How does the UKs PSTI compare with the EUs Cyber Resilience Act?

Year on year cyber-attacks are on the rise and digital products with low security are prime targets for attack. A high-profile example from this year is Badbox 2.0, a large scale malware operation that has infected more than 1 million android TV devices.1,2 The Badbox 2.0 malware is installed during the manufacturing process in many cases due to low supply chain security. The infected devices become part of a botnet which is used to launch thousands of attacks and further infect other devices. The UK government and the European Union have outlined that cybersecurity for digital products is an area where increased regulation is needed. The UK Product Security and Telecommunications Act (PSTI) and the EU Cyber Resilience Act (CRA) aim to address low security standards for digital products and ensure users better understand the security features of devices they own.