U.S. California SB-327 — Security of Connected Devices

Overview

CaliforniaSB-327, also known as the Security of Connected Devices law, is astate regulation that establishes baseline cybersecurity requirementsfor manufacturers of internet-connected devices sold in California.The law aims to improve consumer protection and data security bymandating reasonable security features in connected products.

Enacted by theCalifornia State Legislature and effective since January 2020, SB-327applies to any manufacturer of devices capable of connecting to theinternet, including smart home technology, IoT devices, and networkedappliances. Its primary focus areas include device authentication,password management, and safeguards against unauthorized access,supporting broader privacy and cybersecurity compliance obligations.

Organizationsimplement SB-327 by integrating secure-by-default configurations,enforcing unique device credentials, and integrating cybersecuritycontrols into product development lifecycles. The regulationcomplements existing data protection laws and guides manufacturers inenhancing compliance programs, conducting risk assessments, anddemonstrating operational security for connected devices.

Why it Matters

CaliforniaSB-327 establishes crucial baseline security requirements forconnected devices, helping organizations better protect user data andsystem integrity.

Key benefitsinclude:

•  Support stronger device security oversight

Mandate uniquepreprogrammed passwords or password change at setup, strengtheningoversight of IoT device security practices.

•  Strengthen consumer data protection

Prioritizecontrols to limit unauthorized access and exposure of sensitiveconsumer information collected by connected devices.

•  Enhance regulatory alignment

Alignorganizational device security practices with evolving state-mandatedexpectations, improving compliance posture in complex regulatoryenvironments.

•  Reduce risk of security incidents

Lower thelikelihood of successful attacks and breaches targeting insecuredefault device settings and weak credential management.

•  Increase user and stakeholder trust

Demonstrate aproactive commitment to privacy and security, building confidenceamong customers, partners, and regulatory bodies.

How it Works

U.S. CaliforniaSB-327 — Security of Connected Devices sets regulatory requirementsmandating that manufacturers of connected devices incorporatereasonable security features, such as unique preprogrammed passwordsor mechanisms for users to generate new authentication credentials.The framework is anchored in statutory language, outlining coresafeguards that manufacturers must integrate at the device level,with an emphasis on mitigating common vulnerabilities andunauthorized access risks throughout the product lifecycle.

In practice,organizations apply SB-327 by evaluating device securityarchitectures, updating product development processes, and deployingappropriate security controls prior to market release. Complianceactivities typically involve reviewing authentication mechanisms,documenting changes to default credentials, conducting riskassessments, and monitoring fielded devices for ongoing exposure.Manufacturers may also align internal governance programs andincident response processes to ensure conformity with both state lawand broader industry best practices.

With SmartSuite,organizations can operationalize SB-327 compliance by leveragingcontrol libraries mapped to SB-327 requirements, maintainingdevice-specific risk registers, and managing supporting documentationfor regulatory audits. The platform enables teams to centralizepolicy governance, track compliance status, collect evidence ofsecurity controls, and implement remediation workflows to address anyidentified gaps, supporting comprehensive monitoring and auditreadiness.

Key Elements

•  Device Security Requirements

Establishesminimum security features for connected devices, includingauthentication capability requirements.

•  Reasonable Security Features

Defines criteriafor determining reasonable security measures, considering thedevice’s function and information collected.

•  Authentication Mechanism Standards

Specifiesrequirements for unique preprogrammed passwords or user-generatedauthentication credentials.

•  Manufacturer Obligations

Describesresponsibilities for manufacturers to ensure device security measuresare adequately incorporated during design.

•  Scope and Applicability

Outlines thetypes of devices and use cases covered under the regulation.

•  Harm Prevention Provisions

Providesexpectations for measures to protect users from unauthorized access,destruction, use, modification, or disclosure.

Framework Scope

U.S. CaliforniaSB-327 is adopted by manufacturers of connected devices sold oroffered for sale in California. The framework governs IoT devices andembedded systems, with mandatory security features implemented toprotect against unauthorized access, typically in response toregulatory mandates and to support state-level data protection andcompliance obligations.

Framework Objectives

U.S. CaliforniaSB-327 defines security requirements to protect connected devices andenhance cybersecurity risk management.

•  Safeguard connected devices through the implementation of robustsecurity controls

•  Strengthen cybersecurity governance by establishing clearaccountability for device security

•  Ensure compliance with regulatory mandates for data protectionand privacy

•  Reduce cybersecurity risk associated with unauthorized deviceaccess and data breaches

•  Enhance operational resilience by addressing vulnerabilities inIoT device ecosystems

•  Promote audit readiness by maintaining documented securitymeasures and risk management practices California SB-327 sets minimumsecurity requirements for connected devices and is often referencedalongside frameworks such as NIST Cybersecurity Framework, ISO 27001,and NIST SP 800-53 for IoT security. Organizations implement SB-327to meet regulatory compliance, especially manufacturers anddistributors of consumer IoT products targeting California’smarket.

Common Framework Mappings

CaliforniaSB-327 is often mapped to other privacy, IoT, and cybersecurityframeworks to streamline device security requirements, supportmulti-jurisdictional compliance, and demonstrate a defense-in-depthapproach for connected devices.

Mappedframeworks include:

CIS Controls

COPPA

GDPR

ISO/IEC 27001

ISO/IEC 27002

NISTCybersecurity Framework

NIST SP 800-53

PCI DSS

SOC 2

UL 2900