When we developed Part 21 not at least our (and of our customers) opinion was, that the customer will not accept an onboarding mechanism that enables the vendor to prevent the onboarding after the device was bought.

One result of this is our ticket mechanism and the possibility to create tickets on the shipping way that can be used for onboarding.

This is still a valid and a good solution!

But the world moves forward, and not at least the Ukrainian war changed a lot, especially on government site.
So, it’s more likely to occur, that governments or others demand the possibility for vendors to disable devices after they are shipped. E.G. The device shows up in a country where this device is not allowed to be.

Mechanisms to do that are already inside BRSKI for example.

So, I propose to add an optional mechanism to Part 21 that can be used by vendors to enforce the disabling of the onboarding of the device or to withdraw the allowance of the onboarding after the onboarding. Something like adding an optional MASA to our mechanisms.
For the first part, I think we can enrich the ticket check mechanism in the device to solve that. For the second part I have no idea in the moment, but I guess it’s worse to think about.

All of that is to be prepared when these new requirements will show up in future.

We should start this discussion in the security working group.