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104 091
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6.1 SAEM dissemination concept
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104 091
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6.1.1 SA identification
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The component changeCount (see clause 7.1) shall be handled according to ISO 16460 [1]: • saID shall distinguish different service announcement messages presented by the same Service Announcer ITS-S. • contentCount shall identify a change of the content of the announced SA that corresponds to a certain saID. The content of disseminated SAEM with identic saID and contentCount shall be identical for consecutive messages from the same ITS-S. Messages announcing a different set of services shall have a different saID. A change of the application-specific service announcement data shall be indicated by a change of the contentCount.
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6.1.2 SA service trigger, update, repetition and termination
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The SA facilities layer message processing functional block (see figure 1) shall trigger, update or end the dissemination of SAEM according to the parameters received from the management entity via the MF interface (see clause 5.3.2).
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6.2 SAEM dissemination constraints
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6.2.1 Communication requirements
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An SAEM should be disseminated to reach as many ITS-S as possible, located in the Minimum Dissemination Area (MDA). The MDA is provided by the ITS application to the SA service in the dissemination parameter CSP_CommDistance and is typically defined in a way that every receiving ITS-S has received at least once the SAEM before entering the application's relevance area. NOTE: Applications that need different MDA values should not be announced in the same SAEM. This is taken into account by the SA message processing. The SA service shall provide the MDA as destination area to the Networking & Transport layer in the format compliant to the one specified in ETSI TS 103 899 [3]. The communication requirements for the broadcast communication flow shall be as specified in Table 8. The structure of the requirements is in accordance with ISO/TS 17423 [i.4]. ETSI ETSI TS 104 091 V2.1.1 (2025-11) 15 Table 8: SA communication requirements for service announcement Requirement Value Comment Operational communication service parameters CSP_LogicalChannelType service announcement channel Service announcement channel (logical). Mappings of logical channels to physical channels depend on the access technology and the applicable region of operation of the ITS station providing the SA service CSP_SessionCont n.a. No continuous connectivity CSP_AvgADUrate 255, 1 second (default) TimeDurationValue specified in ISO/TS 17423 [i.4] As applicable, indicates the time between start of subsequent SAEM with same saID CSP_FlowType n.a. CSP_MaxPrio ≤ 253 The SA shall use the highest MaxPrio of the ITS application(s) it announces (not exceeding the CSP_MaxPrio) CSP_PortNo Port number of the applicable transport protocol Port number of the applicable transport protocol used to receive/transmit SAEM CSP_ExpFlowLifetime n.a. Destination communication service parameters CSP_DestinationType 1: broadcast transmission CSP_DestinationDomain site-local CSP_CommDistance 400 m radius (default value) Given by MDA CSP_Directivity n.a. Performance communication service parameters CSP_Resilience High Repeated transmission of the same message CSP_MinThP n.a. CSP_MaxLat ms100 (8). See note -- response within less than 100 ms CSP_MaxADU ≤ max message size in Bytes allowed by transport media maximum size of SAEM Security communication service parameters CSP_DataConfidentiality n.a. CSP_DataIntegrity required CSP_NonRepudiation required CSP_SourceAuthentication required Protocol communication service parameter CSP_Protocol n.a. CSP_SpecificCommsProts n.a. NOTE: ms100 (8) is a reference to the parameter choice 'ms100' in ISO/TS 17423 [i.4].
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6.2.2 Security
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6.2.2.1 Introduction
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Clause 6.2.2 is applicable to ITS stations that are part of an ecosystem that uses the trust model according to ETSI TS 102 940 [7] and ITS certificates according to ETSI TS 103 097 [6]. The security mechanisms for ITS consider the authentication of messages transferred between ITS-Ss with certificates. A certificate indicates its holder's permissions, i.e. what statements the holder is allowed to make or privileges it is allowed to assert in a message signed by that certificate. The format for the certificates is specified in ETSI TS 103 097 [6]. Permissions are indicated by a pair of identifiers within the certificate, the ITS-AID and the SSP. The ITS-Application Identifier (ITS-AID) indicates the overall type of permissions being granted: for example, there is an ITS-AID that indicates that the originating ITS-S is entitled to send SAEMs, see ETSI TS 102 965 [2]. The Service Specific Permissions (SSP) is a field that indicates specific sets of permissions within the overall permissions indicated by the ITS-AID: for example, there may be an SSP value associated with the ITS-AID for SAEM that indicates the originating ITS-S is entitled to send SAEMs with an ITS-AID value contained (as defined in clause 7.2). ETSI ETSI TS 104 091 V2.1.1 (2025-11) 16
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6.2.2.2 Service Specific Permissions (SSP)
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SAEM shall be signed using private keys associated to Authorization Tickets of type explicit that contain a pair of: ITS- AID associated to the SA service as specified in ETSI TS 102 965 [2] and SSPs of type BitmapSsp as specified in ETSI TS 103 097 [6]. The BitmapSsp for SAEMs shall conform to the SSPs specified in IEEE 1609.3 [8], encoded using the Unaligned PER encoding scheme as specified in ISO/IEC 8825-2 [5]. The generic security profile as defined in ETSI TS 103 097 [6] shall be applied to SAEM. Additional header field types are not allowed.
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6.2.3 Priority
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Priority information is provided in the PCI across the OSI layers and/or transmitted by lower layers as Traffic Class.
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7 SAEM specification
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7.1 General
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The SA service shall disseminate the SAEM with the format as specified in Annex A. The header component of the SAEM shall be of type ItsPduHeader, as defined in the ETSI TS 102 894-2 [4]: • The protocolVersion component of the header shall be set to value "1" for the present document. • The messageId component of the header shall be set to the value for "SAEM" as defined in ETSI TS 102 894-2 [4]. • The stationId component shall be set to the Station ID of the Service Announcer ITS-S. The sam component of the SAEM shall be of type Sam as specified in ISO 16460 [1]. The samBody component of sam shall include the component changeCount. This component shall be of type SrvAdvChangeCount and shall be handled as defined in clause 6.1.1. If one of the announced services can be consumed using a communication technology, which is different from the one used to disseminate the SAEM, the samBody component of sam shall include the component extensions; the extensions component shall include the extension ExtendedChannelInfos. The component ExtendedChannelInfos may include an entry for each communication technology on which an announced service can be used. NOTE: The SAEM format allows further sam Extension elements and/or Channel Info Extension elements to be defined. For the encoding of the SAEM the Unaligned PER encoding scheme as specified in Recommendation ITU-T X.691 [5] shall be used.
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7.2 Service info component
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The samBody component of sam shall always include the serviceInfos component. This serviceInfos component shall contain at least one element. Each element shall be of type ServiceInfo and contain the following information for a distinct ITS-S service: • Component serviceID shall contain the ITS-AID of the announced ITS-S service as assigned in ETSI TS 102 965 [2]. • Component channelIndex shall contain a pointer to an entry in the channelInfos component (see clause 7.3) applicable to the announced ITS-S service or in the ExtendedChannelInfos extension; In case the optional channelInfos component and the ExtendedChannelInfos extension are not present, the channelIndex component shall be set to zero, as defined in ISO 16460 [1]. ETSI ETSI TS 104 091 V2.1.1 (2025-11) 17 • Component chOptions: - May contain optional Service Info Extensions within the extensions component: The extension SrvOpP-ProtocolStack shall be present and indicate the protocol to be used by the Service User ITS-S for the announced service according to the values defined in Annex B: The extension IPv6Address shall be only present if the extension SrvOpP-ProtocolStack indicates "IPv6", and shall indicate the IP address of the Service Provider ITS-S. When the Service Provider is implemented in a different ITS-S than the Advertiser and forwarding at data link layer is used, the extension ProviderMACaddress shall be present and indicate the MAC address of the Provider ITS-S. The extension SAMapplicationData contains application specific announcement data. - The subcomponents systemService and serviceProviderPort shall not be used for consistency with IEEE 1609.3 [8]. NOTE: Other implementations of ISO 16460 [1] might specify the use of systemService and serviceProviderPort.
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7.3 Channel info component
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The samBody component of sam shall include the channelInfos component and/or the ExtendedChannelInfos extension (see ISO 16460 [1]) if the ITS-S service can be consumed on a channel that is different from the channel on which the SAEM is transmitted. This channelInfos component, when present, shall contain at least one element. Each element shall be of type ChannelInfo and contain a channel information set. Each set shall indicate the characteristics of a channel associated with the same communication technology as used for the transmission of the SAEM. Usage of the ExtendedChannelInfos extension, if applicable, shall be as specified in ISO 16460 [1].
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7.4 IPv6 routing advertisement
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The samBody component of sam shall include the routingAdvertisement component if the ITS-S service can be consumed using IPv6 connectivity as detailed in ISO 16460 [1]. If the Service Provider ITS-S provides its service via an ITS-S Router and if the communication between Service Provider ITS-S and ITS-S Router is a routed IPv6 connection then: • The component defaultGateway shall provide the 128-bit IPv6 address of the ITS-S Router that provides connectivity to the Service Provider ITS-S. • The component extensions shall contain the extension GatewayMACaddress which shall indicate the MAC address of the ITS-S Router. NOTE: The IPv6 routing advertisement provides information about ITS-S services and the corresponding IPv6 connectivity details to consume the services over an IPv6 network. Conversely a "router advertisement" used by IPv6 to manage and establish an IPv6 connectivity over a router is specified in the corresponding IETF standards and might be used to build up the IPv6 connectivity necessary to consume the announced ITS-S service. The process of building up an IPv6 connection is out of scope of the present document. ETSI ETSI TS 104 091 V2.1.1 (2025-11) 18 Annex A (normative): ASN.1 module This clause provides the normative ASN.1 module containing the syntactical specification of the SAEM PDU, its containers, and the data frames, and data elements defined in the present document. The SAEM-PDU-Descriptions module is identified by the Object Identifier itu-t (0) identified-organization (4) etsi (0) itsDomain (5) wg1 (1) ts104091 (104091) sam (0) major-version-2 (2) minor-version-1 (1). The module can be downloaded as a file as indicated in table A.1. The associated SHA-256 cryptographic hash digest of the referenced file offers a means to verify the integrity of that file. The semantical specification of the SAEM components is contained in the same module in the form of ASN.1 comments and is also available in readable format as indicated in table A.1. Table A.1: ETSI TS 104 091 ASN.1 module information Module name SAEM-PDU-Descriptions OID itu-t (0) identified-organization (4) etsi (0) itsDomain (5) wg1 (1) ts104091 (104091) sam (0) major-version-2 (2) minor-version-1 (1) Link https://forge.etsi.org/rep/ITS/asn1/saem_ts104091/-/raw/v2.1.1/SAEM-PDU-Descriptions.asn SHA-256 hash 5c3d9c8d229d25f85c489e5961b15cbf90caa33a27cf52604f99046e4098b06f Readable format https://forge.etsi.org/rep/ITS/asn1/saem_ts104091/-/blob/v2.1.1/docs/SAEM-PDU- Descriptions.md ETSI ETSI TS 104 091 V2.1.1 (2025-11) 19 Annex B (normative): ASN.1 specification of extensions B.1 General Provides the specification of extensions defined by the present document. B.2 ChannelInfo extensions B.2.1 SrvOpP-ProtocolStack value assignements The value assignements as listed in table B.1 shall be used for the data type SrvOpP-ProtocolStack. Table B.1: ProtocolType value assignements Value Assignment 0 Protocol stack unknown 1 Any protocol stack as desired by the service user 2 A protocol stack featuring the networking protocol: Wave Short Message Protocol according to IEEE 1609.3 [8] 3 A protocol stack featuring the networking protocol: Geonetworking as specified in ETSI TS 836-4-1 [9] and the transport protocol: Basic Transport Protocol as specified in ETSI TS 103 836-5-1 [10] 4 Reserved for future use by ETSI 5 Reserved for future use by ETSI 6 A protocol stack featuring the networking protocol: Internet Protocol Version 6 "IPv6" and the transport protocol: Transmission Control Protocol according to IEEE 1609.3 [8] 7-50 Reserved for future use by ETSI ETSI ETSI TS 104 091 V2.1.1 (2025-11) 20 Annex C (informative): Change history Date Version Information about changes V2.1.1 Release 2 version based on a complete re-work of ETSI EN 302 890-1 to comply with the Release 2 Format. ETSI ETSI TS 104 091 V2.1.1 (2025-11) 21 History Document history V2.1.1 November 2025 Publication
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1 Scope
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The present document defines the means to enable a test environment for verification of specific radio requirements and functional requirements of an ITS-S after deployment, most often when in a non-shielded environment. The present document addresses the security requirements to mitigate the risks identified in ETSI TR 103 971 [i.2].
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2 References
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2.1 Normative references
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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. Referenced documents which are not found to be publicly available in the expected location might be found in the ETSI docbox. 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 necessary for the application of the present document. [1] ETSI TS 103 918 (V2.1.1): "Intelligent Transport Systems (ITS); Security; Testing; ITS Misbehaviour Reporting; Interoperability tests specification; Release 2". [2] ETSI TS 103 868-3 (V2.1.1): "Intelligent Transport Systems (ITS); Testing; Conformance test specifications for ITS Misbehaviour Reporting service; Part 3: Abstract Test Suite (ATS) and Protocol Implementation eXtra Information for Testing (PIXIT); Release 2". [3] ETSI TS 103 525-3 (V2.1.1): "Intelligent Transport Systems (ITS); Testing; Conformance test specifications for ITS PKI management; Part 3: Abstract Test Suite (ATS) and Protocol Implementation eXtra Information for Testing (PIXIT); Release 2". [4] ETSI TS 103 096-3 (V2.1.1): "Intelligent Transport Systems (ITS); Testing; Conformance test specifications for ITS Security; Part 3: Abstract Test Suite (ATS) and Protocol Implementation eXtra Information for Testing (PIXIT); Release 2". [5] ETSI TS 102 942: "Intelligent Transport Systems (ITS); Security; Access Control; Release 2". [6] ETSI TS 103 601: "Intelligent Transport Systems (ITS); Security; Security management messages communication requirements and distribution protocols; Release 2". [7] ETSI TS 103 097: "Intelligent Transport Systems (ITS); Security; Security header and certificate formats; Release 2". [8] ETSI TS 102 940: "Intelligent Transport Systems (ITS); Security; ITS communications security architecture and security management; Release 2". [9] ETSI TS 102 941: "Intelligent Transport Systems (ITS); Security; Trust and Privacy Management; Release 2". [10] ETSI TS 102 943: "Intelligent Transport Systems (ITS); Security; Confidentiality services; Release 2". [11] ETSI TS 103 759: "Intelligent Transport Systems (ITS); Security; Misbehaviour Reporting service; Release 2". [12] ETSI EN 302 665: "Intelligent Transport Systems (ITS); Communications Architecture". ETSI ETSI TS 103 870 V2.1.1 (2025-11) 6
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2.2 Informative references
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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 may be useful in implementing an ETSI deliverable or add to the reader's understanding, but are not required for conformance to the present document. [i.1] ETSI TR 103 573: "Intelligent Transport Systems (ITS); Pre-standardization study of ITS test mode for operational devices in the field". [i.2] ETSI TR 103 971: "Intelligent Transport Systems (ITS); Security; Threat, Vulnerability and Risk Analysis (TVRA)".
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3 Definition of terms, symbols and abbreviations
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3.1 Terms
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For the purposes of the present document, the following terms apply: operational mode: mode of an ITS-S EXAMPLE: Infield test mode, laboratory test mode, active ITS-S mode. test mode dynamic: infield test mode in which the SUT has dynamic position (i.e. can move in space) NOTE: The regular message handling and user services are active. Specific ITM certificates are used. test mode static: infield test mode in which the SUT has a static position (i.e. cannot move in space) NOTE: The regular message exchange of the station is forbidden and only Messages based on the ITM protocol are received or sent. Specific ITM certificates are used.
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3.2 Symbols
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Void.
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3.3 Abbreviations
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For the purposes of the present document, the following abbreviations apply: AA Authorization Authority DTS Dedicated Test System ITM Infield Test Mode ITS-S Intelligent Transport System Station IUT Implementation Under Test PKI Public Key Infrastructure RF Radio Frequency SUT System Under Test TM Test Mode TMS Test Mode Service TVRA Threat Vulnerability Risk Analysis ETSI ETSI TS 103 870 V2.1.1 (2025-11) 7
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4 Infield testing essential requirements
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As stated in the scope statement (clause 1) of ETSI TR 103 573 [i.1]: "The test mode provides the ability of testing RF and functional requirements regarding the communication of devices. This includes but is not limited to over the air tests in non-shielded environments without affecting operational ITS stations not targeted by the message". The text of ETSI TR 103 573 [i.1] suggests that test and non-test traffic should be separated and this is further identified as essential from the results of a TVRA exercise documented in ETSI TR 103 971 [i.2]. The state of the SUT shall be determined as part of the decision to allow a test to be performed. This is required to assure the safety of the environment and operator as outlined in ETSI TR 103 971 [i.2] where risk of harm to the operator and the environment has priority over any other risk. Thus where receiving behaviour needs an observer at the IUT there has to be assurance that the observer/observation does not interfere with the vehicle if the vehicle is in motion. If that assurance cannot be given the test shall not be carried out. Similarly if sending behaviour requires an observer to provide the stimulus then there has to be assurance that the observer/stimulus does not interfere with the vehicle if the vehicle is in motion. If that assurance cannot be given the test shall not be carried out. NOTE: The present document does not define how the determination of interference with vehicle operation is assessed, rather it assumes that any distraction from driving to attend to the test is a disqualifying interference. It is assumed that prior to enabling any form of ITM tests that the basic electrical and functional tests have been carried out, i.e. that the ITS-S is powered and reports that it is able to transmit and receive messages. If the basic electrical and functional tests fail then ITM shall not apply (i.e. the equipment is required to have reasonable confidence that it can operate even if there is a reasonable probability that some additional conformance testing will identify a fault). All conformance and interoperability tests defined in ETSI TS 103 525-3 [3] and ETSI TS 103 096-3 [4] for ITS security and PKI management, and those defined in ETSI TS 103 918 [1] and ETSI TS 103 868-3 [2] for misbehaviour reporting shall, be enabled provided the above conditions are satisfied. It is assumed for the purposes of the present document that the SUT has been approved for installation and has previously passed all required tests for placement on the market. With this assumption the following requirements apply for all ITM use: • ITM shall be exclusive, i.e. whilst ITM is enabled the ITS-S acting as SUT shall not act on any other ITS messaging. • ITM shall be disabled by default in all ITS-Ss. • ITM shall be enabled by an activation message from an authorized test system. • Activation messages shall be addressed to a specific ITS-S. • ITM shall be disabled by a deactivation message from an authorized test system to a specific ITS-S, or shall deactivate on expiry of the ITM timer. • ITM shall be able to be deactivated by direct command of the user of the SUT. • The ITM timer maximum value shall not exceed 1 hour and shall be reset on receipt of an authenticated and authorized ITM message. • A receiving ITS-S shall not act on a received ITM message if ITM has not been enabled.
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5 Security Architecture of ITM
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ITM shall follow the core security models, data structures, protocols and certificate formats from each of ETSI TS 102 942 [5], ETSI TS 103 601 [6], ETSI TS 103 097 [7], ETSI TS 102 940 [8], ETSI TS 102 941 [9], ETSI TS 102 943 [10] and ETSI TS 103 759 [11]. ETSI ETSI TS 103 870 V2.1.1 (2025-11) 8 As identified in both ETSI TR 103 573 [i.1] and ETSI TR 103 971 [i.2] there has to be authoritative separation of ITM from any normal ITS operation. Every received ITS message is expected to be signed and the signature verified before processing. In ETSI TS 102 942 [5] as all assets are required to be considered as protected with a default access control result of DENY it is essential that the access control model is able to clearly distinguish an access attempt from an ITM service or message from any non-ITM service or message access attempt. All ITM messaging shall be authorized by a recognized ITM authority. In the context of pre-conditions for assuring ITM authority separation the test keys identified in clause 5.3.2 of ETSI TS 103 096-3 [4] shall be augmented as follows. The certificates that shall be installed in order to run the mandatory tests are variants of those defined in [4] and need to be clearly identifiable as being part of the ITM authorization tree. • CERT_IUT_A_ITM_RCA • CERT_IUT_A_ITM_AA At least the CERT_IUT_A_ITM_RCA and CERT_IUT_A_ITM_AA certificates shall be installed onto the IUT to be able to validate messages sent by the DTS (see clause 6 below). All certificates used in mandatory tests are derived from the CERT_IUT_A_ITM_RCA certificate. The AA used to distribute the certs used in ITM shall be identifiable as an ITM authority.
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6 Physical architecture of ITM
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The physical architecture of the ITM is shown in Figure 1. It consists of two main components. • The Dedicated Test System (DTS). • The ITS-S acting as the System Under Test (SUT). In respect of the exclusive nature of ITM the following additional requirements in respect of activation of ITM apply. • The DTS shall be able to request an ITM session with a specific ITS-S. • Any ITS-S invited to join an ITM session shall be able to reject the invitation with a clear indication of why the invitation is being rejected. • On acceptance of an invitation to join the ITM session only the key hierarchy of the ITM shall apply. Figure 1: ITM system physical architecture ETSI ETSI TS 103 870 V2.1.1 (2025-11) 9
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7 TMS functional specification
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7.1 SUT ITS-S operational modes
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The specification of the ITS communication architecture from ETSI EN 302 665 [12] applies. As shown in figure 2 a distinction is made between three different operating modes, where the "Active ITS-S Mode" includes the general specification for an ITS-S as described above. Figure 2: Operational modes of a SUT ITS-S
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7.2 Test architecture
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7.2.1 General architecture
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The Test Mode architecture for ITM shall follow the model in clause 5 of ETSI TS 103 096-3 [4]. ETSI ETSI TS 103 870 V2.1.1 (2025-11) 10 Figure 3: TM general architecture
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7.2.2 Upper tester
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The upper tester shall be as defined in clause 5 of ETSI TS 103 096-3 [4].
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7.2.3 Lower tester
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The lower tester shall be as defined in clause 5 of ETSI TS 103 096-3 [4].
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7.3 Initialization and termination
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7.3.1 Initialization of ITM
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ITM shall only be activated by an authorized ITS-S DTS and shall follow the general process defined in clause 7.2 of ETSI TS 103 096-3 [4].
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7.3.2 Termination of ITM
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ITM shall only be deactivated by an authorized ITS-S DTS and shall follow the general process defined in clause 7.2 of ETSI TS 103 096-3 [4]. ETSI ETSI TS 103 870 V2.1.1 (2025-11) 11 Annex A (informative): Bibliography ETSI TS 102 165-1: "Cyber Security (CYBER); Methods and protocols; Part 1: Method and pro forma for Threat, Vulnerability, Risk Analysis (TVRA)". ETSI EN 303 645: "CYBER; Cyber Security for Consumer Internet of Things: Baseline Requirements". ETSI TR 102 638 (V1.1.1): "Intelligent Transport Systems (ITS); Vehicular Communications; Basic Set of Applications; Definitions". ETSI TS 102 965 (V2.1.1): "Intelligent Transport Systems (ITS); Application Object Identifier (ITS-AID); Registration; Release 2". ETSI ETSI TS 103 870 V2.1.1 (2025-11) 12 History Document history V2.1.1 November 2025 Publication
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102 165-3
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1 Scope
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The present document defines the application of the Common Criteria Vulnerability Assessment class defined in Common Criteria part 3 [1] alongside the ETSI TVRA method defined in ETSI TS 102 165-1 [2].
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2 References
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102 165-3
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2.1 Normative references
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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. Referenced documents which are not found to be publicly available in the expected location might be found in the ETSI docbox. 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 necessary for the application of the present document. [1] Common Criteria CCMB-2022-11-003: "Common Criteria for Information Technology, Security Evaluation, Part 3: Security assurance components", November 2022, Revision 1. [2] ETSI TS 102 165-1: "Cyber Security (CYBER); Methods and protocols; Part 1: Method and pro forma for Threat, Vulnerability, Risk Analysis (TVRA)". [3] Common Criteria CCMB-2022-11-006: "Common Methodology for Information Technology, Security Evaluation, Evaluation methodology", November 2022, Revision 1. [4] Common Criteria CCMB-2022-11-001: "Common Criteria for Information Technology, Security Evaluation, Part 1: Introduction and general model". [5] Common Criteria CCMB-2022-11-002: "Common Criteria for Information Technology, Security Evaluation, Part 2: Security functional components".
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2.2 Informative references
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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 may be useful in implementing an ETSI deliverable or add to the reader's understanding, but are not required for conformance to the present document. [i.1] Regulation (EU) 2019/881 of the European Parliament and of the Council of 17 April 2019 on ENISA (the European Union Agency for Cybersecurity) and on information and communication technology cybersecurity certification and repealing Regulation (EU) No 526/2013 (Cybersecurity Act). [i.2] Cybersecurity Certification: Candidate EUCC Scheme V1.1.1. NOTE: The EUCC scheme is a Common Criteria based European candidate cybersecurity certification scheme and issued by the European Union Agency for Cybersecurity (ENISA). ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 7 [i.3] S. W. Cadzow: "Security assurance and standards - design for evaluation", The 2nd IEE Secure Mobile Communications Forum: Exploring the Technical Challenges in Secure GSM and WLAN, 2004. (Ref. No. 2004/10660), London, UK, 2004, pp. 8/1-8/6, doi: 10.1049/ic.2004.0664. [i.4] ETSI's Making Better Standards. [i.5] ETSI TS 102 165-2: "Telecommunications and Internet converged Services and Protocols for Advanced Networking (TISPAN); Methods and protocols; Part 2: Protocol Framework Definition; Security Counter Measures". NOTE: An update is in preparation. [i.6] Raphaël Hertzog, Jim O"Gorman and Mati Aharoni: "Kali Linux Revealed Mastering the Penetration Testing Distribution", ISBN: 978-0-9976156-0-9. [i.7] ETSI TS 103 305-1: "Cyber Security (CYBER); Critical Security Controls for Effective Cyber Defence; Part 1: The Critical Security Controls". [i.8] ETSI TS 103 993: "Cyber Security (CYBER); ONDS Test Suite Structure and Test Purposes". [i.9] ETSI ES 202 553: "Methods for Testing and Specification (MTS); TPLan: A notation for expressing Test Purposes". [i.10] ETSI ES 202 383: "Telecommunications and Internet converged Services and Protocols for Advanced Networking (TISPAN); Security Design Guide; Method and proforma for defining Security Targets". [i.11] Recommendation ITU-T I.130: "Method for the characterization of telecommunication services supported by an ISDN and network capabilities of an ISDN". [i.12] ETSI TS 103 996: "Cyber Security (CYBER); ONDS Protection profile - Test cases". [i.13] ETSI TS 103 962: "CYBER; Optical Network and Device Security; Security provisions in Optical Access Network Devices". [i.14] ETSI TS 104 102: "Cyber Security (CYBER); Encrypted Traffic Integration (ETI); ZT-Kipling methodology". [i.15] Commission Implementing Regulation (EU) 2024/482 of 31 January 2024 laying down rules for the application of Regulation (EU) 2019/881 of the European Parliament and of the Council as regards the adoption of the European Common Criteria-based cybersecurity certification scheme (EUCC). [i.16] Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011. [i.17] Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users, amending Regulation (EU) 2018/858 of the European Parliament and of the Council and repealing Regulations (EC) No 78/2009, (EC) No 79/2009 and (EC) No 661/2009 of the European Parliament and of the Council and Commission Regulations (EC) No 631/2009, (EU) No 406/2010, (EU) No 672/2010, (EU) No 1003/2010, (EU) No 1005/2010, (EU) No 1008/2010, (EU) No 1009/2010, (EU) No 19/2011, (EU) No 109/2011, (EU) No 458/2011, (EU) No 65/2012, (EU) No 130/2012, (EU) No 347/2012, (EU) No 351/2012, (EU) No 1230/2012 and (EU) 2015/166. [i.18] Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices, amending Directive 2001/83/EC, Regulation (EC) No 178/2002 and Regulation (EC) No 1223/2009 and repealing Council Directives 90/385/EEC and 93/42/EEC. [i.19] ETSI TS 104 158-1: "Securing Artificial Intelligence TC (SAI); AI Common Incident Expression (AICIE); Part 1". ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 8 [i.20] ETSI TS 104 170: "Cyber Security (CYBER); Universal Cybersecurity Information Exchange Framework - Repository". [i.21] NIST Special Publication 800-115: "Technical Guide to Information Security Testing and Assessment". [i.22] EC Council: "Understanding the Five Phases of the Penetration Testing Process". [i.23] ETSI TR 103 306 (V1.4.1): "CYBER; Global Cyber Security Ecosystem". [i.24] Global CVE Allocation System. [i.25] NIST: "National Vulnerability Database".
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3 Definition of terms, symbols and abbreviations
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3.1 Terms
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For the purposes of the present document, the following terms apply: blue team: group acting as a corollary to a red team in order to develop measures to counter physical or digital attacks high assurance level: assurance that ICT products, ICT services and ICT processes where the corresponding security requirements, including security functionalities, are provided at a level intended to minimize the known cybersecurity risks, and the risk of incidents and cyberattacks carried out by actors with significant skills and resources NOTE: A contextual definition is given in CSA Article 52.7 [i.1]. red team: group that simulates an adversary in order to attempt physical or digital attacks substantial assurance level: assurance that the ICT products, ICT services and ICT processes where the corresponding security requirements, including security functionalities, are provided at a level intended to minimize the known cybersecurity risks, and the risk of incidents and cyberattacks carried out by actors with limited skills and resources NOTE: A contextual definition is given in CSA Article 52.6 [i.1].
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3.2 Symbols
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Void.
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3.3 Abbreviations
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For the purposes of the present document, the following abbreviations apply: (P)ICS (Protocol) Implementation Conformance Statement AI Artificial Intelligence AICIE AI Common Incident Expression API Application Programming Interface CC Common Criteria CEM CC Evaluation Methodology CSA Cyber Security Act CSC Cyber Security Control CVE Common Vulnerabilities and Exposures CVSS Common Vulnerability Scoring System DORA Digital Operational Resilience Act EUCC EU Common Criteria Certification GCVE Global CVE Allocation System NOTE: See https://gcve.eu. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 9 IA Information Assurance ICT Information Communication Technology IUT Instrument Under Test NVD National Vulnerability Database ONDS Optical Network Device Security PICS Protocol Implementation Conformance Statement PP Protection Profile SDO Standards Development Organisation SFR Security Functional Requirement SP Special Publication ST Security Target ToE Target of Evaluation TP Test Purpose TSF ToE Security Function TSS Test Suite Structure TTCN-3 Testing and Test Control Notation Version 3 TVRA Threat Vulnerability Risk Analysis UCYBEX Universal Cybersecurity Information Exchange Framework ZT Zero Trust
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4 Overview of AVA_VAN
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4.1 Vulnerability analysis and its role in risk assessment
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NOTE 1: AVA_VAN is described in clause 14 of CC Part 3 [1] and is not strictly an acronym or abbreviation but can be read as part of the Vulnerability Assessment class and the term AVA_VAN read as a word in its own right. The approach to risk analysis given in ETSI TS 102 165-1 [2] is to determine the level of risk to each stakeholder from an assessment of the likelihood and impact of an attack by a threat agent against an asset, or collection of assets, within a system. The presumption in ETSI TS 102 165-1 [2] is that all assets have weaknesses that become vulnerabilities if a viable threat can be enacted against them. If no viable threat can be enacted the risk assessment is that there is either no risk or minimal risk and that specific countermeasures to mitigate any threat are unnecessary (as the threat is not viable). The wording of the AVA_VAN class in Common Criteria part 3 [1] is very slightly different as it refers to an exploitable vulnerability (in ETSI TS 102 165-1 [2] a vulnerability is an exploitable weakness). The developer actions for AVA_VAN are relatively simply worded to indicate the developer shall make the TOE available for testing and that it shall be suitable for testing. There is an increasing scale of the depth of analysis from AVA_VAN.1 requiring a vulnerability survey, through AVA_VAN.3 requiring a focussed analysis, and AVA_VAN.5 requiring an Advanced methodical analysis. At the higher levels it is required to conduct a penetration test to verify the implementation. The wording of ETSI TS 102 165-1 [2] uses the terms threat and threat-agent in the context "A threat is enacted by a threat agent, and may lead to an unwanted incident breaking certain pre-defined security objectives" whereas the Common Criteria Part 1 [4] use of the same terms is "A threat consists of an adverse action performed by a threat agent on an asset". NOTE 2: The way in which terms are used in [1] and [3] differ from their use in [2] because the position of the active party is different, in [1] and [3] the terms are used from the perspective on an evaluator determining if the provisions are implemented satisfactorily and if they are sufficient to address the identified risk, whereas in [2] the perspective is to give guidance or to provide a mandate to a developer in determination of a suitable counter to an identified risk. NOTE 3: The present document addresses the EUCC programme [i.2], [i.15] for only the 2022 versions of Common Criteria [1], [3], [4], [5] and does not allow for use of earlier versions as allowed until the end of 2027 by Article 3(20) of the EUCC Implementing Act [i.15]. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 10
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4.2 Addressing the evaluator expectations in standards
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Common Criteria part 3 [1] addresses the actions of an evaluator and for the purposes of the present document is addressed by equating an evaluator to a test environment. The present document addresses steps in the development cycle, for standards and for products, that when followed will give confidence to the development group that an evaluator will give a PASS verdict. Thus, while the Common Criteria Evaluation Method (CEM) [3] defines in some detail the tasks that an evaluator is expected to complete the present document identifies how a developer should prepare for the evaluation and is therefore complimentary to [3] albeit from a different stance/perspective. This is also addressed by the "design for evaluation" paradigm in [i.3] that has been inherited in ETSI's work programme including ETSI TS 102 165-1 [2] and ETSI TS 102 165-2 [i.5]. EXAMPLE: For AVA_VAN.1.3E in [3] there are 7 work units identified (in addition to work units identified for prior levels of AVA_VAN.1) to be undertaken by the evaluator that combine to provide content for the Evaluation Test Report (ETR). In the present document the role of standards, and standards developers, in allowing the evaluator to perform the relevant tasks is addressed. 4.3 Addressing evaluation in the standards development process The model for standards development excellence, as outlined in ETSI's Making Better Standards [i.4] requires that standards are developed against the following criteria: • Necessary: it (a standard) should specify only what is required to meet its objectives, and not impose a particular approach to implementation. • Unambiguous: it should be impossible to interpret the normative parts of the standard in more than one way. • Complete: the requirement should contain all the information necessary to understand that requirement, either directly or by reference to other documents. The reader of a standard should not need to make assumptions about the implementation of any requirement. • Precise: the requirement should be worded clearly and exactly, without unnecessary detail that might confuse the reader. • Well-structured: the individual elements of the requirement should all be included in an appropriate and easy-to-read manner. • Consistent: there should be no contradiction between different requirements within the standard, nor with other related standards. • Testable: there should be clear and obvious means of demonstrating that an implementation complies with the requirement. The mapping for evaluation is addressed specifically in the testable criterion. The convention in ETSI for testing of deterministic standards is that formal conformance tests are developed (a flow of the documents is given in Figure 1). In the test environment considered above (and shown in Figure 1) there is an assumption that the test verdict is either PASS or FAIL. In some cases a verdict of INDETERMINATE can be given. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 11 Figure 1: Standards document flow from requirement to testing Where there is a degree of uncertainty from closed-box testing that the requirement being tested passes or fails it may be appropriate to allow expert evaluation to make a deeper examination of the equipment or implementation in order to assign a pass or fail verdict. The general requirement is that even if the security offered by an equipment or implementation has some uncertainty that the test or evaluation environment is deterministic. NOTE: A test verdict of INDETERMINATE is often accompanied by advice on why a test verdict of PASS or FAIL could not be assigned. As an INDETERMNATE verdict signifies that the test outcome cannot be definitively determined the test report should identify why, such as missing information, unexpected behaviour, or limitations of the testing environment. EXAMPLE: A test to determine if an element is "secure" is mostly non-deterministic as the context of both the attacker and the placement of the element is critical to make a determination. The evaluation process as per [3] takes account of the context in making the determination. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 12
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5 Provisions for content and provision of evidence
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5.1 Expected evidence defined in CEM
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The AVA_VAN class in CEM [3] requires the evidence outlined in Table 1. Whilst [3] identifies the evidence requirements the present document identifies the role of ETSI standards that may be used in providing that evidence. Table 1: Evidence requirements against AVA_VAN from CEM [3] AVA_VAN class Attack potential Evidence requirement in CEM [3] AVA_VAN.1.3E Basic a) the ST; b) the guidance documentation; c) the TOE suitable for testing; d) information publicly available to support the identification of potential vulnerabilities. AVA_VAN.2.4E Basic a) the ST; b) the functional specification; c) the TOE design; d) the security architecture description; e) the guidance documentation; f) the TOE suitable for testing; g) information publicly available to support the identification of possible potential vulnerabilities. AVA_VAN.3.4E Enhanced- Basic a) the ST; b) the functional specification; c) the TOE design; d) the security architecture description; e) the implementation subset selected; f) the guidance documentation; g) the TOE suitable for testing; h) information publicly available to support the identification of possible potential vulnerabilities; i) the results of the testing of the basic design. AVA_VAN.4.4E Moderate a) the ST; b) the functional specification; c) the TOE design; d) the security architecture description; e) the implementation representation; f) the guidance documentation; g) the TOE suitable for testing; h) information publicly available to support the identification of possible potential vulnerabilities; i) the results of the testing of the basic design. AVA_VAN.5.4E High a) the ST; b) the functional specification; c) the TOE design; d) the security architecture description; e) the implementation representation; f) the guidance documentation; g) the TOE suitable for testing; h) information publicly available to support the identification of possible potential vulnerabilities; i) the results of the testing of the basic design.
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5.2 Support to CEM evidence requirements from SDOs/ETSI
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5.2.1 The ST
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The Security Target (ST) may be defined by reference to a standard, particularly if the standard is a Protection Profile (PP). In such a case the ST can claim to be conformant to the PP. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 13 NOTE: ETSI ES 202 383 [i.10], whilst referring to a prior version of Common Criteria, makes recommendations for the preparation of an ST with the following disclaimer "CC evaluation involves the preparation of a Security Target (ST) that specifies the security requirements for an identified Target Of Evaluation (TOE) and describes the functional and assurance security measures offered by that TOE to meet the stated requirements. As an ST is directly related to the final TOE and is therefore prepared by the TOE developer there is no impact on the standardization process". In preparing the ST the guidance offered in clause 5.3 of ETSI ES 202 383 [i.10] should be taken into account. Where the ST is developed to conform to a standard the standards suite that have been adopted shall be cited by the ST developer.
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5.2.2 The functional specification
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As stated in CEM [3] a functional specification provides a description of the purpose and method-of-use of interfaces to the TSF. The ToE Security Function (TSF) may be described by a technical standard. Commonly many standards will identify the pre-conditions, stimuli, and post-conditions for invocation of a TSF. Where the standard is defined as a PP identifying SFRs it is reasonable to expect that the TSFs are similarly defined in a standard. NOTE: In the 3-stage development approach defined by Recommendation ITU-T I.130 [i.11] a mapping of the PP containing abstract SFRs to stage 2 can be made, with the more detailed functionality at stage 3 being the domain of TSFs. EXAMPLE: In ETSI TS 103 996 [i.12] it is identified that the TOE includes FIA_API.1 Authentication proof of identity, with the specific text "The TSF shall provide an [assignment: authentication mechanism] to prove the identity of [assignment: entity] by including the following properties [assignment: list of properties] to an external entity". Where the TOE is being externally accessed then the identity of the accessing entity could be proven by digitally signing a document where the public key for verification is known, or accessible, to the TOE. In which case the entire protocol of the authentication using digital signature may be defined in a standard and that standard identified. In the particular case of ETSI TS 103 996 [i.12] this is contained in ETSI TS 103 962 [i.13] which makes further reference to specific frameworks for authentication given in ETSI TS 102 165-2 [i.5].
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5.2.3 The TOE design
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Where a standard, or suite of standards, is used as the basis of the design of TSFs the relevant standards should be cited in the evidence. Where standards are profiled, or where the TSFs in the TOE are derived from a chain of documents, e.g. a PP, or a stage 1 or stage 2 definition per Recommendation ITU-T I.130 [i.11], these should also be cited in the evidence. The TOE is intended to be a secure system and the evidence should be clear in the design documentation. Where a TVRA exercise [2], or a ZT-Kipling exercise [i.14] has been carried out, and which identifies the form of threat that the system has been designed to be resilient against, this should also include evidence of resilience against known threats and vulnerabilities.
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5.2.4 The security architecture description
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Any security component, e.g. an authentication service, may be described in detail by a standard and the overall security architecture of a component or system may also be defined by a standard. For example, ETSI TS 102 165-2 [i.5] identifies a number of functional components and their dependencies, and a standard may build on this framework to refine the operation for the identified ST and thus be used as a reference architecture for the ST (in such cases as suggested in clause 5.2.2 above the models from ETSI TS 102 165-2 [i.5] can be identified as TSFs). NOTE: Whilst it is suggested above the models from ETSI TS 102 165-2 [i.5] can be identified as TSFs that is not their primary function, rather they serve as exemplars for more detailed refinement in specific applications. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 14
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5.2.5 The implementation representation
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5.2.5.1 Overview of the role of standards in representing the implementation
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Not specific to standardization but in cases where the implementation conforms to any standard that standard should be cited in the evidence. NOTE: The citing of standards should not only address those from an SDO, for example if the development organization has particular standards for development, quality control and so on, these should also be cited as evidence of the rigour of the process leading to the implementation.
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5.2.5.2 Role of security controls (as defined in ETSI TS 103 305-1)
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In addition to the determination of risk given in ETSI TS 102 165-1 [2], and the adoption of common frameworks as given in ETSI TS 102 165-2 [i.5] in order to counter identified threats and mitigate the risk they represent, and the approach to vulnerability analysis and penetration testing outlined in the present document, there are a set of security controls that apply, in part, to the organization using and deploying ICT equipment in a secure manner. Whilst a summary of the applicability of such controls is given in ETSI TS 103 305-1 [i.7] it is stressed that any ICT product is vulnerable if weaknesses exist in the supply chain or the development organizations. In addition, to support the rationale for the existence of any asset in a system the ZT-Kipling criteria defined in ETSI TS 104 102 [i.14] should be applied. NOTE: The purpose of applying the ZT-Kipling method from ETSI TS 104 102 [i.14] is to build evidence that any asset in the system has a known and justified role. Thus, by application of the asset inventory using CSC-1 [i.7] and by validating the purpose of each asset using the ZT-Kipling criteria the developer should have confidence that they can demonstrate to an evaluator that they understand the system. Extending this understanding further by application of the TVRA method from ETSI TS 102 165-1 [2] should demonstrate to the evaluator that a thorough approach to secure system design has been applied by the developer. Table 2: Mapping of CSCs to AVA_VAN expectations Control from ETSI TS 103 305-1 [i.7] Rationale in addressing AVA_VAN Control 1: Inventory and Control of Enterprise Assets (as defined in ETSI TS 103 305-1 [i.7] an enterprise asset is one with the potential to store or process data, and is identified as hardware) A complete inventory of assets in the system is essential to give assurance to the evaluator that the developer has understood the scope of each element of the system and how they interact. Thus, for the present document no real distinction is made between the form of asset (hardware or software). The application of the ZT-Kipling criteria from ETSI TS 104 102 [i.14] gives a detailed justification of the presence and role of any asset. Control 2: Inventory and Control of Software Assets (as defined in ETSI TS 103 305-1 [i.7] a software asset is a discrete package of data and instructions used to direct a computer to complete a specific task, including operating systems and applications) Control 3: Data Protection In applying this control from the perspective of the present document the primary function is to identify data as system assets and to establish and document the role of each data asset and how its role is protected. Control 4: Secure Configuration of Enterprise Assets and Software The bulk of the remaining controls reflect good organizational processes and as cited in the note of clause 5.2.5.1 may be used in the overall documentary evidence of the process in which systems are developed. Control 5: Account Management Control 6: Access Control Management Control 7: Continuous Vulnerability Management Control 8: Audit Log Management Control 9: Email and Web Browser Protections Control 10: Malware Defences Control 11: Data Recovery Control 12: Network Infrastructure Management Control 13: Network Monitoring and Defence Control 14: Security Awareness and Skills Training Control 15: Service Provider Management Control 16: Application Software Security Control 17: Incidence Response Management Control 18: Penetration Testing See Annex A of the present document. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 15
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5.2.6 The guidance documentation
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The details of guidance documentation are addressed in [1] in the class AGD. The intent is to ensure that all relevant aspects for the secure handling of the TOE are described, including the possibility of unintended incorrect configuration or handling of the TOE. Whilst some of the details will be implementation specific there are many aspects that will be guided by standards and processes that may be used to supplement the data. EXAMPLE: A system may be designed with the ability for a user to choose a password but if that password is weak it can be circumvented. The guidance should identify how to create and use a strong password, and the system itself should prohibit weak ones. Making the guidance clear, and ensuring the system operation and the guidance are aligned, is critical to a successful evaluation of a secure system.
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5.2.7 The TOE suitable for testing
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Not relevant to standards (if the TOE is built to conform to standards that has already been addressed). See also clause 5.2.3 above. 5.2.8 Information publicly available to support the identification of possible potential vulnerabilities In general the recommendation for any security work in order to identify the necessary security functionality a TVRA should be performed. The guidance given in ETSI TS 102 165-1 [2] therefore applies. In addition where the ST makes use of known software or hardware the developer should have performed a documentary analysis of reported vulnerabilities in public databases. NOTE: The further development of standards in this domain such as AICIE for AI vulnerabilities (see ETSI TS 104 158-1 [i.19]) and UCYBEX for general cybersecurity vulnerabilities in ETSI TS 104 170 [i.20] should be cited and integrated to the system design.
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5.2.9 The results of the testing of the basic design
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The general principles of good standards design outlined in clause 4.3 above and listed as "Testable: there should be clear and obvious means of demonstrating that an implementation complies with the requirement" should indicate that a test specification exists for each element of the design and for the composition of those elements in the particular configuration required of the design.
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6 Determination of attack potential
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The AVA_VAN class is mapped to attack potential as follows. Attack potential is defined in ETSI TS 102 165-1 [2] using the weighted summation method, the metrics of which are mapped to Annex B of CEM [3] but as per the note in clause 4.1 above written from the perspective of the analyst and not the evaluator. The mapping of the results of the weighted summation analysis to the attack potential measures described in AVA_VAN given in ETSI TS 102 165-1 [2] are copied below and annotated as appropriate. Table 3: Mapping of the weighted summation analysis to attack potential Attack potential values Attack potential required to exploit attack Resistant to attacker with attack potential of AVA_VAN CSA [i.1] rating 0 to 9 Basic No rating CSA-Basic 10 to 13 Enhanced-basic Basic AVA_VAN.1 and AVA_VAN.2 CSA-Substantial 14 to 19 Moderate Enhanced basic AVA_VAN.3 CSA-High 20 to 24 High Moderate AVA_VAN.4 CSA-High > 24 Beyond High High AVA_VAN.5 CSA-High ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 16 The developer should be aware that over time attacks are often refined and distributed in a way that increases the likelihood, by either reducing the level of expertise or nature of the equipment required to instantiate the attack. Thus, a system made available at time t0 expected to be resistant to an attack potential High, may over time only be resistant to an attack potential of Basic. Table 4: Expectation of evaluator tasks in AVA_VAN class AVA_VAN class Attack potential Notes AVA_VAN.1.3E Basic The evaluator shall conduct penetration testing, based on the identified potential vulnerabilities, to determine that the TOE is resistant to attacks performed by an attacker possessing Basic attack potential. AVA_VAN.2.4E AVA_VAN.3.4E Enhanced- Basic The evaluator shall conduct penetration testing, based on the identified potential vulnerabilities, to determine that the TOE is resistant to attacks performed by an attacker possessing Enhanced-Basic attack potential. AVA_VAN.4.4E Moderate The evaluator shall conduct penetration testing based on the identified potential vulnerabilities to determine that the TOE is resistant to attacks performed by an attacker possessing Moderate attack potential. AVA_VAN.5.4E High The evaluator shall conduct penetration testing based on the identified potential vulnerabilities to determine that the TOE is resistant to attacks performed by an attacker possessing High attack potential. A designer may determine the risk of the system by conducting an analysis using the methods described in ETSI TS 102 165-1 [2]. In doing so it will be determined by the analyst what level of expertise the system offers protection against, i.e. in developing the analysis to identify necessary countermeasures the analyst will have made a quantitative assessment of both the attacker capability and motivation, and the resistance to attack offered by the security functions defined. In documenting the analysis undertaken the analyst will be expected to have performed some form of intellectual or actual penetration test in order to validate the results. As shown in Table 4 the evaluator shall conduct penetration testing at a level consistent with the attack potential, therefore the developer should have identified the likelihood of an attacker with the appropriate level of attack potential in conducting their pre-design risk evaluation and, as stated in ETSI TS 102 165-1 [2], updated that analysis as the design is developed. The fully documented TVRA ETSI TS 102 165-1 [2] should be part of the evidence that the selected security functions (SFRs and TSFs) are sufficient to address the identified attack potential.
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7 Standards for the conduct of penetration tests
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7.1 Preparing for a penetration test
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Penetration testing differs from vulnerability testing and vulnerability identification as outlined in clause 4.1. Vulnerability identification as outlined in ETSI TS 102 165-1 [2] identifies the attack surface and from there assesses the risk to assets. The approach outlined in ETSI TS 103 305-1 [i.7] addresses vulnerability testing as a check for the presence of known, insecure enterprise assets, and stops there, although the analysis of ETSI TS 102 165-1 [2] identifies the nature of the threat agent and the means of enabling the threat agent to determine likelihood of an attack. Penetration testing as described in ETSI TS 103 305-1 [i.7] is closer to the form of analysis identified in ETSI TS 102 165-1 [2] by identifying means to exploit weaknesses to see how far an attacker could get, and what business process or data might be impacted through exploitation of that vulnerability. A particular characteristic of penetration testing identified in ETSI TS 103 305-1 [i.7] is that it requires more human involvement and analysis. As outlined in clause 6, and in AVA_VAN, the evaluator is mandated to conduct penetration testing. There are no ETSI standards for the conduct of penetration testing, however some aspects of penetration testing are addressed in ETSI TS 103 305-1 [i.7] (see clause 7.2 below). There are many industry guides, and some guidance to the evaluator in Common Criteria Part 3 [1] and in CEM [3]. One key document in this regard is NIST SP 800-115 [i.21] but it is also recognized that there are considerable public resources that offer training in a number of forms of penetration testing (see Annex A). ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 17
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7.2 Application of CSC-18 from ETSI TS 103 305-1
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ETSI TS 103 305-1 [i.7] addresses Penetration Testing in Control 18 and this is addressed in more detail below with movement of some elements to mandated actions of the developer in order to be able to meet the expectations of the evaluator. Table 5: Review of CSC18 from ETSI TS 103 305-1 [i.7] to AVA_VAN Safeguard Asset Type Security Function Safeguard Title Safeguard Description 18.1 Documentation Govern Establish and Maintain a Penetration Testing Program Establish and maintain a penetration testing program appropriate to the size, complexity, industry, and maturity of the enterprise. Penetration testing program characteristics include scope, such as network, web application, Application Programming Interface (API), hosted services, and physical premise controls; frequency; limitations, such as acceptable hours, and excluded attack types; point of contact information; remediation, such as how findings will be routed internally; and retrospective requirements. 18.2 Network Detect Perform Periodic External Penetration Tests Perform periodic external penetration tests based on program requirements, no less than annually. External penetration testing should include enterprise and environmental reconnaissance to detect exploitable information. Penetration testing requires specialized skills and experience and should be conducted through a qualified party. The testing may be clear box or opaque box. 18.3 Network Protect Remediate Penetration Test Findings Remediate penetration test findings based on the enterprise's documented vulnerability remediation process. This should include determining a timeline and level of effort based on the impact and prioritization of each identified finding. 18.4 Network Protect Validate Security Measures Validate security measures after each penetration test. If deemed necessary, modify rulesets and capabilities to detect the techniques used during testing. 18.5 Network Detect Perform Periodic Internal Penetration Tests Perform periodic internal penetration tests based on program requirements, no less than annually. The testing may be clear box or opaque box. The content of CSC-18.1 shows the essential requirement to have a penetration testing programme within the organization. The result of having this as an organizational stance is expected that in the development parts of the organization that in addition to the conventional functional, interoperability, and maintenance testing activities that the development groups have enabled penetration testing teams (e.g. red-teaming). In this example Red-teams may be used to address CSC-18.2, and CSC-18.5 with mirror Blue-teams addressing CSC-18.3 and CSC-18-4. 7.3 Formal and semi-formal test definitions applied to vulnerability analysis As identified in ETSI TS 103 993 [i.8] using the test purpose notation described in ETSI ES 202 553 [i.9] it can be shown how any requirement in the system should be tested. It is strongly recommended that the developer, in the documentation suite (see clauses 5.1 and 5.2 above) includes, either by reference or directly in the package, the relevant test standards, including a TSS&TP. In preparing a TSS&TP using the TPLan notation of ETSI ES 202 553 [i.9] it should be clear to both the developer and to the evaluator how any security function is to be tested. EXAMPLE: The Test Purpose copied below from ETSI TS 103 993 [i.8] identifies the objective of the test, the pre-conditions and the behaviour to be verified. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 18 TP Id ONDS-IA-001 Test Objective The identity shall always be authenticated on first presentation and periodically thereafter (the latter also is used to verify the operation of periodic re-establishment of a security association (here for authentication)). Reference REQ-31, REQ-30, REQ-4, REQ-8 (implicit), REQ-22, REQ-29 Configuration PICS Selection Initial conditions with {IUT in NotIdentified and NotAuthenticated} with {IUT 'having relevant algorithms and key formats defined in the security policy} Expected behaviour ensure that { when {IUT receives 'Startup' or 'Reauthentication timer expires'} then [IUT sends authentication-claim containing 'semantic or canonical identifier'} when {IUT receives authentication-verification} then {IUT in Authenticated and Identified} } ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 19 Annex A (normative): Application of tools for penetration testing A.1 Overview of penetration testing phases A system cannot be made immune to attack, but can be made more resilient or resistant to attack. In this case the conventional analysis of identifying what the system is, the attack surface and the boundary of that attack surface, and the purpose of the system and its defences, are all critical to determining where the system is most at risk from exploit. The developer has to assume that the system will be vulnerable even if all protections are implemented, if only because some of the system will be implemented with errors, or the assumptions made by the designer will be proven to be false. EXAMPLE 1: A designer may assume that data in memory with strict access control cannot be altered without authorization, i.e. assumes that the only means to read and write data is through the access control system. However, if there is no strict hardware protection of the memory elements there is a potential to modify the memory content electrically. Thus, it may be necessary to specify not just the strict security controls (e.g. access control, authentication) but also the form of memory device used. EXAMPLE 2: An integer value may be represented as having only 8 bits of range (i.e. 0 to 255), but stored in a 64 bit memory structure on the assumption, by the designer, that only the relevant 8 bits of the field are read and the rest ignored. If however a coding error reads the value as a 16- or 32- or 64- bit value and there is no bounds checking to verify the number is in the correct range the system may end up operating on invalid data. If the value is assigned a meaning "maximum speed" with a view to throttling back the system when the speed is exceeded, and this was encoded as 0C in hex as an 8-bit element but when read as a 32-bit element read 1F 1F 1F 0C then the system, without bounds checking (i.e. it acts on the entire 32 bits and not on the 8 relevant bits), could overstress the machine (allowing it to run to dangerous speed) and cause damage. It is expected that an unbounded penetration test will succeed to break one or more TSFs, or bypass one or more TSFs. The particular application of AVA_VAN provides some boundaries to the penetration testing. The primary aim of a penetration test is to show exploitation of a system by means of a discovered vulnerability. One model of penetration testing is the 5-phase model from EC-Council [i.22] that is elaborated for the present document in the succeeding clauses. NOTE: Many of the tools described in this annex can be readily found online (e.g. kali.org [i.6]). A.2 Information Gathering NOTE: This phase is often also referred to as Reconnaissance. Addressed in large part by ETSI TS 102 165-1 [2]. May exploit security controls given in ETSI TS 103 305-1 [i.7] in order to determine the assets and control of the organization, in addition the analyst may apply the ZT-Kipling method from ETSI TS 104 102 [i.14] to assist in determining the legitimacy of any asset in the system. See also clause 5.2.5.2 of the present document and the role of each of the cited documents in building evidence of the rigour of the system and its likely attacks. A.3 Vulnerability Discovery Vulnerability discovery is addressed in ETSI TS 102 165-1 [2] by systematically identifying how any weakness in an asset, or combination of assets, can be attacked (the definition of vulnerability requiring both a weakness and a means to exploit that weakness). ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 20 Many known vulnerabilities have been listed in public repositories, and have been evaluated and rated using the CVE metrics [i.25] or GCVE metrics [i.24]. As a minimum the developer shall be expected to show that any such listed, and publicly known, vulnerabilities have been mitigated and can be declared as having no impact on the system. EXAMPLE 1: The US based National Vulnerability Database (NVD), is historically a repository of vulnerability management data created and maintained by the U.S. government that analyses software vulnerabilities published in the Common Vulnerabilities and Exposures (CVE) database. The NVD rates the severity of known vulnerabilities using the Common Vulnerability Scoring System (CVSS). A CVSS calculator available online uses a system of metrics very similar to those given in ETSI TS 102 165-1 [2]. EXAMPLE 2: The Global CVE Allocation System (GCVE) [i.24] is a modernized approach to the CVE systems that is more decentralised than prior systems but which, similarly, should be treated as a resource by developers to give assurance that publicly known vulnerabilities have been examined and mitigated. EXAMPLE 3: A wider listing of similar repositories can be found in ETSI TR 103 306 [i.23]. A.4 Exploitation This is not addressed in the present document in detail. The role of exploitation is to actually verify the identified penetration actually works. In practice exploitation, and the creation of any application or process to achieve it, should be treated as any other development project. A.5 Pivoting and Exfiltration In this case an attacker has made an initial entry to the system and may exploit that to cause further damage (e.g. privilege escalation). A.6 Reporting The aim of a report in conventional penetration tests is based on an understanding that a pen-test has been requested by a client and the report identifies the nature of the vulnerabilities that have been identified and exploited. For the purposes of the present document this element of a pen-test is not addressed. ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 21 Annex B (informative): Application of VAN in regulation B.1 EU Cyber security act The CSA [i.1] identifies the following definitions (see also clause 3.1) for assurance. The main body of the present document maps the expectation of testing in VAN to these levels. NOTE: The present document does not consider basic assurance level in detail but for completeness it is shown below. High assurance level: assurance that ICT products, ICT services and ICT processes where the corresponding security requirements, including security functionalities, are provided at a level intended to minimize the known cybersecurity risks, and the risk of incidents and cyberattacks carried out by actors with significant skills and resources. Substantial assurance level: assurance that the ICT products, ICT services and ICT processes where the corresponding security requirements, including security functionalities, are provided at a level intended to minimize the known cybersecurity risks, and the risk of incidents and cyberattacks carried out by actors with limited skills and resources. Basic assurance level: assurance that the ICT products, ICT services and ICT processes where the corresponding security requirements, including security functionalities, are provided at a level intended to minimize the known basic risks of incidents and cyberattacks. B.2 EU Cyber Resilience Act Applies the general expectation of the CSA. B.3 EU Network and Information Security Directive 2 Applies the general expectation of the CSA. B.4 Sector specific regulation B.4.1 DORA Not specifically addressed but in financial markets stress tests are used as a close equivalent of some forms of penetration testing to determine the resilience of markets to attack (see Regulation (EU) 2022/2554 [i.16]). B.4.2 Vehicle type regulation Applies the general expectation of the CSA (see Regulation (EU) 2019/2144 [i.17]). B.4.3 Medical devices Applies the general expectation of the CSA (see Regulation (EU) 2017/745 [i.18]). ETSI ETSI TS 102 165-3 V1.1.1 (2025-12) 22 History Document history V1.1.1 December 2025 Publication
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1 Scope
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The present document provides an overview of the history and facets of the risk management ecosystem. The overview includes the history of this activity, the concepts and specifications that emerged, the diverse venues, use cases, and the contemporary state-of-the-art mechanisms for meeting imposed obligations.
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2 References
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2.1 Normative references
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Normative references are not applicable in the present document.
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2.2 Informative references
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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 may be useful in implementing an ETSI deliverable or add to the reader's understanding, but are not required for conformance to the present document. [i.1] Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October 2024 on horizontal cybersecurity requirements for products with digital elements and amending Regulations (EU) No 168/2013 and (EU) 2019/1020 and Directive (EU) 2020/1828 (Cyber Resilience Act) (Text with EEA relevance). [i.2] Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive) (Text with EEA relevance). [i.3] Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011 (Text with EEA relevance). [i.4] European Commission: "Risk Management in the Commission, Implementation Guide". [i.5] NIST: Risk Management History. [i.6] National Bureau of Standards FIPS 31: "Guidelines for Automatic Data Processing Physical Security and Risk Management (1974)". [i.7] National Bureau of Standards: "FIPS 41, Computer Security Guidelines for Implementing the Privacy Act of 1974 (1975)". [i.8] National Bureau of Standards FIPS 65: "Guidelines for Automatic Data Processing Risk Analysis (1979)". [i.9] RAND: "Security Controls for Computer Systems", February 1970. [i.10] GovernmentAttic: "Five (5) Defense Science Board (DSB) reports, 1974-1978". [i.11] MITRE: "Proposed Technical Evaluation Criteria for Trusted Computer Systems." (Nibaldi Report). [i.12] Common Criteria for Information Technology Security Evaluation. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 7 [i.13] RAND Corp: "RM-3420-PR, On Distributed Communications: Introduction to Distributed Communication Networks", August 1964. [i.14] AFIPS Proceedings: Bernard Peters: "Security considerations in a multi-programmed computer system", April 1967. [i.15] IEEE Computer Society, Lipner: "The Birth and Death of the Orange Book", 2015. [i.16] National Computer Security Conferences (1979-2000). [i.17] FAS: "NSA/NCSC Rainbow Series". [i.18] NIST NISTIR 90-4262: "Secure Data Network System (SDNS) Key Management Documents", 1990. [i.19] National Bureau of Standards FIPS 500-153: "Guide to Auditing for Controls and Security", April 1988. [i.20] NIST SP 800-12: "An Introduction to Computer Security", October 1995. [i.21] NIST SP 800-12 Rev.1: "An Introduction to Information Security", June 2017. [i.22] NIST SP 800-39: "Managing Information Security Risk", March 2011. [i.23] NIST SP 800-160 Vol. 1: "Engineering Trustworthy Secure Systems", November. 2022. [i.24] NIST SP 800-60 Rev.2: "Guide for Mapping Types of Information and Systems to Security Categories", January 2024. [i.25] NIST SP 800-53A Rev.5: "Assessing Security and Privacy Controls in Information Systems and Organizations", January 2022. [i.26] BlackDuck: "Security Risk Assessment Threat Modelling Best Practices. [i.27] NIST SP800-37 Rev.2: "Risk Management Framework for Information Systems and Organizations: A System Life Cycle Approach for Security and Privacy", December 2018. [i.28] NIST SP800-137A: "Assessing Information Security Continuous Monitoring (ISCM) Programs: Developing an ISCM Program Assessment", May 2020. [i.29] ETSI TS 103 305-1: "Cyber Security (CYBER); Critical Security Controls for Effective Cyber Defence; Part 1: The Critical Security Controls". [i.30] CIS: "Controls Mapping to NIST SP 800-53". [i.31] ENISA: Risk Management Standards, March 2022. [i.32] BSI DIN 27076: Cyber RisikoCheck, May 2023. [i.33] CIS: Risk Assessment Method 2.0. [i.34] NCSC: Risk Management, 2.0. [i.35] ANSSI: EBIOS Risk Manager. [i.36] NIST SP 800-218: "Secure Software Development Framework (SSDF) Version 1.1", February 2022. [i.37] NIST SP 1800-44A: "Secure Software Development Security, and Operations (DevSecOps) Practices", July 2025. [i.38] USDOD: "DevSecOps Continuous Authorization Implementation Guide," March 2024. [i.39] OWASP: "The OWASP Risk Assessment Framework". [i.40] U.S. Dept. of Defense: "DevSecOps Fundamentals Guidebook: DevSecOps Tools and Activities", March 2021. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 8 [i.41] NIST AI 100-1: "Artificial Intelligence Risk Management Framework", January 2023. [i.42] SIPRI: "Cyber Risk Reduction in China, Russia, the United States and the European Union" June 2024. [i.43] Fair Institute: "FAIR Risk Management". [i.44] USDOD: "DOD Instruction 8510.01, Risk Management Framework for DOD Systems", July 2022. [i.45] NIST: "NIST Risk Management Framework (RMF)". [i.46] ReversingLabs: "Assess & Manage Commercial Software Risk". [i.47] Wikipedia: "Risk Management Framework". [i.48] ETSI TS 102 165-1: "Cyber Security (CYBER); Methods and protocols; Part 1: Method and pro forma for Threat, Vulnerability, Risk Analysis (TVRA)". [i.49] ETSI TR 103 937: "Cyber Security (CYBER); Cyber Resiliency and Supply Chain Management". [i.50] centraleyes: "7 Best Cyber Risk Management Platforms of 2024". [i.51] XM Cyber: "Continuous Threat Exposure Management (CTEM)". [i.52] NTIA: "Cyber Risk Management (CSCRM)". [i.53] Cyber Risk Institute: "Cyber Profile for the Financial Sector". [i.54] Sedona Conference: "The Sedona Conference Commentary on a Reasonable Security Test", The Sedona Conference Journal, Vol 22, 2021. [i.55] NIST: "Software Security in Supply Chains: Software Bill of Materials (SBOM)", November 2024. [i.56] Regulation (EU) 2019/881 of the European Parliament and of the Council of 17 April 2019 on ENISA (the European Union Agency for Cybersecurity) and on information and communications technology cybersecurity certification and repealing Regulation (EU) No 526/2013 (Cybersecurity Act) (Text with EEA relevance). [i.57] Consolidated text: Commission Implementing Regulation (EU) 2024/482 of 31 January 2024 laying down rules for the application of Regulation (EU) 2019/881 of the European Parliament and of the Council as regards the adoption of the European Common Criteria-based cybersecurity certification scheme (EUCC) (Text with EEA relevance). [i.58] ENISA: "Cyber Resilience Act implementation via EUCC and its applicable technical elements". [i.59] CEN/CENELEC: "A Risk-Based Approach to Sectoral Cybersecurity: Introducing EN 18037:2025", 16 April 2025. [i.60] NSA: "The 60 Minute Network Security Guide (First Steps Towards a Secure Network Environment", 16 October 2001. [i.61] NSA: "Guide to Securing Microsoft Windows 2000 Group Policy: Security Configuration Tool Set", May 2001. [i.62] ETSI TR 103 305-4: "Cyber Security (CYBER); Critical Security Controls for Effective Cyber Defence; Part 4: Facilitation Mechanisms". [i.63] Commission Delegated Regulation (EU) 2022/30 of 29 October 2021 supplementing Directive 2014/53/EU of the European Parliament and of the Council with regard to the application of the essential requirements referred to in Article 3(3), points (d), (e) and (f), of that Directive (Text with EEA relevance). [i.64] ETSI TR 104 034: "Cyber Security (CYBER); Software Bill of Materials (SBOM) Compendium". ETSI ETSI TR 104 117 V1.1.1 (2025-12) 9 [i.65] ISO/IEC 27005:2022: "Information security, cybersecurity and privacy protection — Guidance on managing information security risks". [i.66] ISO/IEC 31000:2018: "Risk management — Guidelines". [i.67] NIST SP 800-128: "Guide for Security-Focused Configuration Management of Information Systems," October 2019. [i.68] NIST SP 800-61 Rev.3: "Incident Response Recommendations and Considerations for Cybersecurity Risk Management", April 2025. [i.69] NIST SP 800-34 Rev.1: "Contingency Planning Guide for Federal Information Systems", March 2023. [i.70] NSA/CSS: "Cybersecurity Advisories & Guidance". [i.71] ENISA: "Risk Management". [i.72] ENISA: "Compendium of Risk Management Frameworks with Potential Interoperability", January 2022. [i.73] ENISA: "Interoperable EU Risk Management Framework", January 2023. [i.74] ENISA: "Interoperable EU Risk Management Toolbox", February 2023. [i.75] Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC. [i.76] 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) (Text with EEA relevance). [i.77] BSI TR-03183-2: "Cyber Resilience Requirements for Manufacturers and Products; Software Bill of Materials (SBOM)", October 2024. [i.78] Commission Implementing Regulation (EU) 2024/482 of 31 January 2024 laying down rules for the application of Regulation (EU) 2019/881 of the European Parliament and of the Council as regards the adoption of the European Common Criteria-based cybersecurity certification scheme (EUCC). [i.79] US DOD: "Chief Information Officer Library". [i.80] NIST SP 800-161 Rev.1 Upd.1: "Cybersecurity Supply Chain Risk Management Practices for Systems and Organizations", January 2024. [i.81] CISA: "National Risk Management Center Cybersecurity Division". [i.82] CISA: "Guide to Getting Started with a Cybersecurity Risk Assessment", 2022. [i.83] CISA: "SBOM Resources Library". [i.84] NIST SP 1305: "NIST Cybersecurity Framework 2.0: Quick-Start Guide for Cybersecurity Supply Chain Risk Management (C-SCRM)", February 2024. [i.85] CISA: "A Hardware Bill of Materials (HBOM) Framework for Supply Chain Risk Management", 2023. [i.86] NIST NISTIR 8376: "Key Practices in Cyber Supply Chain Risk Management: Observations from Industry", February 2021. [i.87] NSA: "Securing the Software Supply Chain: Recommended Practices Guide for Customers", October 2022. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 10 [i.88] Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) (Text with EEA relevance).
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3 Definition of terms, symbols and abbreviations
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3.1 Terms
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For the purposes of the present document, the following terms apply: risk: any event or issue that could occur and adversely impact the achievement of an organisation's operational or strategic objective risk management: continuous, proactive and systematic process of identifying, assessing and managing risks in line with the accepted risk levels, carried out at every level of an organisation to provide reasonable assurance EXAMPLE: Making more reasoned decisions (justifying why certain decisions were taken, what risk factors were considered, etc.); improving efficiency (aligning risk levels and resource and control system allocations); reinforcing the reliability of management systems (ensuring key risks have been taken into consideration and that internal control systems have been adequately reinforced) [i.4]. threat surface: total scope of potential threats that could exploit vulnerabilities within a system or network NOTE: The SIPRI report on comparative cyber risk management regimes provides a use juxtaposition of terminology [i.42].
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3.2 Symbols
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Void.
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3.3 Abbreviations
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For the purposes of the present document, the following abbreviations apply: AFIPS American Federation of Information Processing Societies AI Artificial Intelligence ANSSI Agence nationale de la sécurité des systèmes d'information (FR) ATO Authorization To Operate BSI Bundesamt für Sicherheit in der Informationstechnik (DE) CAS Controls Assessment Specification cATO Continuous Authorization To Operate CBOM Cybersecurity Bill of Materials CSCRM Cyber Security Risk Management CSS Central Security Service DAST Dynamic Application Security Testing DSB Defense Science Board (US) EBIOS Expression des Besoins et Identification des Objectifs de Sécurité HBOM Hardware Bill of Materials NBS National Bureau of Standards (US) NCSC National Computer Security Conference (US) NCSC National Cyber Security Centre (UK) NIST National Institute for Standards and Technology (US) NSA National Security Agency (US) RAF Risk Assessment Framework RAM Risk Assessment Method RMF Risk Management Framework ETSI ETSI TR 104 117 V1.1.1 (2025-12) 11 SAST Static Application Security Testing SBOM Software Bill of Materials SDNS Secure Data Network System SIPRI Stockholm International Peace Research Institute SNAC Systems and Network Attack Center
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4 History
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4.1 Timeline of risk management
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The long historical arc of risk management across the past 60 years together with highlights described in subsequent clauses is depicted in Figure 4.1-1. The timeline depicts how risk and its management arose at outset of contemporary cybersecurity with the integration of computer systems and digital networks, followed by recurrent initiatives that increased significantly in scope and diversity after 2005 as the threat surfaces and adverse consequences expanded significantly. Figure 4.1-1: Risk Management Timeline It is noted that risk management requires comprehensive risk identification and recent activity in the EU (see CRA [i.1], NIS2 [i.2] and RED [i.63] as examples) require that provision of security measures is "risk based" therefore assumes both risk management and risk identification actions are in place.
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4.2 Early period 1940 - 1995
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The earliest discussions of risk management in contemporary computer systems and networks appear to have ensued at the RAND Corporation concurrently with its research staff conceptualising packet-based digital networks [i.13]. The next six years witnessed significant studies between RAND and the NSA - resulting in a set of initial papers dealing with risk management at the seminal April 1967 AFIPS [i.14] Atlantic City Conference The five basic tenets were set by NSA's lead computer scientist, Bernard Peters, at the AFIPS Conference: 1) "security cannot be attained in the absolute sense; 2) every security system seeks to attain a probability of loss which is commensurate with the value returned by the operation being secured; ETSI ETSI TR 104 117 V1.1.1 (2025-12) 12 3) for each activity which exposes private, valuable, or classified information to possible loss, it is necessary that reasonable steps be taken to reduce the probability of loss; 4) any loss which might occur must be detected; 5) there are several minimum requirements to establish an adequate security level for the software of a large multi-programmed system with remote terminals." The AFIPS Conference was followed by an initial RAND Report to the Defense Science Board in 1970 and underscored Peters basic tenets. That document - often referred to as the Willis Ware Report after its author - identified a set of 29 inherent "computer network vulnerabilities" and set the stage for risk management activities that would follow over subsequent decades [i.9]. The Board served at the time as means for industry collaboration among multiple U.S. national security agencies on evolving risk management challenges [i.10]. Figure 4.2-1: Ware Computer Network Vulnerabilities [i.9] In 1972, the US National Bureau of Standards (NBS) launched its Risk Management Program followed by its publication in June 1974 of FIPS 31 guidelines on risk management for computer security [i.6]. FIPS 31 was very comprehensive in addressing most of the identified Ware Report vulnerabilities - consisting of eleven different sets of action ranging from physical security to supporting utilities to envisioning local disasters. It included the conduct of a risk analysis consisting of an estimate of potential losses from different threats, estimating the probability of their occurrence, and remedial measures. FIPS 41 followed in 1975 and provided a greater level of structure and detailed standards for security risk assessments and safeguard selection, physical security, information management practices, and systems security [i.7]. Security risk assessment included five different categories: 1) accidents, errors, and omissions; 2) risks from uncontrolled system access; 3) risks from authorized users of personal data; 4) risks from the physical environment and from malicious destructive acts; 5) risks from deliberate penetrations. The next cluster of developments occurred between 1978 and 1983 with the multiple initiatives and increasingly public activities of NSA's National Computer Security Center (NCSC) related to risk management. It published sets of technical reports, guides and standards for secure computer systems that subsequently became known as the Rainbow Series [i.15]. The institution of the National Computer Security Conferences provided a means for broad industry collaboration on risk management initiatives and challenges and vetting a significant number of seminal cybersecurity developments which continue today [i.16]. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 13 Among these materials was Grace Hammonds Nibaldi's landmark work in 1979 at MITRE on technical evaluation of trusted computer systems that became known as the Nibaldi Report [i.11]. She proposed a risk management schema with specific measures consisting of six protection levels with the "residual risks" enumerated at every level. In this period, NBS published further guidelines for risk analysis as FIPS 65 in late 1979 [i.8], followed by NSA's NCSC's initial Orange Book [i.17]. The set represents perhaps the most exhaustive set of cybersecurity methods and standards for computer systems and networks ever prepared and remain reflected in almost every cybersecurity activity today. The subsequent period up until 1995 was marked primarily by NSA undertaking the large-scale Secure Data Network System (SDNS) initiative which has diverse Orange Book risk management methods included in the SDNS standards [i.18], coupled with NBS publication of SP 500-153 [i.19] in 1988 providing detailed risk management auditing and measurement specification [i.19]. SDNS was designed to provide a managed risk public internet infrastructure, protocols and services that became subordinated in the market by TCP/IP based alternatives.
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4.3 Contemporary period after 1995
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The period from 1995 onwards is primarily marked by extensive introduction of open, autonomous, complex computational systems and networks coupled with an increase of threat surfaces from all manner of vulnerabilities and actors that dramatically increased the challenges of risk management. Perhaps to most seminal event marking this paradigm change was the creation by NSA of the Systems and Network Attack Center (SNAC) in August 1995 known organisationally as C4 [i.60]. SNAC set in motion a considerable array of initiatives and standards that were subsequently explained in 2001 via "The 60 Minute Network Security Guide (First Steps Towards a Secure Network Environment)" to "better understand how to reduce and manage network security risk" [i.60]. Another action taken via the National Bureau of Standards - newly minted as the National Institute for Standards and Technology (NIST) - was publishing a comprehensive 276-page Computer Security Handbook in 1995 with an entire chapter devoted to risk management [i.20]. SNAC also began addressing threats arising from "Internet-connected systems" together with diverse new practices and mitigations through NSA published critical security control safeguards and configurations [i.61]. Risk management is defined in the 1995 Handbook as "the process of assessing risk, taking steps to reduce risk to an acceptable level and maintaining that level of risk". The basic components of risk management were articulated: 1) undertake a risk assessment; 2) mitigate the risks; 3) analyse the uncertainty; 4) understand control interdependencies; 5) know the costs. See Figure 4.3-1 below. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 14 Figure 4.3-1: Risk Management Activities and Processes [i.20] The comprehensiveness of the SNAC programme and the initial Computer Security Handbook with its articulation of risk management have endured. The Controls were transferred to the Center for Internet Security and transposed into numerous ETSI specifications including the production of a Risk Assessment Method (RAM) with partners [i.29], [i.33], [i.62]. The NIST publication itself was not revised until 2017 and remains the current version with references to multiple, constantly evolving reference materials [i.21]. Over the 1995 - 2010 period, "computer security" terminology transition to "information security."Risk Management was newly articulated as a framework: 1) framing risk; 2) assessing risk; 3) responding to risk; and 4) monitoring risk. See Figures 4.3-2 and 5.1-1 below. Figure 4.3-2: NIST SP 800-12 Risk Management Framework [i.21] ETSI ETSI TR 104 117 V1.1.1 (2025-12) 15 The risk management provisions in SP 800-12 Rev 1 [i.20] remain the most comprehensive and exhaustive articulation of risk management today and includes numerous additional publications that are constantly evolving [i.22], [i.28], [i.36], [i.37], [i.41], [i.55], [i.67], [i.68], [i.69], [i.80], [i.84], [i.86] and [i.87]. Noteworthy is that the ETSI Critical Security Controls [i.29] provide an effective set of relevant controls within this framework, and a mapping to NIST SP 800-53A, "Assessing Security and Privacy Controls in Information Systems and Organizations" is available [i.30]. In parallel to much of the above, development of the ISO Common Criteria for Information Technology Security Evaluation [i.12] took steps to unify the security evaluation standards existing at this time: the European ITSEC standard, developed by France, Germany, the Netherlands and the UK; the U.S. TCSEC standard (aka. Orange Book) developed by the United States Department of Defense and the Canadian CTCPEC derived from the TCSEC standard. By unifying security evaluation criteria, the objective was to avoid re-evaluation of products addressing international markets. Common Criteria version 1.0 was issued in 1994. A central theme of Common Criteria is to demonstrate that the security functions deployed adequately meet the risks identified. In the early 2000s ETSI took its place in the Risk Management arena with a step towards "design for assurance" in which it was identified as necessary to identify risks and to be able to demonstrate that mitigations were adequate. This initiative therefore built on the foundations of SP 800-12, the Critical Security Controls, the Common Criteria and others to develop, first the TVRA method (in ETSI TS 102 165-1 [i.48] in 2003) but to evolve it by application in the development of standards as a framework for risk mitigation. 4.4 Emerging trends: software assurance and expansion of venues After 2005, the risk management domain became marked by four major trends - a focus on software assurance, the expansion of risk management frameworks in multiple international venues, sector-specific profiles, and diverse legal obligations, especially in EU legislation. As ICT devices became increasingly virtualised with constantly evolving software running on ubiquitous generic networked hardware, software became the principal "threat surface." Sharing the associated risk management burdens became essential. Multiple national security communities from ranging from NSA and the Rainbow Books in the 1980s to the Common Criteria Control Board in the 1990s, sought to institute improved levels of software assurance as part of risk management frameworks through diverse certification schemes that proved enormously costly and completely ineffective [i.15]. Furthermore, the Common Criteria schemes could not be applied to autonomous, open public information infrastructures where the software was constantly changing. The establishment of the non-profit SAFECode organisation in 2007 based on the successes of major software vendor initiatives and improvement of increasingly complex code sets marked a turning point in risk management that became the basis for NIST publishing its Secure Software Development Framework (SSDF) [i.36]. The platform has been further integrated into Risk Management via the DevSecOps construct [i.37]. Security is integrated into the core of DevSecOps phases and weaved into the fabric that touches each phase depicted in Figure 4.3-2, above. This integrated and wrapped approach to security facilitates automated risk characterization, monitoring, and risk mitigation across the totality of the application lifecycle. DevSecOps also inherently is entwined with the introduction of emerging Software Bill of Materials requirements [i.38]. The second significant trend was manifested by the increasing globalisation risk management frameworks. NIST instantiated portions of its risk management framework in a set of ISO 31000 series standards in 2009. France's ANSSI published its EBIOS risk manager in 2010 [i.35]. In the past several years, there had been an unending stream of national, regional, and industry cyber risk management guidelines and tools that are treated in clause 5 below. These contemporary risk management materials have also included assessment methods that provide some measurable values to the risk attributes [i.33]. The third significant trend - sector specific risk management - has been notable in multiple industry sectors where there are substantial liability exposures and driven especially by insurance industry efforts to measure risk. A prominent Artificial Intelligence sector Risk Management Framework (AI RMF) appeared in early 2023 that includes an AI RMF Playbook, Roadmap, and Crosswalk [i.41]. The fourth significant trend - legal obligations - is most prominently exemplified in EU legislation. The use of "risk" and "risk-management in the five principal EU cybersecurity legislative enactments after 2021 is shown in Table 4.4-1, below. The EC maintains a risk-management website [i.4] as does the U.S. NTIA a site for Cyber Risk Management (CSCRM) [i.52]. The U.S. DOD has promulgated cyber-risk related procurement requirements [i.44]. The Sedona Conference which sets legal normative standards for adjudications of burden allocation adopted its "reasonable security test" based on risk-management outcomes [i.54]. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 16 Table 4.4-1: Risk and Risk-Management in EU Cybersecurity Legislation Legislative Instrument Use of "risk" Use of risk- management AI Act [i [i.88] 777 3 DORA [i.3] 344 3 NIS2 [i.2] 145 53 CRA [i.1] 179 1 GDPR [i.76] 75 0 RED [i.63] 14 0 eIDAS [i.75] 11 0 EUCC [i.78] 10 25
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5 Risk management ecosystem
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5.0 The ecosystem ontology
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Figure 5.0-1 provides a high-level view of the contemporary Risk Management ecosystem ontology that emerged from the SNAC programme beginning in 1995 - placing the core standards cluster at the centre with five identified derivative groups that provide different profiles of the core provisions. Figure 5.0-1: High-level view of the cyber risk management ecosystem
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5.1 Core Risk management process standards
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Over several decades, the three basic risk assessment actions and four risk mitigation actions outlined in Figure 4.3-1 above have not changed. All the subsequent treatments by NIST and derivatives in Figure 5.0-1 have simply grouped the actions as processes and then enhanced with treatments of life cycles and bills of material shown in Figure 5.1-1. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 17 NIST SP 800-39 NIST SP 800-37 Rev. 1 NIST SP 800-37 Rev. 2 • Risk framing • Risk assessment • Responding to the risk • Monitoring • Categorize System • Select Controls • Implement Controls • Access Controls • Authorize System • Monitor Controls • Prepare • Categorize • Select Controls • Implement Controls • Access Controls • Authorize System • Monitor Controls Figure 5.1-1: Core Cyber Risk Management Processes During the period after 2015, the risk management ecosystem witnessed a focus on a pair of significant idealised dimensions to the core process. One dimension emphasized the cyclical nature of the processes and became known as DevSecOps. The second dimension emphasized in greater detail on identification and analysis of the software components and became known as Software Bill of Materials (SBOM). See Figures 5.1-2 and 5.1-3 below. Actual implementation of SBOM, however, has resulted in several challenges and constraints [i.64]. Figure 5.1-2: Additional risk management process dimensions [i.55] Figure 5.1-3: DevSecOps Phases and Continuous Feedback Loops [i.37] ETSI ETSI TR 104 117 V1.1.1 (2025-12) 18
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5.2 Risk management derivative standards clusters
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5.2.1 International standards
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A considerable array of international standards for risk management have emerged and examples are enumerated below. NIST/NSA Risk Management Standards, SP 800-39 family [i.22] The NIST family of de facto international risk management standards represent the continuum of NSA SNAC programme joint activity that provide the foundation of all the derivatives and collectively constitute the state of the art. Published in 2011 as a successor to the 1995 risk management handbook, SP-39 consists of a family of specifications that have been continuously updated and expanded and include: • "NIST Risk Management Framework (RMF)", August 2025 [i.45]. The RMF site provides continuing notice of recent updates. • NIST SP 800-60 Rev. 2: "Guide for Mapping Types of Information and Systems to Security Categories", January 2024 [i.24]. • NIST SP 800-53A Rev. 5: "Assessing Security and Privacy Controls in Information Systems and Organizations", January 2022 [i.25]. • NIST SP 800-34 Rev.1: "Contingency Planning Guide for Federal Information Systems", March 2023 [i.69]. • NIST SP 800-61 Rev.3: "Incident Response Recommendations and Considerations for Cybersecurity Risk Management", April 2025 [i.68]. • NIST SP 800-128: "Guide for Security-Focused Configuration Management of Information Systems, October 2019 [i.67]. • NIST SP 800-37 Rev.2: "Risk Management Framework for Information Systems and Organizations: A System Life Cycle Approach for Security and Privacy", December 2018 [i.27]. • NIST SP 800-137A: "Assessing Information Security Continuous Monitoring (ISCM) Programs: Developing an ISCM Program Assessment", May 2020 [i.28]. • NIST SP 800-218: "Secure Software Development Framework (SSDF) Version 1.1", February 2022 [i.36]. • NIST SP 1800-44A: "Secure Software Development, Security, and Operations (DevSecOps) Practices", July 2025 [i.37]. • NIST AI 100-1: "Artificial Intelligence Risk Management Framework", January 2023 [i.41]. • NIST SP 800-160 Vol.1: "Engineering Trustworthy Secure Systems", Nov. 2022 [i.23]. • NIST SP 800-161 Rev.1 Upd.1: "Cybersecurity Supply Chain Risk Management Practices for Systems and Organizations", January 2024 [i.80]. • NIST SP 1800-44A: "Software Security in Supply Chains: Software Bill of Materials (SBOM)", November 2024 [i.55]. • NIST SP 1305: "NIST Cybersecurity Framework 2.0: Quick-Start Guide for Cybersecurity Supply Chain Risk Management (C-SCRM)", February 2024 [i.84]. • NIST NISTIR 8376: "Key Practices in Cyber Supply Chain Risk Management: Observations from Industry", February 2021 [i.86]. • NSA: "Securing the Software Supply Chain: Recommended Practices Guide for Customers", October 2022 [i.87]. The NIST published risk management standards are continuously enhanced and facilitated by NSA/CSS advisories, information sheets, operational risk notices and recommended configurations that are referenced and used by national security agencies globally [i.70]. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 19 ETSI TVRA (ETSI TS 102 165-1 [i.48] This specification newly updated in 2025 in a stepwise evolution since its first publication in 2003 defines a method primarily for use in undertaking an analysis of the threats, risks and vulnerabilities of an Information and Communications Technology (ICT) system to identify applicable countermeasures. The method described has been tailored to apply to pre-production but can be applied to production devices with due attention given to the possibility that the application of countermeasures may be unachievable for a re-design strategy. The method also builds from the Common Criteria for security assurance and evaluation and may be used to form part of the documentation set for the Target Of Evaluation. ETSI Cyber Resiliency and Supply Chain Management (ETSI TR 103 937 [i.49] This technical report was published in 2024 to address the increasing significant attacks on ICT infrastructure that has led to a return to cybersecurity fundamentals developed after the conceptualization of packet data networks to provide access to computer resources. It was a realization that persistent vulnerabilities in every digital element and system will always exist, that "ex ante" trust certifications were minimally useful, and that a different set of tools was necessary. The development of these tools for cyber resiliency proceeded under a broad "Zero Trust Model" aegis that includes Supply chain Bill Of Materials (SBOM), community exchange of vulnerability and remediation code, Continuous Monitoring for threat anomalies, and application of Critical Security Controls. The report is also applicable to the implementation of EU Cyber Resilience Act. ENISA Risk Management [i.71] The family of international risk management reports, specifications, and tools are significant components of ENISA's EU cybersecurity mission. The materials are continuously updated and expanded and include: • ENISA: "Compendium of Risk Management Frameworks with Potential Interoperability", Jan 2022 [i.72]. This report presents the results of desktop research and the analysis of currently used cybersecurity Risk Management (RM) frameworks and methodologies with the potential for interoperability. • ENISA: "Risk Management Standards", January 2022 [i.31]. The report provides an overview of EU legislation that increasingly refers to risk management, enumerates primarily ISO risk management standards, describes methodologies and tools that can be used to conform with or implement those standards, and makes 15 recommendations directed at EU policy makers, European SDOs, and ENISA itself. • ENISA: "Interoperable EU Risk Management Framework", January 2023 [i.73]. This report proposes a methodology for assessing the potential interoperability of Risk Management (RM) frameworks and methodologies and presents related results. • ENISA: "Interoperable EU Risk Management Toolbox", February 2023 [i.74]. This document presents the EU RM toolbox, a solution proposed by ENISA to address interoperability concerns related to the use of information security RM methods. ISO Risk Management Standards 27005 and 31000 [i.65] and [i.66] Published in 2022, ISO/IEC 27005 [i.65] provides guidance on managing information security risks to support the implementation of an Information Security Management System (ISMS) based on other ISO/IEC standards. Derived from the NIST standards, it offers a structured approach for identifying, assessing and treating information security risks across all types of organisations. Published in 2018, ISO/IEC 31000 [i.66] also derived from the NIST standards, provides generic principles and guidelines for risk management. CEN/CENELEC EN 18037:2025 [i.59] The 2025 specification describes a risk-based approach based on ISO 27000 series standards that could be used in conjunction with the EU Cyber Resilience Act across multiple stakeholder organisations. The utility for CRA requirements per se, however, is unclear because ICT risks related to threats to the availability of the ICT system can typically only be mitigated at ICT system level, not by requirements to dedicated ICT products which is the scope of the CRA. If EN 18037 assessments were carried out for the majority market sectors and application areas of ICT products, the results could be documented, and some of the documentation obligations could be undertaken. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 20 CIS/ETSI Risk Management Controls family The CIS Critical Security Controls and configuration guides were part of the original NSA/NIST risk management family of specifications and have been subsequently amplified to include platforms for assessing actual control implementations and quantitatively measuring risk. These publications have been directly and indirectly transposed into ETSI Technical Specifications and Reports and include: • ETSI TS 103 305-1 [i.29]: "Cyber Security (CYBER); Critical Security Controls for Effective Cyber Defence" . • ETSI TR 103 305-4 [i.62]: "Cyber Security (CYBER); Critical Security Controls for Effective Cyber Defence; Part 4: Facilitation Mechanisms". • CIS: "Controls Mapping to NIST SP 800-53" [i.30]. • CIS: Risk Assessment Method (RAM) 2.0 [i.33] was developed to provide a structured approach for organizations to identify, analyse, and prioritize risks related to the Critical Security Controls. The latest versions introduced different approaches to support organizations at various implementation levels (IG1, IG2, and IG3). The Controls and RAM are continuously updated and refined through a consensus-based process involving experts from government, industry, and academia that ensures the methods remain relevant and effective in addressing evolving cyber threats. OWASP Risk Assessment Framework (RAF) [i.39] The OWASP Risk Assessment Framework (RAF) consists of tools for Static Application Security Testing (SAST) and Dynamic Application Security Testing (DAST). The OWASP Risk Assessment Framework is a structured methodology for evaluating and prioritizing risks associated with web application vulnerabilities. It uses a two-dimensional approach, assessing both the likelihood of a vulnerability being exploited and the potential impact of such an event. This framework helps organizations understand and address security weaknesses in their web applications by providing a systematic way to analyse and prioritize risks. The Framework consists of five steps: 1) Identify Risks; 2) Assess Likelihood; 3) Assess Impact; 4) Calculate Risk; and 5) Prioritize and Mitigate. SIPRI Risk Management Report [i.42] The 2024 report provides an overview of cyber risk reduction terminology and regulatory measures within China, Russia, the United States and the European Union (EU), based on primary source official documents. Cyber risk reduction may be defined as a combination of risk assessment, risk management and mitigation processes, through which risks in cyberspace are identified, evaluated and addressed to reduce harm and negative impacts. This paper offers a foundation to enhance engagement among the four actors on cyber risk reduction.
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5.2.2 National standards
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A considerable array of national standards for risk management have emerged. Prominent examples are enumerated below. UK NCSC Risk Management Guidance [i.34] The 2023 guidance website provides a comprehensive 14-part compendium of topics and actions for cyber security risk practitioners to help their organisations understand and make decisions in this area. It is also helpful to those setting up a cyber security risk management functions in their organisation for the first time or looking to improve existing functions. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 21 Germany BSI Risk Management Publications Germany's Bundesamt für Sicherheit in der Informationstechnik (BSI) has produced a set of risk management publications: • BSI DIN 27076: "CyberRisikoCheck", May 2023 [i.32]. • BSI Standard 200-3: "Risk Analysis based on IT-Grundschutz", Version. 1, Oct 2017 [i.78]. The standard provides a structured approach for organizations to identify, assess, and manage information security risks. The IT-Grundschutz framework is a comprehensive methodology for establishing and maintaining an Information Security Management System (ISMS). The updated version is based on a simplified hazard model that combines the former 450 specific hazards into 46 elementary, product and technology-neutral hazards. • BSI TR-0318 3-2: "Cyber Resilience Requirements for Manufacturers and Products; Software Bill of Materials (SBOM)", October 2024 [i.77]. TR-0318 3-2 facilitates risk assessments encompassing knowledge of software components. France Agence nationale de la sécurité des systèmes d'information ANSSI Risk Management Tools [i.35] In November 2019, ANSSI published the web site based EBIOS Risk Manager as method for assessing and treating digital risks. It provides a toolbox that can be adapted, of which the use varies according to the objective of the project. EBIOS Risk Manager is compatible with the reference standards in effect, in terms of risk management as well as in terms of cybersecurity. In addition to the EBIOS Risk Manager guide, "method sheets" have been created to help users conduct each workshop described in the guide. The platform is evolved with the assistance of the Club EBIOS organisation. US Department of Defense Risk Management Framework The US DOD has initiated a number of Risk Management related programmes together with implementing specifications [i.79]. In July 2022, it published "DOD Instruction 8510.01, Risk Management Framework for DOD Systems" [i.44]. The 2022 publication updated a 2014 version and established a life-cycle approach with 7 steps found in NIST SP 800-37 Revision. 2 [i.27]. In March 2021, the DOD further published "DevSecOps Fundamentals Guidebook: DevSecOps Tools and Activities" [i.40] that further implements the SP 800-37 Revision. 2 discussing risk tolerance levels and including the establishment of a software lifecycle within the pipeline that uses management processes that meets the unique needs of the mission environment, system complexity, system architecture, software design choices, risk tolerance level, and system maturity level. The Guidebook was further updated in March 2024 with the "DevSecOps Continuous Authorization Implementation Guide" [i.38] which introduced the DevSecOps cATO (continuous Authorization to Operate) evaluation criteria [i.79]. Risk Management Frameworks (RMF) establish the continuous management of system cybersecurity risk. Current RMF implementation focuses on obtaining system authorizations (ATOs) but falls short in implementing continuous monitoring of risk once authorization has been reached. cATO attempts to emphasize the continuous monitoring step of RMF. It embraces real-time or near real-time data analytics for reporting security events essential to achieve the level of cybersecurity required to combat contemporary cyber threats and operate in contested spaces. US Dept of Commerce NTIA Cyber Risk Management [i.52] NTIA began significant cyber risk management public outreach initiatives beginning in 2017 to work with the private sector to develop an array of risk management platforms that are instantiated on a dedicated Cyber Risk Management (CSCRM) web site that include NIST and CISA enumerated above and include the following topics. • Cyber Supply Chain Risk Management for the Public. • Software Bill of Materials (SBOM) Resources Library. US DHS Cybersecurity and Information Security Agency (CISA) Cyber Risk Management [i.81] CISA has undertaken significant cyber risk management programs - especially relating to supply chain risk management - that overlap with those of NSA, NIST, and NTIA and include the following: • CISA: "Guide to Getting Started with a Cybersecurity Risk Assessment" 2022 [i.82]. • CISA: "SBOM Resources Library" [i.83]. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 22 • CISA: "A Hardware Bill of Materials (HBOM) Framework for Supply Chain Risk Management" 2023 [i.85].
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5.2.3 Industry sector guidelines
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Almost every significant industry sector has some form of cybersecurity risk management guidelines. Within the EU, as noted above, the DORA financial services sector enabling legislation uses the term "risk" no less than 344 times. It is beyond the scope of the present Technical Report to treat all the different industry sector guidelines. A representative example of how cyber risk management is effected for the financial sector can be found in the non-profit Cyber Risk Institute publication "Cyber Profile for the Financial Sector" [i.53]. A generic model for different sectors can be found in the Fair Institute model "FAIR Risk Management" [i.43].
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5.2.4 Implementation tools market
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The significant demand for cyber risk management tools has resulted in a large market for implementation tools. Some of the more prominent surveys and tools include: • centraleyes: "7 Best Cyber Risk Management Platforms of 2024" [i.50]. • ReversingLabs: "Assess & Manage Commercial Software Risk" [i.46]. • xmcyber: "Continuous Threat Exposure Management (CTEM)" [i.51]. • BlackDuck: "Security Risk Assessment, Threat Midelling Best Practices [i.26].
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5.2.5 Legal obligations
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Regulatory requirements The only risk management regulatory obligations are those of the European Union as shown in Table 4.4-1 which is effectively experimenting with the concepts as the only governmental authority promulgating risk management requirements. The challenge, however, is achieving a reasonable and proportional outcome given that risk management requires knowledge of factors spread across a constantly changing ICT system and under the autonomous control of many different parties. For example, CRA product manufacturers have very limited knowledge of the implementations of their products and no real control over them and thus cannot undertake a risk assessment. Risk assessments are typically what an end user undertakes, not a product manufacturer. Ultimately, regulatory requirements that lack proportionality and reasonableness will be determined through judicial decisions described in the judicial decisions below [i.54]. Judicial decisions Court cases related to risk management often arise from situations where a failure in risk management practices has led to harm or loss. Here's a breakdown of relevant information: 1) Risk Management Failures and Legal Liability: - Duty of Care: Organizations have a legal and ethical obligation to protect employees, customers, and others from foreseeable harm. This duty of care is a core concept in risk management. - Negligence: When an organization fails to meet its duty of care, it can be found negligent and held liable for the resulting harm. Negligence is often the basis of many risk management related lawsuits. - Risk Management Liability: Companies can be held liable for risk management failures that lead to financial losses, reputational damage, or even criminal charges. EXAMPLE: The Wells Fargo fake accounts scandal and Boeing's 737 Max incidents are examples where failures in risk management led to significant legal and financial consequences. 2) Court Cases in Specific Industries: - Technology: With the increasing reliance on technology, companies face risks related to cybersecurity, data privacy, and intellectual property. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 23 3) Examples of Risk Management Cases: - State v. Loomis (Wisconsin, 2016): This case involved the use of a risk assessment tool (COMPAS) in sentencing, raising questions about due process and algorithmic bias. - Southwest Airlines Co. v. Liberty Ins. Underwriters, Inc. (5th Cir. 2024): This case dealt with whether losses incurred due to an airline's business decisions to mitigate damages from a computer disruption were covered under a cyber insurance policy. - Cases involving duty of care: There are numerous cases related to duty of care in various sectors, highlighting the importance of organizations taking reasonable steps to prevent harm. 4) Best Practices for Risk Management: - Proactive Risk Identification and Assessment: Organizations should regularly identify and assess potential risks to their operations, employees, and stakeholders. - Robust Policies and Procedures: Implementing clear policies and procedures to address identified risks is essential. - Employee Training and Awareness: Training employees on risk management practices and fostering a culture of safety is crucial. - Continuous Monitoring and Improvement: Risk management is an ongoing process that requires continuous monitoring and improvement. In conclusion, court cases related to risk management demonstrate the legal and financial consequences of inadequate risk management practices. Organizations need to prioritize risk management, adhere to their duty of care, and take proactive steps to prevent foreseeable harm. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 24 Annex A: Bibliography • Eling, McShane, & Nguyen: "Cyber risk management: History and future research directions" Risk Management Insur Rev. 2021; 24:93-125. • IBM: "What is cyber risk management". • SAFECode: "NIST Publishes Important New Framework for Secure Software Development", June 2020. • BlackDuck: "Open Source Security and Risk Analysis Report", 25 February 2025. • BlackDuck: "Navigating the EU Cyber Resilience Act", 7 July 2025. ETSI ETSI TR 104 117 V1.1.1 (2025-12) 25 History Document history V1.1.1 December 2025 Publication
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