Do Keyboards and Mice Need to Comply with EN 18031?

Whether keyboards and mice must comply with the en 18031 standard depends on their specific functional design, connectivity type, and whether they involve sensitive data processing. Below is a comprehensive analysis:

Applicability Assessment

1. Wireless Keyboards/Mice (Bluetooth, Wi-Fi, 2.4G, etc.):

- Classified as radio equipment (under red directive).

- If equipped with networking capabilities (e.g., via receiver or Bluetooth connected to the internet), they must comply with EN 18031-1 cybersecurity requirements, including:

- Protection against network attacks (e.g., DDoS defense)

- Secure update mechanisms

- Key management

2. Wired Keyboards/Mice:

- Do not rely on radio communication

- Not subject to EN 18031

Applicability of EN 18031-2 / EN 18031-3

1. EN 18031-2 (Privacy & Data Protection):

Applicable only if the device processes personal data, such as:

- Keyboard with built-in biometrics (fingerprint or facial recognition storing user information)

- Mouse/keyboard recording behavioral data (e.g., macro programming storing usage habits) and uploading to the cloud

- Ordinary keyboards/mice without such functions are exempt

2. EN 18031-3 (Financial Security):

- Applicable only to devices supporting payment or cryptocurrency transactions (e.g., keyboard with integrated NFC payment)

- Ordinary keyboards/mice are exempt

Special Cases Requiring Third-Party (NB) Certification

Wireless keyboards/mice must undergo Notified Body (NB) certification if they include:

- Password-free usage:e.g., Bluetooth pairing without authentication

- Child-focused design:e.g., cartoon-themed devices without parental controls

Implementation Recommendations

1. Testing Priorities:

- Validate encryption of wireless communications (e.g., AES-128)

- Verify signed firmware updates

- Ensure resistance against brute-force pairing attacks

2. Timeline:

- Certification must be completed before August 1, 2025, otherwise the product cannot be marketed in the EU

3. Exemptions:

- Devices with USB wired connection onlyrequire no EN 18031 compliance investment

1. Ordinary Wireless Keyboards/Mice:Must comply with EN 18031-1; self-declaration is acceptable.

2. Biometric/Children-Oriented Wireless Keyboards/Mice:Must additionally comply with EN 18031-2and may require NB certification.

3. Wired Keyboards/Mice:Not applicable under EN 18031.

Recommendation:

Manufacturers should select the compliance path based on product functions, and prioritize disabling password-free pairing options to simplify certification.