ETSI EN 304 626

CRA; Essential cybersecurity requirements for operating systems · vertical pack 0.1.0 · 19 clause-5 requirements

INTERIM DRAFT (V0.0.11, 2025-12-11) — early-stage ETSI CYBER-EUSR working draft; the draft's own cover carries the caution that it is provided for information and future development work only. Subject to substantial change before publication. Not cited in the Official Journal: conformance confers NO presumption of conformity today.

This is a vertical pack: a product-category standard, published in full and evaluated alongside the horizontal CRA rule pack— it supplements that pack for one Annex III category, it does not replace it. Everything below — every requirement, applicability entry, assessment block, correspondence row, threat and draft defect — is rendered from the same file the assessment engine reads. Nothing is generated at answer time, so this page cannot drift from what the product evaluates.

The same data, machine-readable, is served at /api/pack/vertical?id=en-304-626 — fetch it, keep a copy, and diff it when the draft moves. Because the standard is a moving draft, the source card pins exactly which text this pack was built from, and the draft gaps card records the defects we found in that text rather than papering over them.

On this page: source & license · how it attaches · requirement index · full text · CRA correspondence · threats · draft gaps · how it's built

Source, license and attribution

  • Source: https://labs.etsi.org/rep/stan4cra/en-304-626 (the ETSI Labs draft repository), commit 078b416a, retrieved 2026-09-02.
  • License: BSD-3-Clause, © 2025 ETSI. Redistributed with attribution as the license requires; the verbatim requirement and mitigation text below is reproduced from the interim draft.

To be plain about what that means: the normative requirement and assessment text on this page is reproduced verbatim from the interim draft under the license above, with the required copyright notice, conditions and disclaimer preserved in full below. The draft is a consultation document, not an ETSI deliverable — approved versions of ETSI standards are available only from the ETSI Documentation Service, and nothing reproduced here confers any presumption of conformity.

Full license text
Copyright 2025 ETSI Redistribution and use in source and binary forms, with or without modification, are permitted provided that the following conditions are met: 1. Redistributions of source code must retain the above copyright notice, this list of conditions and the following disclaimer. 2. Redistributions in binary form must reproduce the above copyright notice, this list of conditions and the following disclaimer in the documentation and/or other materials provided with the distribution. 3. Neither the name of the copyright holder nor the names of its contributors may be used to endorse or promote products derived from this software without specific prior written permission. THIS SOFTWARE IS PROVIDED BY THE COPYRIGHT HOLDERS AND CONTRIBUTORS "AS IS" AND ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE ARE DISCLAIMED. IN NO EVENT SHALL THE COPYRIGHT HOLDER OR CONTRIBUTORS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, OR CONSEQUENTIAL DAMAGES (INCLUDING, BUT NOT LIMITED TO, PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES; LOSS OF USE, DATA, OR PROFITS; OR BUSINESS INTERRUPTION) HOWEVER CAUSED AND ON ANY THEORY OF LIABILITY, WHETHER IN CONTRACT, STRICT LIABILITY, OR TORT (INCLUDING NEGLIGENCE OR OTHERWISE) ARISING IN ANY WAY OUT OF THE USE OF THIS SOFTWARE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGE.

How this pack attaches

The pack applies to products classified under the CRA Annex III item Operating systems (pack category id: important-1). Attaches to a product whose CRA classification matched the Annex III 'Operating systems' item, or manually. The horizontal CRA pack keeps evaluating the product either way; this pack adds the category-specific requirements on top.

Scope (the draft’s own)

## 1.1 General The present document specifies security requirements and related assessment criteria regarding the compliance of Operating Systems with EU Regulation 2024/2847. Following harmonised standards in the design and manufacture of products may ensure that the products comply with corresponding EU rules. The use of harmonised standards are voluntary. ## 1.2 Products in scope
1.2.1 General Products in scope are products whose core function and intended or reasonably foreseeable use or misuse is as an operating system. Operating systems include software products with digital elements that provide an abstract interface of the underlying hardware and control the execution of software, and that may provide services such as computing resource management and configuration, scheduling, input-output control, managing data, and providing an interface through which applications interact with system resources and peripherals. The underlying hardware may be virtualized to some degree, as when an operating system is running on a hypervisor. This category includes but is not limited to: * General purpose operating systems * Personal computing operating systems * Mobile operating systems * Server operating systems * Special purpose operating systems * Real-time operating systems * Embedded operating systems * Single-purpose operating systems Many products contain multiple operating systems which can affect the security functions of other operating system(s) in the product. For example, a Baseboard Management Controllers (BMC) contains an operating system that can manage most or all of the hardware managed by the main system operating system. Radiofrequency transmission devices often have an embedded real-time operating system and the ability to read or write to system memory or trigger interrupts. Some of the operating systems may not always be readily available as separate products and are included as components of another product. Where there may be other specifications that target that product category, it may be more relevant to review the operating system as part of that larger system rather than independently via this standard.
1.2.2 Components of operating systems that are in scope The scope is of this document is limited to the security-relevant parts of the operating system, including components that provide or are capable of modifying or controlling essential security functions of the operating system. The following non-exhaustive list of types of components are common to many operating systems and, when present, are considered security-relevant: - Kernel: The central component responsible for managing hardware resources and enforcing access controls. - Device Drivers: Software components supplied with the operating system that interact directly with hardware devices. - Security Libraries: Libraries used to provide critical security services, such as encryption, authentication, and authorization. - Authentication Services: Core authentication mechanisms required for operating system functionality. - Privileged Processes: Operating system processes running with elevated privileges or access to sensitive resources. - Software Update Mechanisms: Systems responsible for installing and updating software components supplied with the operating system. - Logging and Monitoring: Functions performed by the operating system that record security-relevant events or monitor system behavior. - Configuration Management: Management of the configuration of security-relevant operating system settings, including provisioning of secure-by-default configuration as appropriate to the product context. Other components of operating systems often contribute to the essential security of a product and should be given equal consideration, as appropriate for each product's context. ## 1.3 Products not in scope The present document does not apply to products that contain an operating system or are part of an operating system if the core purpose of the product is not that of an operating system. However, it may be useful as one part of the process of demonstrating compliance for a product containing or interacting with an operating system. The present document does not cover functions of the operating system that are not security-relevant. The present document does not cover other product categories defined in EU Regulation 2024/2847, such as hypervisors, container runtime systems, or boot managers, even where such products provide security-relevant functionality which overlaps that of an operating system.

Applicability (the draft’s own)

Editor's Note: The CRA requires the manufacturer to keep all the documentation necessary to show that the tests were conducted. In Article 13 Rec. 22, MSA's are granted the right to request "all the information and documentation, in paper or electronic form, necessary to demonstrate the conformity of the product with digital elements and of the processes put in place by the manufacturer with the essential cybersecurity requirements set out in Annex I." The objective of these requirements is to provide manufacturers with sufficient guidance to consistently satisfy such requests from the market authorities.
5.1.1 Necessity of Requirements Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information.
5.1.2 Types of Technical Requirements Testable Requirements: The essential quality of technical requirements is their capability to be verified by testing an implementation of the product. This verification ensures that the requirement can be assessed in an objective manner. If such verification is not practicable, the requirement is instead classified as a documentation requirement. Documentation Requirements: For documentation requirements, the manufacturer shall provide supporting documentation, including but not limited to configuration files and documented organizational policies to ensure that compliance with the standard can be demonstrated even when direct product testing is not feasible. NOTE: Simple process requirements (e.g., a statement that something has been done, without supporting evidence) are not acceptable and should be converted into technical requirements whenever possible and documentation requirements otherwise.
5.1.3 Assumptions Regarding Requirements #### 5.1.3.1 Testability Manufacturers are already required to provide the ability to enable testing and collect output on the product as placed on the market, and will supply instructions for enabling and collecting test data. #### 5.1.3.2 Source Code The market authorities may request source code access as part of a verification process, if necessary. #### 5.1.3.3 Mitigations Mitigations are the technical means by which a technical requirement is satisfied. Mitigations should be tailored to the use case and take into account the foreseeable and expected skill level of the product's users, appropriate for the expected operational environment, and proportional to the foreseeable risk.
5.1.3.4 Risk Transferral Some risks may be transferred partially or fully to other components of the final product, or to the user of the product. When that is the case, migitations that transfer the risk will be included as an option to fulfill a technical requirement, depending on the use case and risk factors. This section is a list of technical requirements necessary to satisfy the CRA essential requirements. Each technical requirement can be satisfied by one or more potential mitigations. Each mitigation may or may not be appropriate for an individual use case. The following section will define which mitigations will be required, depending on risk factors and/or a use case. NOT ALL MITIGATIONS ARE NECESSARY FOR ALL USE CASES. See Section 5.3 for the mappings of security profiles to mitigations and Annex C for additional information.

The 16 use cases

Applicability is declared per use case: the draft defines 16 product contexts, and each clause-5 requirement states, per use case, whether it is required. The index below renders every column; enabling the pack on an assessment means choosing one of these.

Operating system for learning and researchUC-LR
* is not used for any purpose beyond learning and research * does not store any sensitive or useful data * security is provided entirely by the environment * is highly modified by the user
Non-internet-connected device such as a bluetooth speakerUC-IoT-1
* does not store any user-specific data * has no means to connect directly to a public network * not intended to support hardware, software, or operating system changes
Internet-enabled power switchUC-IoT-2
* connects to a central service, operated by the device manufacturer, for remote data processing * stores account information to authenticate to WiFi and to cloud service provider * has a minimalistic interface, such as a single button for pairing and a reset button * does not have accessible I/O ports
Internet-connected "smart home" deviceUC-IoT-3
* e.g. a thermostat, fridge, or alarm system * connects to a central service, operated by the device manufacturer, for remote data process * stores account information to authenticate to WiFi and to cloud service provider * does not support arbitrary file storage or end-user operating system configuration changes * does not have accessible I/O ports * may display personalized information, such as location-specific weather forecast * serviced by trained professionals who do not modify software or hardware outside of manufacturer specifications
Consumer-grade home wireless routerUC-RO-1
* stores account information for authentication with ISP * not intended for end-user hardware or software modification * is exposed to the open internet
Business-grade remote door locking systemUC-OT-1
* does not store any user data * not intended for hardware or software modification * is not exposed to the open internet, and is only connected to trusted networks * only serviced by professionals * does not have accessible I/O ports * hardware likely contains tamper-evident signals which operating system can rely on
Personal mobile deviceUC-MOB-1
* stores highly sensitive personal information * large number of sensors allow mass collection of sensitive personal data * size and cost make it a common target of theft * device usage is not limited to trusted locations and loss is foreseeable * hardware and operating system configuration not intended for modification by users * end-users frequently install software of uncertain provenance * device frequently connects to untrusted networks * device frequently collects user's location at all times * device is often always on and always connected
Wearable health trackerUC-WE-1
* e.g. a smart watch or step tracker * stores information about a single user only * stored information may be highly sensitive, and is likely to be strictly structured (not arbitrary files) * does not have accessible I/O ports and is not user-modifiable * connects to a central service, operated by the device manufacturer, for remote data processing * connections are proxied by a trusted device, such as a mobile phone * is not exposed to a public network
Personal computer in a fixed and generally safe locationUC-PC-1
* hardware, software and operating system may be configured and modified by the end-user * the user may not be either highly skilled or an authorized representative of the manufacturer * foreseeably connects to a public network and to low-trust local networks, but is not reachable from the open internet * stores personal information and arbitrary files
Enterprise workstation in a fixed and generally safe locationUC-PC-2
* installed in an access-controlled workspace * serviced by trained professionals who may modify both software and hardware * connected to a public network with external mitigations, such as enterprise-grade firewalls * connects to trusted local networks * hardware likely contains tamper-evident indicators and secure elements for cryptographic storage * used for web browsing * stores business data, personal information and arbitrary files
Personal laptopUC-LA-1
* hardware, software and operating system may be configured and modified by the end-user * device is a foreseeable target of theft and tampering by untrusted 3rd parties * stores personal information and arbitrary files * unrestricted connection to a public network * is frequently connected to untrusted networks * hardware likely contains tamper-evident indicators and secure elements for cryptographic storage
Enterprise laptopUC-LA-2
* hardware, software and operating system may be configured and modified by the end-user * serviced by trained professionals who may modify both software and hardware * device is a foreseeable target of theft and tampering by untrusted 3rd parties * stores business data, personal information and arbitrary files * unrestricted connection to a public network * is frequently connected to untrusted networks * hardware likely contains tamper-evident indicators and secure elements for cryptographic storage
Personal serverUC-PS-1
* one or a small number of trusted users * installed in a fixed location at home or in a cohosting facility * connected to a public network with a firewall * connects to trusted local network * limited access permitted from a public network for specific services * semi-professional semi-automated management by one or a few people * always stationary, access to hardware interfaces unlikely
Enterprise server in a datacenter with no user accountsUC-SE-1
* installed in a monitored and secured facility * serviced by trained professionals who may modify both software and hardware * connected to a public network with external mitigations, such as enterprise-grade firewalls * connects to trusted local networks * hardware likely contains tamper-evident indicators and secure elements for cryptographic storage
Enterprise server in a datacenter with only trusted user accountsUC-SE-2
* Same as UC-SE-2 but with trusted users
Enterprise server in a datacenter hosting many untrusted user accountsUC-SE-3
* Same as UC-SE-2 but with untrusted users

Requirement index

Every requirement in one place: the 19 clause-5 requirements with their per-use-case applicability. Ids link to the full verbatim text below; each row is addressable so a review can cite specific rows.

IdRequirement (first line)UC-LRUC-IoTUC-IoTUC-IoTUC-ROUC-OTUC-MOBUC-WEUC-PCUC-PCUC-LAUC-LAUC-PSUC-SEUC-SEUC-SE
5.2.2TR-NKEV: No known exploitable vulnerabilities at first use
TR-NKEVRecognizing that there may be vulnerabilities discovered between the time that a product is placed on the market and the time of that product's first use, and that the product should be free from known vulnerabilities both when first made available and when first used by a consumer, the product shall be able to be updated at the time of first use to address all known exploited vulnerabilities which were discovered after the product's placement on the market and before that first use.
5.2.3TR-SSDD: Secure design and development
TR-SSDDThe product shall be designed and developed in a secure manner.
5.2.4TR-MISO: Prevent local unauthorized access of memory-addressable security-relevant data
TR-MISOThe product shall protect memory addresses from unauthorized access by executables under the product's control, including the product itself. This includes system memory, storage addressable via memory mapping, memory for I/O devices, and anything else accessible via the memory-related instructions in the platform.
5.2.5TR-MSAF: Mitigate memory safety errors
TR-MSAFThe product shall appropriately mitigate risks due to memory safety errors.
5.2.6TR-LMII: Limit incident impact
TR-LMIIThe product shall implement appropriate mitigations to limit incident impact.
5.2.7TR-MINI: Minimize impact on other devices and services
TR-MINIThe product shall implement appropriate mitigations to minimize impact on other devices and services.
5.2.8TR-SDEF: Secure by default configuration
TR-SDEFThe product shall operate in a secure configuration by default.
5.2.9TR-SCUD: Secure updates
TR-SCUDThe product shall be securely updateable by the user.
5.2.7TR-AUTH: Authentication and access control
5.2.7TR-CDST: Confidentiality of data stored on the product
TR-CDSTThe product shall protect data stored on the product from unauthorized access.
5.2.8TR-CDTX: Confidentiality of data transmitted by product
TR-CDTXThe product shall protect data transmitted by the product from unauthorized access.
5.2.9TR-CRYP: Encryption
5.2.10TR-IDST: Integrity of data stored on the product
TR-IDSTThe product shall protect the integrity of data stored on the product from unauthorized modification and report corruption.
5.2.11TR-IDTX: Integrity of data transmitted by the product
TR-IDTXThe product shall detect corruption of the data transmitted by the product.
5.2.12TR-DMIN: Data Minimization
TR-DMINThe product shall minimize the data processed.
5.2.13TR-AVAI: Availability
TR-AVAIThe product shall protect the availability of essential and core functions.
5.2.14TR-LMAS: Minimize exposed interfaces
TR-LMASThe manufacturer shall minimize exposed interfaces in the default configuration of the product in all operating modes, including initial configuration, during initialization, while in use, while shutting down or paused, or after reset.
5.2.15TR-LOGG: Logging and monitoring
TR-LOGGThe product shall record security-relevant internal events, including but not limited to changes to configuration and access or modification of data and functions. The product shall provide an opt-out mechanism.
5.2.16TR-SCDL: Secure deletion
TR-SCDLThe product shall provide a method of deleting all user data and settings and resetting the product to its secure-by-default configuration.
5.2.17TR-SDTR: Secure data read and transfer
TR-SDTRThe product shall provide a method to read all data and settings from the product, and if provided, securely transfer data and settings to another product.
5.2.18TR-VULH: Vulnerability handling
TR-VULHThe product shall have vulnerability handling processes compliant with [3] prEN 40000-1-3: "Cybersecurity requirements for products with digital elements – Vulnerability Handling".

● = required for that use case · — = not required. Use cases: UC-LR Operating system for learning and research · UC-IoT-1 Non-internet-connected device such as a bluetooth speaker · UC-IoT-2 Internet-enabled power switch · UC-IoT-3 Internet-connected "smart home" device · UC-RO-1 Consumer-grade home wireless router · UC-OT-1 Business-grade remote door locking system · UC-MOB-1 Personal mobile device · UC-WE-1 Wearable health tracker · UC-PC-1 Personal computer in a fixed and generally safe location · UC-PC-2 Enterprise workstation in a fixed and generally safe location · UC-LA-1 Personal laptop · UC-LA-2 Enterprise laptop · UC-PS-1 Personal server · UC-SE-1 Enterprise server in a datacenter with no user accounts · UC-SE-2 Enterprise server in a datacenter with only trusted user accounts · UC-SE-3 Enterprise server in a datacenter hosting many untrusted user accounts.

5.2.2TR-NKEV: No known exploitable vulnerabilities at first use

TR-NKEVRecognizing that there may be vulnerabilities discovered between the time that a product is pla…Clause 5.2.2

Requirement (verbatim from the interim draft)

Recognizing that there may be vulnerabilities discovered between the time that a product is placed on the market and the time of that product's first use, and that the product should be free from known vulnerabilities both when first made available and when first used by a consumer, the product shall be able to be updated at the time of first use to address all known exploited vulnerabilities which were discovered after the product's placement on the market and before that first use.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.3TR-SSDD: Secure design and development

TR-SSDDThe product shall be designed and developed in a secure manner.Clause 5.2.3

Requirement (verbatim from the interim draft)

The product shall be designed and developed in a secure manner.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.4TR-MISO: Prevent local unauthorized access of memory-addressable security-relevant data

TR-MISOThe product shall protect memory addresses from unauthorized access by executables under the pr…Clause 5.2.4

Requirement (verbatim from the interim draft)

The product shall protect memory addresses from unauthorized access by executables under the product's control, including the product itself. This includes system memory, storage addressable via memory mapping, memory for I/O devices, and anything else accessible via the memory-related instructions in the platform. The product does not need to protect against unauthorized access by elements of the platform it is running on (e.g. CPU microcode, devices on the system bus, other operating systems in the device, a hypervisor). Future iterations of the standard may add this requirement for appropriate use cases.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.5TR-MSAF: Mitigate memory safety errors

TR-MSAFThe product shall appropriately mitigate risks due to memory safety errors.Clause 5.2.5

Requirement (verbatim from the interim draft)

The product shall appropriately mitigate risks due to memory safety errors.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

Preparation

None

Verdict

each involved thread fails to read or write the target data and takes a segmentation fault, has error handling code executed, or is terminated in all tests => PASS, otherwise FAIL

Evidence the standard asks for

error messages, log message, or the product reboots or halts

Guidance

Most memory safety mitigations have the same Verdict and Evidence: For each mitigation grouped under requirement TR-MSAF, for each field Preparation, Verdict, or Evidence, if it is not specified for that test, then the above Preparation, Verdict, or Evidence field shall apply.

5.2.6TR-LMII: Limit incident impact

TR-LMIIThe product shall implement appropriate mitigations to limit incident impact.Clause 5.2.6

Requirement (verbatim from the interim draft)

The product shall implement appropriate mitigations to limit incident impact.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

Preparation

None

Verdict

each involved thread fails to read or write the target data and takes a segmentation fault, has error handling code executed, or is terminated in all tests => PASS, otherwise FAIL

Evidence the standard asks for

error messages, log message, or the product reboots or halts

Guidance

Most memory safety mitigations have the same Verdict and Evidence: For each mitigation grouped under requirement TR-LMII, for each field Preparation, Verdict, or Evidence, if it is not specified for that test, then the above Preparation, Verdict, or Evidence field shall apply.

5.2.7TR-MINI: Minimize impact on other devices and services

TR-MINIThe product shall implement appropriate mitigations to minimize impact on other devices and ser…Clause 5.2.7

Requirement (verbatim from the interim draft)

The product shall implement appropriate mitigations to minimize impact on other devices and services. Editor's Note: We hope that there will be additional contributions to this section in the future.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.8TR-SDEF: Secure by default configuration

TR-SDEFThe product shall operate in a secure configuration by default.Clause 5.2.8

Requirement (verbatim from the interim draft)

The product shall operate in a secure configuration by default.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.9TR-SCUD: Secure updates

TR-SCUDThe product shall be securely updateable by the user.Clause 5.2.9

Requirement (verbatim from the interim draft)

The product shall be securely updateable by the user.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.7TR-AUTH: Authentication and access control

Editor's Note: We anticipate that future revisions of this document will include state-of-the-art authentication requirements. This section should reference authentication and access control standards.

5.2.7TR-CDST: Confidentiality of data stored on the product

TR-CDSTThe product shall protect data stored on the product from unauthorized access.Clause 5.2.7

Requirement (verbatim from the interim draft)

The product shall protect data stored on the product from unauthorized access.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.8TR-CDTX: Confidentiality of data transmitted by product

TR-CDTXThe product shall protect data transmitted by the product from unauthorized access.Clause 5.2.8

Requirement (verbatim from the interim draft)

The product shall protect data transmitted by the product from unauthorized access.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.9TR-CRYP: Encryption

Editor's Note: We anticipate that future revisions of this document will include state-of-the-art encryption requirements, including references to appropriate encryption standards not already included in the Agreed Cryptographic Mechanism and CRA Addendum.

5.2.10TR-IDST: Integrity of data stored on the product

TR-IDSTThe product shall protect the integrity of data stored on the product from unauthorized modific…Clause 5.2.10

Requirement (verbatim from the interim draft)

The product shall protect the integrity of data stored on the product from unauthorized modification and report corruption. Guidance: Integrity may be protected by the environment, permissions, duplication, backups, and/or checksums.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.11TR-IDTX: Integrity of data transmitted by the product

TR-IDTXThe product shall detect corruption of the data transmitted by the product.Clause 5.2.11

Requirement (verbatim from the interim draft)

The product shall detect corruption of the data transmitted by the product. Guidance: Integrity may be protected by the environment, permissions, duplication, backups, and/or checksums.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.12TR-DMIN: Data Minimization

TR-DMINThe product shall minimize the data processed.Clause 5.2.12

Requirement (verbatim from the interim draft)

The product shall minimize the data processed.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.13TR-AVAI: Availability

TR-AVAIThe product shall protect the availability of essential and core functions.Clause 5.2.13

Requirement (verbatim from the interim draft)

The product shall protect the availability of essential and core functions.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.14TR-LMAS: Minimize exposed interfaces

TR-LMASThe manufacturer shall minimize exposed interfaces in the default configuration of the product…Clause 5.2.14

Requirement (verbatim from the interim draft)

The manufacturer shall minimize exposed interfaces in the default configuration of the product in all operating modes, including initial configuration, during initialization, while in use, while shutting down or paused, or after reset.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.15TR-LOGG: Logging and monitoring

TR-LOGGThe product shall record security-relevant internal events, including but not limited to change…Clause 5.2.15

Requirement (verbatim from the interim draft)

The product shall record security-relevant internal events, including but not limited to changes to configuration and access or modification of data and functions. The product shall provide an opt-out mechanism.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.16TR-SCDL: Secure deletion

TR-SCDLThe product shall provide a method of deleting all user data and settings and resetting the pro…Clause 5.2.16

Requirement (verbatim from the interim draft)

The product shall provide a method of deleting all user data and settings and resetting the product to its secure-by-default configuration. Guidance: Overwriting all user-writable storage or encrypting all user data and deleting the key are two secure deletion mechanisms.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.17TR-SDTR: Secure data read and transfer

TR-SDTRThe product shall provide a method to read all data and settings from the product, and if provi…Clause 5.2.17

Requirement (verbatim from the interim draft)

The product shall provide a method to read all data and settings from the product, and if provided, securely transfer data and settings to another product.

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

5.2.18TR-VULH: Vulnerability handling

TR-VULHThe product shall have vulnerability handling processes compliant with [3] prEN 40000-1-3: "Cyb…Clause 5.2.18

Requirement (verbatim from the interim draft)

The product shall have vulnerability handling processes compliant with [3] prEN 40000-1-3: "Cybersecurity requirements for products with digital elements – Vulnerability Handling".

Applicability

Per clause 5.1.1: "Not all requirements are necessary for all products. The mapping table at the end of each requirement enumerates the set of risk factors and product use cases for which the requirements are necessary. See Annex C for more information." This interim draft carries no per-requirement applicability tables; clause 5.3 assigns MITIGATIONS to security profiles instead (see draftGaps).

This interim draft contains no assessment block for this requirement. Recorded in the draft gaps.

Correspondence to the CRA

The draft’s own correspondence table: which of its clauses address which essential requirement of CRA Annex I. This is the draft’s claim, reproduced as it stands — not Vandorisk’s judgment of coverage, and (status block above) not a presumption of conformity.

CRA provisionDraft clause(s)
No known exploitable vulnerabilitiesNKEV
Secure design, development, productionSSDD, LMII
Secure by default configurationSDEF
Secure updatesSCUD
Authentication and access control mechanismsAUTH*
Confidentiality protectionMISO, LMII, CDST, CDTX, CRYP*
Integrity protection for data and configurationMISO, IDST, IDTX
Data minimizationDMIN
Availability protectionAVAI, LMII
Minimize impact on other devices or servicesMINI, SDEF, AVAI, SSDD, LMII
Limit attack surfaceMISO, LMAS, SSDD, LMII
Exploit mitigation by limiting incident impactMISO, LMII, AVAI, SSDD
Logging and monitoring mechanismsLOGG
Secure deletion and data transferSCDL, SDTR
Vulnerability handlingVULH

Where the table covers CRA Annex I Part 1 only, the Part 2 (vulnerability handling) obligations remain assessed through the horizontal CRA pack(II.1–II.8).

Threat catalogue

The 10 threats the draft derives its requirements against, verbatim:

TH-UEVUUnknown exploitable vulnerabilities
Attacker may use unknown exploitable vulnerabilities in the product implementation to get unauthorized access to product assets.
TH-KEVUKnown exploitable vulnerabilities
Attacker may use known exploitable vulnerabilities in the product implementation to get unauthorized access to product assets.
TH-UAPPUnauthorized access to product assets via unprotected physical interfaces in default configuration
Attacker may use unprotected debug or management interfaces to get unauthorized access to product assets via physical access in the default configuration of the product.
TH-UAPSUnauthorized access to product assets via unprotected local software access in default configuration
Attacker may use unprotected debug or management interfaces to get unauthorized access to product assets via local software access in the default configuration of the product.
TH-UAPNUnauthorized access to product assets via unprotected network interfaces in default configuration
Attacker may use unprotected debug or management interfaces to get unauthorized access to product assets via the network in the default configuration of the product.
TH-UADTUnauthorized access to confidential data transmitted
Attacker may use network access to get unauthorized access to confidential data transmitted by the product.
TH-PDOSDenial of service attack on product functions via user or network access
Attacker may use user or network access for a denial-of-service attack on product functions.
TH-DDOSDenial of service attack on other products via exploitation of vulnerabilities or unauthorized use of product functions
Attacker may use the network to exploit vulnerabilities in the product to attack other products.
TH-MQSEMasquerading authorized server
Attacker may masquerade as an authorized server to get unauthorized access to product assets.
TH-LEAKData leak through side channels
Attacker may use the ability to run arbitrary software on the product to get unauthorized read access to confidential data.

Draft gaps

Defects and holes we found in the interim draft while building this pack — recorded rather than papered over; they will be rechecked against each new draft. A standard under consultation is allowed to have holes. A pack that hides them is not.

  • TR-SCUD: clause 5.2.9 contains a bare TODO heading (5.2.9.5 — the draft notes it awaits a submission from an unavailable ETSI member).
  • TR sections without any Requirement text in this interim draft: TR-AUTH, TR-CRYP — TR-AUTH ("future revisions will include state-of-the-art authentication requirements") and TR-CRYP ("waiting on the cross-vertical cryptography approach"; there is no Annex K). They are kept as empty topics, not as answerable requirements.
  • Clause numbering collides in this draft (three sections numbered 5.2.7, two 5.2.8, two 5.2.9, and two mitigation headings numbered 5.2.8.4); requirements and mitigations are identified by their TR-/MI- codes, which are unique.
  • assessment criteria drafted for only 2 of 19 requirements: only TR-MSAF and TR-LMII carry a requirement-level assessment block (their shared "Default Preparation, Verdict, and Evidence"); the other 17 requirements have assessment: null. Assessment prose does exist per MITIGATION (bulleted Objective/Preparation/Activities/Verdict/Evidence inside each entry of a requirement's mitigations list, preserved verbatim), because this draft has not yet separated clause-6 assessment criteria from clause-5 requirements — clause 6 (Conformity Assessment) is empty apart from an editor's note saying the guidance stays adjacent to the requirements for now.
  • Clause 5.3 (Risk Mitigation Sets) assigns mitigations per security profile SP-* using bare codes, several of which clause 5.2 never defines (SUAP, SUAO, SUVP, SUOE, SUDC, AUTH, CRYP, VULH, DMIN, KEVT-vs-SCAN alternates and MSAF-*/MZRO-*/MRWX-* wildcards). Per-use-case applicability therefore cannot be derived reliably and is not fabricated: every loaded requirement is treated as applicable (applicability {}), and the profile tables remain in the draft for manual consultation.
  • Four availability mitigations under TR-AVAI are TODO stubs with no normative text yet (MI-FDRP, MI-LMEM, MI-FAIR, MI-DOST) — their verbatim TODO lines are preserved in the mitigations list.
  • Annex D.4 names risk-transfer mitigations that clause 5.2 does not define (MI-SUDC, MI-SUOE, MI-SUAO) — dangling references in this interim draft.
  • This draft has no Annex K (cryptography) and no Annex R (RDPS); rdps is loaded empty. Annex A maps by CRA requirement description rather than Annex I item numbers, and flags AUTH and CRYP as 'waiting on cross-vertical'.
  • The draft's ids are TR-XXXX (requirements) and MI-XXXX (mitigations); it contains no REQ-prefixed ids. MI-SCFS references "TR-SDDV", a code defined nowhere — the surrounding section is TR-SSDD.
  • Annex C numbers its threats C.4.3–C.4.7 then C.4.9–C.4.13 — C.4.8 does not exist in this interim draft; the 10 published threats are loaded.

How this pack is built, and corrections

The pack is produced by a deterministic parser over the vendored draft text pinned in the source card— no model writes or rewrites any requirement. When ETSI updates the draft, the pack is rebuilt from the new text, the draft gaps are rechecked, and the result ships as a new pack version — never a silent edit.

The interim draft and, once published, the standard itself are the authoritative texts — this pack reproduces and cites them, it does not replace them, and nothing on this page is legal advice. If you find an error — a mis-parsed requirement, an applicability entry that does not match the draft, a gap we missed — write to hello@vandorisk.com. The horizontal pack this one attaches alongside is published at /pack, with every tracked vertical standard listed there.