ETSI TR 103 621 V1.2.1 (2022-09)

Guide to Cyber Security for Consumer Internet of Things

RTR/CYBER-0084

General Information

• Status: Not Published
• Technical Committee: CYBER - Cyber Security
• Current Stage: 12 - Completion
• Due Date: 19-Sep-2022
• Completion Date: 06-Sep-2022

Standards Content (Sample)

TECHNICAL REPORT
Guide to Cyber Security for Consumer Internet of Things

2 ETSI TR 103 621 V1.2.1 (2022-09)

Reference
RTR/CYBER-0084
Keywords
cybersecurity, IoT
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ETSI
3 ETSI TR 103 621 V1.2.1 (2022-09)
Contents
Intellectual Property Rights . 6
Foreword . 6
Modal verbs terminology . 6
Introduction . 6
1 Scope . 7
2 References . 7
2.1 Normative references . 7
2.2 Informative references . 7
3 Definition of terms, symbols and abbreviations . 9
3.1 Terms . 9
3.2 Symbols . 9
3.3 Abbreviations . 9
4 Using the present document . 10
4.1 Purpose . 10
4.2 Relationship to ETSI EN 303 645 . 10
4.3 Relationship to ETSI TS 103 701 . 10
5 Guidance on implementation . 10
6 Examples to meet cyber security provisions for consumer IoT . 11
6.1 Provision 5.1-1 . 11
6.2 Provision 5.1-2 . 12
6.3 Provision 5.1-3 . 12
6.4 Provision 5.1-4 . 13
6.5 Provision 5.1-5 . 14
6.6 Provision 5.2-1 . 14
6.7 Provision 5.2-2 . 14
6.8 Provision 5.2-3 . 15
6.9 Provision 5.3-1 . 15
6.10 Provision 5.3-2 . 15
6.11 Provision 5.3-3 . 15
6.12 Provision 5.3-4 . 16
6.13 Provision 5.3-5 . 16
6.14 Provision 5.3-6 . 16
6.15 Provision 5.3-7 . 16
6.16 Provision 5.3-8 . 17
6.17 Provision 5.3-9 . 17
6.18 Provision 5.3-10 . 17
6.19 Provision 5.3-11 . 18
6.20 Provision 5.3-12 . 19
6.21 Provision 5.3-13 . 19
6.22 Provision 5.3-14 . 19
6.23 Provision 5.3-15 . 19
6.24 Provision 5.3-16 . 19
6.25 Provision 5.4-1 . 20
6.26 Provision 5.4-2 . 20
6.27 Provision 5.4-3 . 21
6.28 Provision 5.4-4 . 21
6.29 Provision 5.5-1 . 21
6.30 Provision 5.5-2 . 22
6.31 Provision 5.5-3 . 23
6.32 Provision 5.5-4 . 23
6.33 Provision 5.5-5 . 23
6.34 Provision 5.5-6 . 23
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4 ETSI TR 103 621 V1.2.1 (2022-09)
6.35 Provision 5.5-7 . 24
6.36 Provision 5.5-8 . 24
6.37 Provision 5.6-1 . 24
6.38 Provision 5.6-2 . 25
6.39 Provision 5.6-3 . 25
6.40 Provision 5.6-4 . 25
6.41 Provision 5.6-5 . 25
6.42 Provision 5.6-6 . 26
6.43 Provision 5.6-7 . 26
6.44 Provision 5.6-8 . 26
6.45 Provision 5.6-9 . 27
6.46 Provision 5.7-1 . 27
6.47 Provision 5.7-2 . 27
6.48 Provision 5.8-1 . 27
6.49 Provision 5.8-2 . 28
6.50 Provision 5.8-3 . 28
6.51 Provision 5.9-1 . 28
6.52 Provision 5.9-2 . 29
6.53 Provision 5.9-3 . 29
6.54 Provision 5.10-1 . 29
6.55 Provision 5.11-1 . 30
6.56 Provision 5.11-2 . 30
6.57 Provision 5.11-3 . 30
6.58 Provision 5.11-4 . 30
6.59 Provision 5.12-1 . 31
6.60 Provision 5.12-2 . 31
6.61 Provision 5.12-3 . 31
6.62 Provision 5.13-1 . 32
7 Examples to meet data protection provisions for consumer IoT . 32
7.1 Provision 6-1 . 32
7.2 Provision 6-2 . 33
7.3 Provision 6-3 . 33
7.4 Provision 6-4 . 33
7.5 Provision 6-5 . 33
8 Handling of recommendations . 33
8.1 Status of recommendations in ETSI EN 303 645 . 33
8.2 Example situations where recommendations cannot be followed . 34
8.2.1 Provision 5.2-2 . 34
8.2.2 Provision 5.2-3 . 34
8.2.3 Provision 5.3-1 . 34
8.2.4 Provision 5.3-4 . 34
8.2.5 Provision 5.3-5 . 34
8.2.6 Provision 5.3-6 . 34
8.2.7 Provision 5.3-9 . 35
8.2.8 Provision 5.3-11 . 35
8.2.9 Provision 5.3-12 . 35
8.2.10 Provision 5.3-14 . 35
8.2.11 Provision 5.3-15 . 35
8.2.12 Provision 5.5-2 . 35
8.2.13 Provision 5.5-3 . 36
8.2.14 Provision 5.5-4 . 36
8.2.15 Provision 5.5-6 . 36
8.2.16 Provision 5.6-3 . 36
8.2.17 Provision 5.6-5 . 36
8.2.18 Provision 5.6-6 . 36
8.2.19 Provision 5.6-7 . 37
8.2.20 Provision 5.6-8 . 37
8.2.21 Provision 5.6-9 . 37
8.2.22 Provision 5.7-1 . 37
8.2.23 Provision 5.7-2 . 37
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5 ETSI TR 103 621 V1.2.1 (2022-09)
8.2.24 Provision 5.8-1 . 37
8.2.25 Provision 5.9-1 . 37
8.2.26 Provision 5.9-2 . 38
8.2.27 Provision 5.9-3 . 38
8.2.28 Provision 5.10-1 . 38
8.2.29 Provision 5.11-2 . 38
8.2.30 Provision 5.11-3 . 38
8.2.31 Provision 5.11-4 . 38
8.2.32 Provision 5.12-1 . 38
8.2.33 Provision 5.12-2 . 38
8.2.34 Provision 5.12-3 . 39
8.2.35 Provision 6-4 . 39
History . 40

ETSI
6 ETSI TR 103 621 V1.2.1 (2022-09)
Intellectual Property Rights
Essential patents
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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 Directives including the ETSI IPR Policy, no investigation regarding the essentiality of IPRs,
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.
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BLUETOOTH is a trademark registered and owned by Bluetooth SIG, Inc.
Foreword
This Technical Report (TR) has been produced by ETSI Technical Committee Cyber Security (CYBER).
Modal verbs terminology
In the present document "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 of provisions).
"must" and "must not" are NOT allowed in ETSI deliverables except when used in direct citation.
Introduction
The growth of the Internet of Things has spurred the development of security requirements for IoT devices. ETSI
EN 303 645 [i.1] provides baseline cyber security provisions for a wide range of Consumer IoT products and remains
outcome focused. While ETSI TS 103 701 [i.3] deals with the assessment of conformance of IoT products against the
provisions of ETSI EN 303 645 [i.1], the present document has been developed to guide manufacturers on its
implementation, by providing non-exhaustive examples of practical solutions that can be used to meet these provisions.
Additionally, the examples provided herein are not limitative; it is possible to meet the provisions in ETSI
EN 303 645 [i.1] by using other solutions.

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7 ETSI TR 103 621 V1.2.1 (2022-09)
1 Scope
The present document serves as guidance to help manufacturers and other stakeholders in meeting the cyber security
provisions defined for Consumer IoT devices in ETSI EN 303 645 [i.1] and ETSI TS 103 645 [i.2].
The present document is complementary to ETSI EN 303 645 [i.1] and ETSI TS 103 701 [i.3]. It explains the
relationship between these specifications and how they can be used together. It also provides a non-exhaustive set of
example implementations that can be used to meet the provisions of ETSI EN 303 645 [i.1] and ETSI TS 103 645 [i.2],
noting that not all possible implementations are included. Where relevant, pointers to supporting specifications are
provided. Usage by industry players as well as future development of standards, such as specialisation into precise use
cases, or certification aspects, are being given consideration.
2 References
2.1 Normative references
Normative references are not applicable in the present document.
2.2 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 the
referenced 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 the
user with regard to a particular subject area.
[i.1] ETSI EN 303 645 (V2.1.1): "CYBER; Cyber Security for Consumer Internet of Things: Baseline
Requirements".
[i.2] ETSI TS 103 645 (V2.1.2): "CYBER; Cyber Security for Consumer Internet of Things: Baseline
Requirements".
NOTE: The technical content of ETSI TS 103 645 (V2.1.2) is exactly the same as in ETSI EN 303 645 (V2.1.1).
[i.3] ETSI TS 103 701 (V1.1.1): "CYBER; Cyber Security for Consumer Internet of Things:
Conformance Assessment of Baseline Requirements".
[i.4] IETF RFC 5246: "The Transport Layer Security (TLS) Protocol Version 1.2".
[i.5] IETF RFC 6347: "Datagram Transport Layer Security Version 1.2".
[i.6] GNU Bison.
NOTE: Available at https://www.gnu.org/software/bison/. ®
[i.7] W3C Recommendation: "W3C XML Schema Definition Language (XSD) 1.1 Part 1: Structures".
NOTE: Available at https://www.w3.org/TR/xmlschema11-1/.
[i.8] JSON Schema.
NOTE: Available at https://json-schema.org/.
[i.9] Article 29 Working Party: "Guidelines on transparency under Regulation 2016/679".
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8 ETSI TR 103 621 V1.2.1 (2022-09)
[i.10] Article 29 Working Party: "Guidelines on consent under Regulation 2016/679".
NOTE: Available at https://edpb.europa.eu.
[i.11] IETF RFC 1034: "DOMAIN NAMES - CONCEPTS AND FACILITIES".
[i.12] Microsoft™ SDL: "Security Development Lifecycle".
NOTE: Available at https://www.microsoft.com/sdl.
[i.13] ISO/IEC 27034-3: "Information technology -- Application security -- Part 3: Application security
management process".
[i.14] ISO/IEC 29147: "Information technology -- Security techniques -- Vulnerability disclosure".
[i.15] IETF RFC 5246: "The Transport Layer Security (TLS) Protocol Version 1.2".
[i.16] IETF RFC 7516: "JSON Web Encryption (JWE)".
[i.17] ETSI TR 103 838: "Cyber security; Guide to Coordinated Vulnerability Disclosure".
[i.18] IoT Security Foundation: "Vulnerability Disclosure Best Practice Guidelines".
NOTE: Available at https://www.iotsecurityfoundation.org/best-practice-guidelines/. ®
[i.19] HackerOne , vulnerability disclosure service.
NOTE: Available at https://www.hackerone.com/.
[i.20] NCSC: "Setting up two-factor authentication (2FA)".
NOTE: Available at https://www.ncsc.gov.uk/guidance/setting-two-factor-authentication-2fa.
[i.21] NCSC: "Secure development and deployment guidance".
NOTE: Available at https://www.ncsc.gov.uk/collection/developers-collection.
[i.22] ETSI TS 119 312: "Electronic Signatures and Infrastructures (ESI); Cryptographic Suites".
[i.23] NIST SP800-90A: ''Recommendation for Random Number Generation Using Deterministic
Random Bit Generators''.
[i.24] AIS 20/31: ''A proposal for: Functionality classes for random number generators''.
[i.25] ANSI/ISA-62443: ''Security for industrial automation and control systems''.
[i.26] IETF RFC 7235: "Hypertext Transfer Protocol (HTTP/1.1): Authentication".
[i.27] IEEE 802.11w™-2009: "IEEE Standard for Information technology - Telecommunications and
information exchange between systems - Local and metropolitan area networks - Specific
requirements. Part 11: Wireless LAN Medium Access Control (MAC) and Physical Layer (PHY)
Specifications Amendment 4: Protected Management Frames".
[i.28] IEEE 802.11i™-2004: "IEEE Standard for information technology-Telecommunications and
information exchange between systems-Local and metropolitan area networks-Specific
requirements-Part 11: Wireless LAN Medium Access Control (MAC) and Physical Layer (PHY)
specifications: Amendment 6: Medium Access Control (MAC) Security Enhancements".
[i.29] IETF RFC 6238: "TOTP: Time-Based One-Time Password Algorithm".
[i.30] Directive (EU) 2019/770 of the European Parliament and of the Council of 20 May 2019 on
certain aspects concerning contracts for the supply of digital content and digital services.
NOTE: Available at https://eur-lex.europa.eu/.
[i.31] Mayhew, Joe, and Hamid Jahankhani: "Current Challenges of Modern-Day Domestic Abuse",
Policing in the Era of AI and Smart Societies. Springer, Cham, 2020. 267-282.
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9 ETSI TR 103 621 V1.2.1 (2022-09)
[i.32] Datta Burton, S. et al.: "The UK Code of Practice for Consumer IoT Cybersecurity: where we are
and what next" (2021).
[i.33] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free
movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
[i.34] FIPS PUB 140-2 (2001): "Security Requirements for Cryptographic Modules".
3 Definition of terms, symbols and abbreviations
3.1 Terms
For the purposes of the present document, the terms given in ETSI EN 303 645 [i.1] apply.
3.2 Symbols
Void.
3.3 Abbreviations
For the purposes of the present document, the abbreviations given in ETSI EN 303 645 [i.1] and the following apply:
ACM Agreed Cryptographic Mechanisms
AES Advanced Encryption Standard
AIS Application notes and Interpretation of the Scheme
ANSI American National Standards Institute
ARM Advanced RISC Machine ®
BLE Bluetooth Low Energy
CBC Cipher Block Chaining
CCM Counter with CBC-MAC
CPU Central Processing Unit
CSA Coordination and Support Action
CSPRNG Cryptographically Secure Pseudorandom Number Generator
DNS Domain Name System
DTLS Datagram Transport Layer Security
ECDH Elliptic Curve Diffie-Hellman
ECDHE Elliptic Curve Diffie-Hellman Ephemeral
ECDSA Elliptic Curve Digital Signature Algorithm
ECRYPT European Network of Excellence for Cryptology
EN European Standard
FAQ Frequently Asked Question
FIPS Federal Information Processing Standards
GCM Galois/Counter Mode
GHz GigaHertz
HTTP Hypertext Transfer Protocol
IEC International Electrotechnical Commission
IETF Internet Engineering Task Force
IoT Internet of Things
ISA International Society of Automation
IV Initialization Vector
JSON JavaScript Object Notation
KDF Key Derivation Function
MAC Message Authentication Code
PIN Personal Identification Number
PKI Public Key Infrastructure
PSK Pre-Shared Key
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10 ETSI TR 103 621 V1.2.1 (2022-09)
RAM Random-Access Memory
RFC Request for Comments
RSA Rivest, Shamir and Adleman
SAE Simultaneous Authentication of Equals
SHA Securing Hash Algorithm
SMS Short Message Service
SOGIS Senior Officials Group on Information Security
TOTP Time-based One-Time-Password
TPM Trusted Platform Module
WAN Wide Area Network
WLAN Wireless LAN ®
WPA Wi-Fi Protected Access
XOR exclusive OR
XTS XOR-Encrypt-XOR-Based Tweaked-Codebook Mode with Ciphertext Stealing
4 Using the present document
4.1 Purpose
The present document provides guidance to implement the provisions in ETSI EN 303 645 [i.1] in the form of examples
illustrating possible solutions. The intent is to help implementers better understand how each provision can be met. It is
reminded that ETSI EN 303 645 [i.1] and ETSI TS 103 645 [i.2] both provide guidance text and examples. These can
be referred to when considering the examples provided herein. These examples are provided in clauses 6 and 7.
In ETSI EN 303 645 [i.1] and ETSI TS 103 645 [i.2] recommendations are expected to be followed by manufacturers
unless there exists a justification for not doing so. Examples of situation where it might be difficult to follow a given
recommendation are provided in clause 8.
4.2 Relationship to ETSI EN 303 645
The examples provided in the present document are tailored to the outcome-focused nature of ETSI EN 303 645 [i.1]. It
is acknowledged that ETSI EN 303 645 [i.1] can be specialised into more precise domains of applicability, for example
smart locks. In such case, the example solutions to meet the new set of provisions can be better tailored to this specific
IoT domain. It is expected that these examples would be included in an update to the present document, or to a future,
dedicated guidance document.
4.3 Relationship to ETSI TS 103 701
ETSI TS 103 701 [i.3] provides a framework for the assessment of the provisions defined in ETSI EN 303 645 [i.1]. As
such, they can be used (when implemented) to inform the definition of test scenarios and the development of a test plan
based on ETSI TS 103 701 [i.3]. As described in clauses 4.1 and 4.2, a specialisation of ETSI EN 303 645 [i.1] for a
specific application domain can allow more precise examples to be provided which, when implemented, would allow
more precise test scenarios and test plan, leading to stronger certainty on the test expectations and outcomes.
5 Guidance on implementation
Clauses 6 and 7 provide examples for implementing the provisions laid out in ETSI EN 303 645 [i.1]. The examples
provided herein are not exhaustive or limitative; it is possible to meet the provisions in ETSI EN 303 645 [i.1] by using
other solutions or variants of the provided examples.
For each provision, the examples are not given in a specific qualitative order (therefore, example 1 is not necessarily
qualitatively better than example(s) 2 or 3) but are ordered by usage, from the most widely applicable examples to the
more specific ones. While most examples are meant to cover a large spectrum of IoT cases, those that relate to a
specific type of IoT device, constrained device, or a given use case are indicated as such.
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11 ETSI TR 103 621 V1.2.1 (2022-09)
The examples in clauses 6 and 7 of the present document provide guidance on the implementation of cybersecurity
mainly protecting users from unknown other users. However, consumer IoT devices can be misused, e.g. by intimate
partners, which makes it even more difficult to find appropriate security measures.
The following list provides examples of related threats using consumer IoT devices:
• audio control (i.e. recording and/or replying);
• video control (i.e. recording and/or displaying);
• data control (i.e. collection, manipulation, unintended disclosure);
• access to shared accounts linked to the consumer IoT device and therefore providing the possibility for social
stalking (e.g. social media);
• other remote control threats (e.g. heating control, door lock control).
The exploitation of the aforementioned threats might result in coercive control (e.g. isolation from friends and family,
spying, deprivation of vital and basic means such as medical services and food, controlling finances, etc.).
In this regard, the following measures could help to mitigate domestic abuse by using consumer IoT devices [i.31]:
• introduction of legal policy to prosecute abusers and protect victims of domestic abuse in cases of digital
coercive control;
• development of technology that at least provides evidence of activity in cases of domestic abuse, however,
without violating data protection/privacy regulations;
• creation of awareness to improve prevention, and establish contact possibilities in cases of domestic abuse to
support the victims by providing appropriate advice.
Privacy and data protection related legislation only cover a small part of the first of the aforementioned measures as
requirements are set against personal data in terms of transparency in processing as well as purpose limitation, accuracy,
integrity and confidentiality.
The second item referring to technology depends on the specific application scenario and can be considered during the
development of corresponding solutions or verticals based on ETSI EN 303 645 [i.1] appropriate to the properties of the
technology, risk, benefit and usage. Designing ways to prevent the misuse of the device intends to mitigate the risk of
its misuse, but it is understood that it might not eliminate the risk entirely.
The item regarding awareness can be realized by training and by reaching out to all stakeholders of consumer IoT
products, for instance by advertisements or by including the domestic abuse matter into guidelines as in the present
document.
NOTE: The UK Code of Practice for Consumer IoT Security [i.32] provides statistics and references to the
current state of the art regarding research in consumer IoT tech abuse. It also references to industry actors
providing guidelines to prevent that technology is being used for domestic abuse.
6 Examples to meet cyber security provisions for
consumer IoT
6.1 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". (ETSI EN 303 645 [i.1])
NOTE 1: An example for this provision is also provided in ETSI EN 303 645 [i.1].
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12 ETSI TR 103 621 V1.2.1 (2022-09)
EXAMPLE 1: The consumer IoT device password for the factory default state is printed on a sticker under the
device casing. During the initialization phase, the user is requested to provide a new password and
the procedure cannot complete without the new password being different from the default state
password.
EXAMPLE 2: The consumer IoT device has no password in the factory default state and generates a password for
the user during the initialization phase. The device is not constrained and the password generation
process is based on a cryptographically secure pseudorandom number generator where the entropy
source is an on-device ring oscillator.
NOTE 2: For simpler and constrained devices, a less advanced MCU does not provide the same cryptographic
acceleration and entropy.
EXAMPLE 3: The consumer IoT device prompts a user to create a password, choosing any complexity
requirements such that a user can create a memorable password with a strength appropriate to the
device's capabilities and the security necessary for the application.
6.2 Provision 5.1-2
"Where pre-installed unique per device passwords are used, these shall be generated with a mechanism that reduces the
risk of automated attacks against a class or type of device". (ETSI EN 303 645 [i.1])
NOTE 1: An example for this provision is also provided in ETSI EN 303 645 [i.1].
EXAMPLE 1: The password is generated using a cryptographically secure pseudorandom number generator
present on a chip in the device. The password complexity is such that the password cannot be
guessed through an exhaustive search attack (including optimized variants such as dictionary
attacks) via the quickest authentication method available on the device, at least during its expected
lifetime. The password is concatenated with a per-device salt and hashed. The device uses a
well-known widely implemented hashing algorithm with no known weaknesses, appropriate to the
device's capabilities and the security necessary for the application.
NOTE 2: A guidance on the choice of hashing algorithms is given in ETSI TS 119 312 [i.22].
EXAMPLE 2: The manufacturer generates pre-installed passwords within the factory environment using a critical
security parameter, stored within a hardware security module, concatenated with either the serial
number or MAC address of the device. The resultant string is hashed and the last 8 bytes,
...