the world.
In the IoT industry, CVD is currently not well-established [i.16] as some companies are reticent about dealing withsecurity researchers. Here, CVD provides companies a framework to manage this process. This gives security
researchers an avenue to inform companies of security issues, puts companies ahead of the threat of malicious
exploitation and gives companies an opportunity to respond to and resolve vulnerabilities in advance of a public
disclosure.
Provision 5.2-2 Disclosed vulnerabilities should be acted on in a timely manner.
A "timely manner" for acting on vulnerabilities varies considerably and is incident-specific; however, conventionally,
the vulnerability process is completed within 90 days for a software solution, including availability of patches andnotification of the issue. A hardware fix can take considerably longer to address than a software fix. Additionally, a fix
that has to be deployed to devices can take time to roll out compared with a server software fix.

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Provision 5.2-3 Manufacturers should continually monitor for, identify and rectify security vulnerabilities within
products and services they sell, produce, have produced and services they operate during the defined support period.
NOTE 1: Manufacturers are expected to exercise due care for all software and hardware components used in the
product, this includes due care related to the selected third parties that provide associated services tosupport the functions of the product.
Software solutions often contain open source and third party software components. Creating and maintaining list of all
software components and their sub-components is a pre-requisite to be able to monitor for product vulnerabilities.
Various tools exist to scan source code and binaries and build a so-called Software Bill of Materials (SBOM), which
identifies third party components and the versions used in the product. This information is then used to monitor for the
associated security and licensing risks of each identified software component.
Vulnerabilities are expected to be reported directly to the affected stakeholders in the first instance. If that is notpossible, vulnerabilities can be reported to national authorities. Manufacturers are also encouraged to share information
with competent industry bodies, such as the GSMA [i.21] and the IoT Security Foundation. Guidance on CoordinatedVulnerability Disclosure is available from the IoT Security Foundation [i.22] which references ISO/IEC 29147 [i.4].
This is expected to be performed for devices within their defined support period. However, manufacturers can continue
this outside that period and release security updates to rectify vulnerabilities.
Manufacturers that provide IoT products have a duty of care to consumers and third parties who can be harmed by theirfailure to have a CVD programme in place. Additionally, companies that share this information through industry bodies
can assist others who can be suffering from the same problem.
Disclosures can comprise different approaches depending on the circumstances:•

Vulnerabilities related to single products or services: the problem is expected to be reported directly to theaffected stakeholder (usually the device manufacturer, IoT service provider or mobile application developer).
The source of these reports can be security researchers or industry peers.

•

Systemic vulnerabilities: a stakeholder, such as a device manufacturer, can discover a problem that is
potentially systemic. Whilst fixing it in the device manufacturer's own product is crucial, there is significant
benefit to industry and consumers from sharing this information. Similarly, security researchers can also seek
to report such systemic vulnerabilities. For systemic vulnerabilities, a relevant competent industry body cancoordinate a wider scale response.

NOTE 2: The Common Vulnerability Reporting Framework (CVRF) [i.5] can also be useful to exchange
information on security vulnerabilities.
Cyber security threat information sharing can support organizations in developing and producing secure products
according to ETSI TR 103 331 [i.6].

5.3

Keep software updated

Developing and deploying security updates in a timely manner is one of the most important actions a manufacturer cantake to protect its customers and the wider technical ecosystem. It is good practice that all software is kept updated andwell maintained.
Each provision from 5.3-3 to 5.3-12 is dependent upon an update mechanism being implemented, as perprovision 5.3-1 or 5.3-2.
Provision 5.3-1 All software components in consumer IoT devices should be securely updateable.
NOTE 1: Managing software updates successfully generally relies on communication of version information forsoftware components between the device and the manufacturer.
Not all software on a device will be updateable.
EXAMPLE 1:

The first stage boot loader on a device is written once to device storage and from then on isimmutable.

EXAMPLE 2:

On devices with several microcontrollers (e.g. one for communication and one for the application)some of them might not be updateable.

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Provision 5.3-2 When the device is not a constrained device, it shall have an update mechanism for the secure
installation of updates.
NOTE 2: There are cases where provision 5.3-1 applies even where 5.3-2 does not.
"Securely updateable" and "secure installation" means that there are adequate measures to prevent an attacker misusing
the update mechanism.
EXAMPLE 3:

Measures can include the use of authentic software update servers, integrity protected
communications channels, verifying the authenticity and integrity of software updates. It is
recognized that there are great variances in software update mechanisms and what constitutes"installation".

EXAMPLE 4:

An anti-rollback policy based on version checking can be used to prevent downgrade attacks.

Update mechanisms can range from the device downloading the update directly from a remote server, transmitted froma mobile application or transferred over a USB or other physical interface. If an attacker compromises this mechanism,it allows for a malicious version of the software to be installed on the device.
Provision 5.3-3 An update shall be simple for the user to apply.
The degree of simplicity depends on the design and intended usage of the device. An update that is simple to apply will
be automatically applied, initiated using an associated service (such as a mobile application), or via a web interface on
the device. If an update is difficult to apply, then that increases the chance that a user will repeatedly defer updating thedevice, leaving it in a vulnerable state.
Provision 5.3-4 Automatic mechanisms should be used for software updates.
If an automatic update fails, then a user can, in some circumstances, no longer be able to use a device. Detection
mechanisms such as watchdogs and the use of dual-bank flash or recovery partitions can ensure that the device returns
to either a known good version or the factory state.
Security updates can be provided for devices in a preventative manner, as part of automatic updates, which can remove
security vulnerabilities before they are exploited. Managing this can be complex, especially if there are parallel
associated service updates, device updates and other service updates to deal with. Therefore, a clear management anddeployment plan is beneficial to the manufacturer, as is transparency to consumers about the current state of update
support.
In many cases, publishing software updates involves multiple dependencies on other organizations such as
manufacturers that produce sub-components; however, this is not a reason to withhold updates. It can be useful for the
manufacturer to consider the entire software supply chain in the development and deployment of security updates.
It is often advisable not to bundle security updates with more complex software updates, such as feature updates. A
feature update that introduces new functionality can trigger additional requirements and delay delivery of the update todevices.
EXAMPLE 5:

Under the EU Product Legislation, a feature update could change the intended use of a device andthus turn it into a new product, requiring a new conformity assessment to be conducted. However,a software update with limited impact could be considered a maintenance update which would not
require a new conformity assessment. More information on the impact of software updates in thecontext of the EU Product Legislation can be found in the Blue Guide [i.13].

Provision 5.3-5 The device should check after initialization, and then periodically, whether security updates areavailable.
EXAMPLE 6:

The user could be shown the existence of updates via the interface with which the device isinitialized.

EXAMPLE 7:

A device checks for available updates daily at a randomized time.

For some products, it can be more appropriate for the associated service, rather than the device, to perform such checks.
Provision 5.3-6 If the device supports automatic updates and/or update notifications, these should be enabled in theinitialized state and configurable so that the user can enable, disable, or postpone installation of security updates and/or
update notifications.

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It is important from a consumer rights and ownership perspective that the user is in control of whether or not theyreceive updates. There are good reasons why a user may choose not to update, including security. In addition, if an
update is deployed and subsequently found to cause issues, manufacturers can ask users to not upgrade their software inorder that those devices are not affected.
Provision 5.3-7 The device shall use best practice cryptography to facilitate secure update mechanisms.
Provision 5.3-8 Security updates shall be timely.
"Timely" in the context of security updates can vary, depending on the particular issue and fix, as well as other factors
such as the ability to reach a device or constrained device considerations. It is important that a security update that fixes
a critical vulnerability (i.e. one with potentially adverse effects of a large scale) is handled with appropriate priority by
the manufacturer. Due to the complex structure of modern software and the ubiquity of communication platforms,
multiple stakeholders can be involved in a security update.
EXAMPLE 8:

A particular software update involves a third party vendor of software libraries, an IoT device
manufacturer, and an IoT service platform operator. Collaboration between these stakeholders
ensures appropriate timeliness of the software update.

Provision 5.3-9 The device should verify the authenticity and integrity of software updates.
A common approach for confirming that an update is valid is to verify its integrity and authenticity. This can be done on
the device; however, constrained devices can have power limitations that make performing cryptographic operations
costly. In such cases, verification can be performed by another device that is trusted to perform this verification. The
verified update would then be sent over a secure channel to the device. Performing verification of updates at a hub andthen on the device, can reduce the risk of compromise.
It is good practice for a device to act upon the detection of an invalid and potentially malicious update. Beyond rejecting
the update, and without limitation, it can report the incident to an appropriate service and/or inform the user. In addition,
mitigating controls can be put in place to prevent an attacker from bypassing or misusing an update mechanism. Giving
the attacker as little information as possible as part of the update mechanism reduces their ability to exploit it.
EXAMPLE 9:

When a device detects that an update could not be delivered or applied successfully (by failing
integrity or authentication checks), the device can mitigate information leakage by not providing
any information about the failure to the initiator of the update process. However, the device cangenerate a log entry and deliver notification of the log entry to a trusted peer (e.g. a device
administrator) over a secure channel, so that the occurrence of the incident is known and the owneror administrator of the device can make an appropriate response.

Provision 5.3-10 Where updates are delivered over a network interface, the device shall verify the authenticity andintegrity of each update via a trust relationship.
NOTE 3: Valid trust relationships include: authenticated communication channels, presence on a network that
requires the device to possess a critical security parameter or password to join, digital signature based
verification of the update, or confirmation by the user.
NOTE 4: The validation of the trust relationship is essential to ensure that a non-authorized entity (e.g. device
management platform or device) cannot install malicious code.
Provision 5.3-11 The manufacturer should inform the user in a recognizable and apparent manner that a security update
is required together with information on the risks mitigated by that update.
EXAMPLE 10: The manufacturer informs the user that an update is required via a notification on the user interface
or via an email.
Provision 5.3-12 The device should notify the user when the application of a software update will disrupt the basic
functioning of the device.
NOTE 5: This is not necessary if a notification is made by an associated service.
This notification can include extra detail, such as the approximate expected duration for which the device will beoffline.
EXAMPLE 11: A notification includes information about the urgency and approximate expected duration of
downtime.

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It can be critical for users that a device continues to operate during an update. This is why the provision above
recommends to notify the user when an update will disrupt functionality where possible. Particularly, devices that fulfil
a safety-relevant function are expected not to turn completely off in the case of an update; some minimal system
functional capability is expected. Disruption to functionality can become a critical safety issue for some types ofdevices and systems if not considered or managed correctly.
EXAMPLE 12: During an update, a watch will continue to display the time, a home thermostat will continue tomaintain a reasonable temperature and a Smart Lock will continue to lock and unlock a door.
Provision 5.3-13 The manufacturer shall publish, in an accessible way that is clear and transparent to the user, thedefined support period.
When purchasing a product, the consumer expects this period of software update support to be made clear.
Provision 5.3-14 For constrained devices that cannot have their software updated, the rationale for the absence ofsoftware updates, the period and method of hardware replacement support and a defined support period should be
published by the manufacturer in an accessible way that is clear and transparent to the user.
Provision 5.3-15 For constrained devices that cannot have their software updated, the product should be isolable andthe hardware replaceable.
There are some situations where devices cannot be patched. For constrained devices a replacement plan needs to be inplace and be clearly communicated to the consumer. This plan would typically detail a schedule for when technologies
will need to be replaced and, where applicable, when support for hardware and software ends.
Provision 5.3-16 The model designation of the consumer IoT device shall be clearly recognizable, either by labellingon the device or via a physical interface.
This is often performed by communicating with a device over a logical interface, however it can also be part of a UI.
EXAMPLE 13: A device has a HTTP (or HTTPS when appropriate) API that reports the model designation (afteruser authentication).
Knowledge of the specific designation of the device is often required to check the defined support period of software
updates or the availability of software updates.

5.4

Securely store sensitive security parameters

Provision 5.4-1 Sensitive security parameters in persistent storage shall be stored securely by the device.
Secure storage mechanisms can be used to secure sensitive security parameters. Appropriate mechanisms include those
provided by a Trusted Execution Environment (TEE), encrypted storage associated with the hardware, Secure Elements(SE) or Dedicated Security Components (DSC), and processing capabilities of software running on a UICC, according
to ETSI TR 121 905 [i.29], ETSI TS 102 221 [i.25]/embedded UICC according to GSMA SGP.22 Technical
Specification v2.2.1 [i.26].
NOTE:

This provision applies to persistent storage, but manufacturers can also implement similar approaches forsensitive security parameters in memory.

EXAMPLE 1:

The root keys involved in authorization and access to licensed radio frequencies (e.g. LTE-mcellular access) are stored in a UICC.

EXAMPLE 2:

A remote controlled door-lock using a Trusted Execution Environment (TEE) to store and accessthe sensitive security parameters.

EXAMPLE 3:

A wireless thermostat stores the credentials for the wireless network in a tamper protected
microcontroller rather than in external flash storage.

Provision 5.4-2 Where a hard-coded unique per device identity is used in a device for security purposes, it shall be
implemented in such a way that it resists tampering by means such as physical, electrical or software.
EXAMPLE 4:

A master key used for network access that is unique to the device is stored in UICC which iscompliant to relevant ETSI standards (see, for example ETSI TS 102 221 [i.25]).

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Provision 5.4-3 Hard-coded critical security parameters in device software source code shall not be used.
Reverse engineering of devices and applications can easily discover credentials such as hard-coded usernames andpasswords in software. These credentials can also be API keys that allow usage of security-sensitive functions in aremote service, or private keys used in the security of protocols that the device uses to communicate. Such credentials
will often be found within source-code, which is well-known bad practice. Simple obfuscation methods also used to
obscure or encrypt this hard-coded information can be trivially broken.
Provision 5.4-4 Any critical security parameters used for integrity and authenticity checks of software updates and forprotection of communication with associated services in device software shall be unique per device and shall be
produced with a mechanism that reduces the risk of automated attacks against classes of devices.
EXAMPLE 5:

A different symmetric key is deployed on every device of the same product class for generating
and verifying message authentication codes for software updates.

EXAMPLE 6:

The device uses the manufacturer's public key to verify a software update. This is not a criticalsecurity parameter and does not need to be unique per device.

Provisioning a device with unique critical security parameters helps to protect the integrity and authenticity of software
updates as well as the communication of the device with associated services. If global critical security parameters areused, their disclosure can enable wide-scale attacks on other IoT devices such as to enable the creation of botnets.

5.5

Communicate securely

Provision 5.5-1 The consumer IoT device shall use best practice cryptography to communicate securely.
Appropriateness of security controls and the use of best practice cryptography is dependent on many factors including
the usage context. As security is ever-evolving it is difficult to give prescriptive advice about cryptography or othersecurity measures without the risk of such advice quickly becoming obsolete.
Provision 5.5-2 The consumer IoT device should use reviewed or evaluated implementations to deliver network andsecurity functionalities, particularly in the field of cryptography.
Reviews and evaluations can involve an independent internal or external entity.
EXAMPLE 1:

Distributed software libraries within the development and test community, certified softwaremodules, and hardware equipment crypto-service providers (such as the Secure Element and Trust
Execution Environment) are all reviewed or evaluated.

Provision 5.5-3 Cryptographic algorithms and primitives should be updateable.
NOTE 1: This is also known as "cryptoagility".
For devices that cannot be updated, it is important that the intended lifetime of the device does not exceed therecommended usage lifetime of cryptographic algorithms used by the device (including key sizes).
Provision 5.5-4 Access to device functionality via a network interface in the initialized state should only be possible
after authentication on that interface.
NOTE 2: Functionality can vary significantly on the use case and can encompass a range of things, including accessto personal data and device actuators.
There are devices that provide public, open data for example in the Web of Things [i.18]. These devices are accessible
without authentication to provide open access to all.
The device can be compromised via vulnerabilities in network services. A suitable authentication mechanism canprotect against unauthorized access and can contribute to defence-in-depth in the device.
Provision 5.5-5 Device functionality that allows security-relevant changes in configuration via a network interface shall
only be accessible after authentication. The exception is for network service protocols that are relied upon by the device
and where the manufacturer cannot guarantee what configuration will be required for the device to operate.
NOTE 3: Protocols that are an exception include ARP, DHCP, DNS, ICMP, and NTP.

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Security-relevant changes include permission management, configuration of network keys andpassword changes.

Provision 5.5-6 Critical security parameters should be encrypted in transit, with such encryption appropriate to theproperties of the technology, risk and usage.
Provision 5.5-7 The consumer IoT device shall protect the confidentiality of critical security parameters that arecommunicated via remotely accessible network interfaces.
Many different methods exist for enrolment and authentication. Some authentication values are provided by out-of-band
authentication mechanisms, such as a QR code, and some are human-readable, such as a password.
Where an authentication mechanism uses unique values per authentication attempt (e.g. in a challenge-response
mechanism or when using one time passwords as a second factor), the response is not the authentication value itself.
However, it is still good practice to apply confidentiality protection to those values.
Confidentiality protection can be achieved using an encrypted communication channel or payload encryption. This isoften done using protocols or algorithms at least as strong as the key material transmitted, however other mitigations,such as the need for close proximity, are available.
Provision 5.5-8 The manufacturer shall follow secure management processes for critical security parameters that relate
to the device.
The use of open, peer-reviewed standards for critical security parameters (commonly referred to as "key management")
is strongly encouraged.

5.6

Minimize exposed attack surfaces

The "principle of least privilege" is a foundation stone of good security engineering, applicable to IoT as much as in any
other field of application.
Provision 5.6-1 All unused network and logical interfaces shall be disabled.
EXAMPLE 1:

An administrative UI that is supposed to be accessed from the LAN is not accessible from the
WAN by default.

EXAMPLE 2:

A Direct Firmware Update (DFU) service exposed over Bluetooth® Low Energy is used fordevelopment but not expected to be used in production. It is disabled in the final product.

Provision 5.6-2 In the initialized state, the network interfaces of the device shall minimize the unauthenticateddisclosure of security-relevant information.
Security-relevant information can be exposed over a network interface as part of the initialization process. Whensecurity-relevant information is shared by a device when establishing a connection, it can be used by attackers to
identify vulnerable devices.
EXAMPLE 3:

When finding vulnerable devices throughout the whole IP address space, security-relevant
information could be information about the device configuration, kernel version or software
version.

Provision 5.6-3 Device hardware should not unnecessarily expose physical interfaces to attack.
Physical interfaces can be used by an attacker to compromise firmware or memory on a device. "Unnecessarily" refers
to the manufacturer's assessment of the benefits of an open interface, used for user functionality or for debugging
purposes.
EXAMPLE 4:

A micro-USB port meant to be used to power the device only is physically configured so as not toalso allow command or debug operations.

Provision 5.6-4 Where a debug interface is physically accessible, it shall be disabled in software.
EXAMPLE 5:

A UART serial interface is disabled through the bootloader software on the device. No logon
prompt and no interactive menu is available due to this disabling.

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Provision 5.6-5 The manufacturer should only enable software services that are used or required for the intended use oroperation of the device.
EXAMPLE 6:

The manufacturer does not provision the device with any background processes, kernel extensions,commands, programs or tools that are not required for the intended use.

Provision 5.6-6 Code should be minimized to the functionality necessary for the service/device to operate.
EXAMPLE 7:"Dead" or unused code is removed and not considered to be benign.

Provision 5.6-7 Software should run with least necessary privileges, taking account of both security and functionality.
EXAMPLE 8:

Minimal daemons/processes run with "root" privileges. In particular the processes that use network
interfaces require unprivileged users rather than requiring a "root" user.

EXAMPLE 9:

Applications running on a device that includes a multi-user operating system (e.g. Linux®) use
different users for each component or service.

Software attacks on devices that aim to corrupt memory can be mitigated through mechanisms such as stack canaries,
Address Space Layout Randomization (ASLR). The manufacturer can use platform security features where they areavailable to help further reduce the risk. Reducing privileges that they run at and minimizing code also helps to mitigate
this risk.
Provision 5.6-8 The device should include a hardware-level access control mechanism for memory.
Software exploits often use the lack of access control in memory to execute malicious code. Access control mechanisms
limit whether data in memory on the device can be executed. Suitable mechanisms include technologies such as MMUs
or MPUs, executable space protection (e.g. NX bits), memory tagging, and trusted execution environments.
Provision 5.6-9 The manufacturer should follow secure development processes for software deployed on the device.
Secure development processes, including using version control, or enabling security-related compiler options (e.g. stackprotection) can help ensure software artefacts are more secure. Manufacturers can use these options when using
toolchains that support them.

5.7

Ensure software integrity

Provision 5.7-1 The consumer IoT device should verify its software using secure boot mechanisms.
A hardware root of trust is one way to provide strong attestation as part of a secure boot mechanism. A hardware root oftrust is a component of a system from which all other components derive their "trust" - i.e. the source of cryptographic
trust within that system. To fulfil its function, the hardware root of trust is reliable and resistant to both physical andlogical tampering, as there is no mechanism to determine that the component has failed or been altered. By utilizing a
hardware root of trust, a device can have confidence in results of cryptographic functions, such as those utilized for
secure boot. A hardware root of trust can be either backed by mechanisms used for secure storage of credentials or otheralternatives providing baseline levels of security assurance proportionate to the required level of security for a given
device.
Provision 5.7-2 If an unauthorized change is detected to the software, the device should alert the user and/or
administrator to the issue and should not connect to wider networks than those necessary to perform the alerting
function.
The ability to recover remotely from unauthorized changes can rely on a known good state, such as locally storing aknown good version to enable safe recovery and updating of the device. This will avoid denial of service and costly
recalls or maintenance visits, whilst managing the risk of potential takeover of the device by an attacker subverting
update or other network communications mechanisms.
If a consumer IoT device detects an unauthorized change to its software, it will be able to inform the right stakeholder.
In some cases, devices can have the ability to be in administration mode.
EXAMPLE:A thermostat in a room can have a user mode; this mode prevents changing of other settings. If anunauthorized change to software is detected, an alert to the administrator is appropriate, as theadministrator has the ability to act on the alert (whereas a user does not).

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5.8

ETSI EN 303 645 V2.1.1 (2020-06)

An attack that forces a device to revert to a known good state can introduce a DoS risk if the device isunable to successfully perform this or if the attacker is able to repeatedly cause this effect.

Ensure that personal data is secure

Provision 5.8-1 The confidentiality of personal data transiting between a device and a service, especially associatedservices, should be protected, with best practice cryptography.
Provision 5.8-2 The confidentiality of sensitive personal data communicated between the device and associatedservices shall be protected, with cryptography appropriate to the properties of the technology and usage.
NOTE 1: In the context of this provision, "sensitive personal data" is data whose disclosure has a high potential tocause harm to the individual. What is to be treated as "sensitive personal data" varies across products anduse cases, but examples are: video stream of a home security camera, payment information, content ofcommunication data and timestamped location data. Carrying out security and data protection impact
assessments can help the manufacturer make appropriate choices.
NOTE 2: Associated services in this context are typically cloud services. Moreover these services are controlled or
can be influenced by the manufacturer. These services typically are not operated by the user.
NOTE 3: Confidentiality protection often includes integrity protection according to best practice cryptography.
Provision 5.8-3 All external sensing capabilities of the device shall be documented in an accessible way that is clear
and transparent for the user.
EXAMPLE:An external sensing capability can be an optic or acoustic sensor.

Clause 6 of the present document contains provisions specific to protecting personal data.

5.9

Make systems resilient to outages

The aim of the provisions in the present clause is to ensure that IoT services are kept up and running as the adoption of
IoT devices across all aspects of a consumer's life increases, including in functions that are relevant to personal safety. It
is important to note that safety-related regulations can apply, but the key is to avoid making outages the cause of impact
on the user and to design products and services that provide a level of resilience to these challenges.
Provision 5.9-1 Resilience should be built in to consumer IoT devices and services, taking into account the possibilityof outages of data networks and power.
Provision 5.9-2 Consumer IoT devices should remain operating and locally functional in the case of a loss of network
access and should recover cleanly in the case of restoration of a loss of power.
NOTE:"Recovering cleanly" normally involves resuming connectivity and functionality in the same or improved
state.

Provision 5.9-3 The consumer IoT device should connect to networks in an expected, operational and stable state andin an orderly fashion, taking the capability of the infrastructure into consideration.
EXAMPLE 1:

A Smart Home loses connection to the internet following a power outage. When the network
connection is restored, the devices in the home reconnect after a randomized delay to minimize
network utilization.

EXAMPLE 2:

After making an update available, the manufacturer notifies devices in batches to prevent them all
simultaneously downloading the update.

IoT systems and devices are relied upon by consumers for increasingly important use cases that can be safety-relevant
or life-impacting. Keeping services running locally if there is a loss of network is one of the measures that can be taken
to increase resilience. Other measures can include building redundancy into associated services as well as mitigations
against Distributed Denial of Service (DDoS) attacks or signalling storms, which can be caused by mass-reconnectionsof devices following an outage. It is expected that the level of resilience necessary is proportionate and determined byusage, with consideration given to others that rely on the system, service or device given that an outage can have awider impact than expected.

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Orderly reconnection means in a manner that takes explicit steps to avoid simultaneous requests, such as for software
updates or reconnections, from a large number of IoT devices. Such explicit steps can include the introduction of arandom delay before a reconnection attempt according to an incremental back-off mechanism.

5.10

Examine system telemetry data

Provision 5.10-1 If telemetry data is collected from consumer IoT devices and services, such as usage and measurement
data, it should be examined for security anomalies.
EXAMPLE 1:

Security anomalies can be represented by a deviation from normal behaviour of the device, as
expressed by the monitored indicators, for example an abnormal increase of failed login attempts.

EXAMPLE 2:

Telemetry from multiple devices allows a manufacturer to notice that updates are failing due toinvalid software update authenticity checks.

Examining telemetry, including log data, is useful for security evaluation and allows for unusual circumstances to be
identified early and dealt with, minimizing security risk and allowing quick mitigation of problems.
Clause 6 of the present document contains provisions specific to protecting personal data when telemetry data iscollected.

5.11

Make it easy for users to delete user data

Provision 5.11-1 The user shall be provided with functionality such that user data can be erased from the device in a
simple manner.
NOTE 1: User data in this context means all individual data which is stored on the IoT device including personaldata, user configuration and cryptographic material such as user passwords or keys.
Provision 5.11-2 The consumer should be provided with functionality on the device such that personal data can beremoved from associated services in a simple manner.
Such functionality is intended for situations when there is a transfer of ownership, when the consumer wishes to delete
personal data, when the consumer wishes to remove a service from the device and/or when the consumer wishes todispose of the device. It is expected that such functionality is compliant to applicable data protection law, including the
GDPR [i.7].
Removing personal data "easily" means that minimal steps are required to complete that action that each involve
minimal complexity.
Such functionality can potentially present an attack vector.
Provision 5.11-3 Users should be given clear instructions on how to delete their personal data.
Provision 5.11-4 Users should be provided with clear confirmation that personal data has been deleted from services,
devices and applications.
Consumer IoT devices often change ownership and will eventually be recycled or disposed of. Mechanisms can beprovided that allow the consumer to remain in control and remove personal data from services, devices andapplications. When a consumer wishes to completely remove their personal data, they also expect retrospective deletionof backup copies.
Deleting personal data from a device or service is often not simply achieved by resetting a device back to its factory
default state. There are many use cases where the consumer is not the owner of a device, but wishes to delete their own
personal data from the device and all associated services such as cloud services or mobile applications.
EXAMPLE:A user can have temporary usage of consumer IoT products within a rented apartment. Carryingout a factory reset of the product can remove configuration settings or disable the device to thedetriment of the apartment owner and a future user. A factory reset, deleting all data from the IoT
device, would not be an appropriate way to delete the personal data of a single user in a shared use
context such as this.

NOTE 2: Annex A of the present document contains an example model of device states including data storage foreach state.

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5.12

ETSI EN 303 645 V2.1.1 (2020-06)

Make installation and maintenance of devices easy

Provision 5.12-1 Installation and maintenance of consumer IoT should involve minimal decisions by the user andshould follow security best practice on usability.
EXAMPLE:The user uses a wizard to setup the device where a subset of configuration options is presented
with the common defaults already specified and with appropriate security options already turnedon by default.

Provision 5.12-2 The manufacturer should provide users with guidance on how to securely set up their device.
However, the ideal is for a process that involves the minimum of human intervention and which achieves a secure
configuration automatically.
Provision 5.12-3 The manufacturer should provide users with guidance on how to check whether their device issecurely set up.
Security issues caused by consumer confusion or misconfiguration can be reduced and sometimes eliminated byproperly addressing complexity and poor design in user interfaces. Clear guidance to users on how to configure devices
securely can also reduce their exposure to threats.
In the general case, the average overhead of securely setting up a device is higher than the average overhead ofchecking whether a device is securely setup. The check of a secure setup, from a process standpoint, can be undertaken
in large part by the manufacturer through an automated process that communicates with the device remotely. Part ofsuch an automated process could include validation of the device's capacity to establish a secure communication
channel.

5.13

Validate input data

Provision 5.13-1 The consumer IoT device software shall validate data input via user interfaces or transferred via
Application Programming Interfaces (APIs) or between networks in services and devices.
Systems can be subverted by incorrectly formatted data or code transferred across different types of interface.
Automated tools such as fuzzers can be used by attackers or testers to exploit potential gaps and weaknesses thatemerge as a result of not validating data.

6

EXAMPLE 1:

The device receives data that is not of the expected type, for example executable code rather thanuser inputted text. The software on the device has been written so that the input is parameterized or"escaped", preventing this code from being run.

EXAMPLE 2:

Out of range data is received by a temperature sensor, rather than trying to process this input it
identifies that it is outside of the possible bounds and is discarded and the event is captured intelemetry.

Data protection provisions for consumer IoT

Many consumer IoT devices process personal data. It is expected that manufacturers provide features within consumer
IoT devices that support the protection of such personal data. In addition, there exist laws and regulations that relate to
the protection of personal data in consumer IoT devices (for example the GDPR [i.7]). The present document intends tohelp manufacturers of consumer IoT devices provide a number of features for the protection of personal data from astrictly technical perspective.
Provision 6-1 The manufacturer shall provide consumers with clear and transparent information about what personal
data is processed, how it is being used, by whom, and for what purposes, for each device and service. This also applies
to third parties that can be involved, including advertisers.
Provision 6-2 Where personal data is processed on the basis of consumers' consent, this consent shall be obtained in avalid way.
Obtaining consent "in a valid way" normally involves giving consumers a free, obvious and explicit opt-in choice of
whether their personal data can be used for a specified purpose.

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Provision 6-3 Consumers who gave consent for the processing of their personal data shall have the capability towithdraw it at any time.
Consumers expect to be able to preserve their privacy by configuring IoT device and service functionality appropriately.
Provision 6-4 If telemetry data is collected from consumer IoT devices and services, the processing of personal data
should be kept to the minimum necessary for the intended functionality.
Provision 6-5 If telemetry data is collected from consumer IoT devices and services, consumers shall be provided withinformation on what telemetry data is collected, how it is being used, by whom, and for what purposes.

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Annex A (informative):
Basic concepts and models
A.1

Architecture

A consumer IoT device is a collection of hardware and software components, generally with physical interfaces which
can also be network interfaces. A general example and a specific "Smart Speaker" sophisticated example are shown
below in figure A.1. These architectures are informative and it is not expected that a device would have all or some of
the components pictured.

Figure A.1: Examples of a general architecture of a device and of an architecture for a Smart Speaker
Consumer IoT deployed in the home will often consist of a variety of both constrained and non-constrained devices thatwill be connected to the LAN, either directly through IP connectivity, such as over Ethernet or Wi-Fi®, or indirectly via
a gateway or hub. This indirect connection to the LAN will generally use non-IP connectivity (e.g. protocols based onIEEE 802.15.4 [i.24]). A router will then connect the LAN to the WAN (i.e. the Internet). In some cases, however, adevice within the home can connect directly to the WAN over other non-IP or IP connections (such as GSM or
LoRaWAN).

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ETSI EN 303 645 V2.1.1 (2020-06)

Consumer IoT devices in the home will often connect outwards to (or be connected into by) online or local services. In
the present document those that are included by the manufacturer (for example telemetry, or a companion mobile
application) or that have to be installed as part of the initialization are classed as associated services - in cases where theuser chooses to install a service, or access external content then these would not count as associated services. For
example, some scenarios:•

websites accessed via a device's browser are likely to not be associated services as the user is deciding toaccess them, not the developer of the device software;•

software applications (such as an "app" that might be installed on a Smart TV) that run on a device; if they are
installed by default, then they would generally be classified as associated services. If, however, they are
installed through a store at the choice of the user, then they would not be associated;•connecting to a telemetry platform would be an associated service as this is usually pre-configured by thedevice manufacturer.

Figure A.2 provides an example of an architecture for this model of deployment. The "home" boundary represents theapproximate extent of the scope defined for the present document - including communication to associated services.

Figure A.2: Example of a reference architecture for consumer IoT deployment in a home environment
Figure A.3 shows an example, realistic, deployment of consumer IoT within a home. The following use-cases illustrate
how this setup would be used and clarify what would and would not be covered under definitions:•

The Smart TV communicates with two external services. The first is the Device Telemetry Service (anassociated service); this captures, with user permission, information from the TV such as crash logs and dataon usage to enable the developers to fix software defects and prioritize development of new functionality. The
Smart TV also connects to a Video Sharing Service through an application downloaded by the user after
initialization. This Video Sharing Service enables a user to watch entertainment via a third-party application,
which is installable within the operating system used by the TV. This streaming service would not be an
associated service.

•

The Gateway provides access to a variety of constrained devices, including an IEEE 802.15.4 [i.24] meshnetwork and a Light Sensor, used to monitor and manage the home. It connects to a Cloud Access Service thatenables the user to control their Smart Lock remotely and see data from sensors. This is an associated service.

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ETSI EN 303 645 V2.1.1 (2020-06)•

The Smart Fridge has a web browser installed; this allows the user to view headlines from a news website
while nearby. The news website would not be an associated service.

•

The Weather Sensor is used by the user to check the temperature outside their home. As it is physically remotefrom the home itself it is unable to connect to the LAN. Instead it communicates via GSM directly to the
WAN. The service the Weather Sensor connects to is an associated service.

Figure A.3: Example architecture of a consumer IoT deployment

A.2

Device states

Decommissioning devices is out of scope of the present document. A decommissioned device is in a state where
sensitive data is not present. A device (from manufacturing to decommissioning) will transition between several states.
These transitions are illustrated in figure A.4, to make clear how the defined states could be used in a device. In thismodel, a decommissioned device would be in the Factory Default state, as the Factory Reset process is likely to be theprocess used to remove all user data and configuration.
EXAMPLE:When decommissioned, a device can be recycled, resold or destroyed.

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Figure A.4: State diagram for consumer IoT device states
Within these states, figure A.5 shows an example model for what data would be stored within an arbitrary device. It is
not expected that this would be the same for every case.

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ETSI EN 303 645 V2.1.1 (2020-06)

Figure A.5: Model of example device storage in states

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Annex B (informative):
Implementation conformance statement pro forma
Notwithstanding the provisions of the copyright clause related to the text of the present document, ETSI grants thatusers of the present document can freely reproduce the pro forma in the present annex so that it can be used for its
intended purposes and can further publish the completed annex including table B.1.
Table B.1 can provide a mechanism for the user of the present document (who is expected to be an entity involved in
the development or manufacturing of consumer IoT) to give information about the implementation of the provisions
within the present document.
The reference column gives reference to the provisions in the present document.
The status column indicates the status of a provision. The following notations are used:M

the provision is a mandatory requirementRthe provision is a recommendationMC

the provision is a mandatory requirement and conditionalRC

the provision is a recommendation and conditional

NOTE:

Where the conditional notation is used, this is conditional on the text of the provision. The conditions areprovided at the bottom of the table with references provided for the relevant provisions to help withclarity.

The support column can be filled in by the user of the present document. The following notations are used:Y

supported by the implementationN

not supported by the implementation

N/A

the provision is not applicable (allowed only if a provision is conditional as indicated in the status
column and if it has been determined that the condition does not apply for the product in question)

The detail column can be filled in by the user of the present document:•

If a provision is supported by the implementation, the entry in the detail column is to contain information on
the measures that have been implemented to achieve support.

•

If a provision is not supported by the implementation, the entry in the detail column is to contain informationon the reasons why implementation is not possible or not appropriate.

•

If a provision is not applicable, the entry in the detail column is to contain the rationale for this determination.

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Table B.1: Implementation of provisions for consumer IoT security
Clause number and title
Reference
StatusSupportDetail
5.1 No universal default passwords
Provision 5.1-1
M C (1)
Provision 5.1-2
M C (2)
Provision 5.1-3
M
Provision 5.1-4
M C (8)Provision 5.1-5
M C (5)
5.2 Implement a means to manage reports of vulnerabilities
Provision 5.2-1
MProvision 5.2-2
RProvision 5.2-3
R
5.3 Keep software updated
Provision 5.3-1
R
Provision 5.3-2
M C (5)
Provision 5.3-3
M C (12)
Provision 5.3-4
R C (12)
Provision 5.3-5
R C (12)
Provision 5.3-6
R C (9, 12)
Provision 5.3-7
M C (12)
Provision 5.3-8
M C (12)
Provision 5.3-9
R C (12)
Provision 5.3-10
M (11, 12)
Provision 5.3-11
R C (12)
Provision 5.3-12
R C (12)
Provision 5.3-13
M
Provision 5.3-14
R C (3, 4)
Provision 5.3-15
R C (3, 4)
Provision 5.3-16
M
5.4 Securely store sensitive security parameters
Provision 5.4-1
M
Provision 5.4-2
M C (10)
Provision 5.4-3
M
Provision 5.4-4
M
5.5 Communicate securely
Provision 5.5-1
MProvision 5.5-2
RProvision 5.5-3
R
Provision 5.5-4
R
Provision 5.5-5
MProvision 5.5-6
R
Provision 5.5-7
M
Provision 5.5-8
M
5.6 Minimize exposed attack surfaces
Provision 5.6-1
MProvision 5.6-2
MProvision 5.6-3
R
Provision 5.6-4
M C (13)
Provision 5.6-5R
Provision 5.6-6
R
Provision 5.6-7
R
Provision 5.6-8
R
Provision 5.6-9
R
5.7 Ensure software integrity
Provision 5.7-1
RProvision 5.7-2
R
5.8 Ensure that personal data is secure
Provision 5.8-1
RProvision 5.8-2
MProvision 5.8-3
M

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Clause number and title
Reference
StatusSupportDetail5.9 Make systems resilient to outages
Provision 5.9-1
RProvision 5.9-2
RProvision 5.9-3
R
5.10 Examine system telemetry data
Provision 5.10-1
R C (6)
5.11 Make it easy for users to delete user data
Provision 5.11-1
M
Provision 5.11-2
R
Provision 5.11-3
R
Provision 5.11-4
R
5.12 Make installation and maintenance of devices easy
Provision 5.12-1
R
Provision 5.12-2
R
Provision 5.12-3
R
5.13 Validate input data
Provision 5.13-1
M
6 Data protection provisions for consumer IoT
Provision 6.1
M
Provision 6.2
M C (7)
Provision 6.3
M
Provision 6.4
R C (6)
Provision 6.5
M C (6)
Conditions
1) passwords are used;
2) pre-installed passwords are used;
3) software components are not updateable;
4) the device is constrained;5) the device is not constrained;
6) telemetry data being collected;7) personal data is processed on the basis of consumers' consent;8) the device allowing user authentication;9) the device supports automatic updates and/or update notifications;10) a hard-coded unique per device identity is used for security purposes;
11) updates are delivered over a network interface;12) an update mechanism is implemented;13) a debug interface is physically accessible.

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History
Document history
V1.1.1February 2019

Publication as ETSI TS 103 645

V2.0.0November 2019

EN Approval Procedure

AP 20200224: 2019-11-26 to 2020-02-24

V2.1.0April 2020

Vote

V 20200619:

V2.1.1

June 2020

Publication

ETSI

2020-04-20 to 2020-06-19