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Draft Harmonized StandardCRA Annex I

EN 40000-1-3

prEN 40000-1-3: Cyber Resilience Act, Vulnerability Handling Requirements (CEN Enquiry draft)

Draft standard (prEN 40000-1-3:2025 (CEN Enquiry, October 2025)). Not yet cited in the Official Journal, so applying it does not yet confer presumption of conformity. Used as the working blueprint for a defensible, traceable vulnerability-handling process.

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This content is based on the preliminary version of EN 40000-1-3 and may change when the standard is officially published by the European Commission.

What presumption of conformity means for manufacturers

When the European Commission cites EN 40000-1-3 in the Official Journal of the EU, manufacturers who fully apply this standard can presume they are meeting the CRA's essential vulnerability handling requirements under Annex I. This is a formal legal bridge: full application of the standard removes the burden of independently demonstrating compliance with the underlying regulatory requirements.

EN 40000-1-3 covers the complete vulnerability handling lifecycle, from policy establishment through coordinated disclosure. CVD Portal implements infrastructure for every clause in the standard, allowing manufacturers to satisfy all 24 requirements through a single platform.

“Once EN 40000-1-3 is cited in the Official Journal, a manufacturer that fully applies it will be able to invoke presumption of conformity with the CRA Annex I vulnerability handling requirements under Article 27(1) of the Cyber Resilience Act. Until then it is a draft used as the working blueprint.”

Full clause coverage: 24 clauses, 24 satisfied

Every EN 40000-1-3 clause maps directly to CVD Portal features. Portal-managed artifacts are automatically verified. Tenant-managed artifacts are guided, drafted, and tracked through the obligations framework.

ClauseTitle & DescriptionArticlePortal Feature
§4.1
Vulnerability handling policy
The manufacturer shall establish, maintain, and publish a policy describing its vulnerability handling process.
PRE-1
Policy on Vulnerability Handling
Obligations tracker
§4.2
Coordinated disclosure policy
The manufacturer shall define and publish a coordinated vulnerability disclosure policy specifying how reporters are engaged.
PRE-2
Policy on Coordinated Vulnerability Disclosure
CVD policy page
§4.3
Operational security
The manufacturer shall implement operational security controls protecting the vulnerability handling process from interference.
PRE-3
Operational Security
Submission inbox
§4.4
Stakeholder communication
The manufacturer shall define channels and procedures for ongoing communication with affected stakeholders.
PRE-4
On-going Communication
Communication log
§4.5
Secure communication channel
The manufacturer shall provide a secure, authenticated channel for confidential vulnerability reports.
PRE-5
Secure Communication
PGP encryption
§5.1
Product identification
The manufacturer shall maintain a register of products with digital elements and their version histories.
PRE-6
Product Identification
Product registry
§5.2
Software component inventory
The manufacturer shall produce and maintain a software bill of materials (SBOM) for each product.
PRE-7
Identification of Software Components
SBOM manager
§5.3
Hardware component inventory
The manufacturer shall maintain an inventory of hardware components with security-relevant firmware versions.
PRE-8
Identification of Hardware Components
Hardware registry
§6.1
Security testing and review
The manufacturer shall plan and execute periodic security tests and reviews of products.
PRE-9
Planning Regular Tests and Reviews
Security reviews
§6.2
Update distribution
The manufacturer shall operate mechanisms to distribute security updates to users reliably and securely.
PRE-10
Mechanisms for Distribution
CSAF advisories
§7.1
Vulnerability intake capability
The manufacturer shall provide a publicly accessible, secure channel for receiving vulnerability reports.
RCP-1
Capability to Receive Reports
Public portal
§7.2
Vulnerability monitoring
The manufacturer shall monitor internal and external sources for vulnerability intelligence affecting its products.
RCP-2
Monitoring
Monitoring sources
§7.3
Software impact assessment
On receiving a report, the manufacturer shall identify all affected software components and versions.
RCP-3
Potentially Impacted Software Components
Threat intel
§7.4
Hardware impact assessment
On receiving a report, the manufacturer shall identify all affected hardware components and firmware versions.
RCP-4
Potentially Impacted Hardware Components
Hardware registry
§7.5
Coordinator involvement
The manufacturer shall define when and how to engage a coordinator in multi-party vulnerability cases.
RCP-5
Coordinator Involvement
Coordinator assign
§7.6
Regular security testing cycles
The manufacturer shall conduct regular security testing and reviews of its products during the active support period.
RCP-6RCP-7
Performing Regular Tests
Security reviews
§8.1
Initial assessment and triage
The manufacturer shall perform initial assessment and triage of each received vulnerability report.
VRF-1
Initial Assessment and Verification
Submission triage
§8.2
Vulnerability risk assessment
The manufacturer shall assess the risk of each confirmed vulnerability using a documented scoring methodology.
VRF-2
Vulnerability Risk Assessment
CVSS calculator
§9.1
Remediation decision
The manufacturer shall document and justify a remediation decision for each confirmed vulnerability.
RMD-1
Remediation Decision
Remediation panel
§9.2
Remediation development
The manufacturer shall develop effective remediation for confirmed vulnerabilities within defined timelines.
RMD-2
Remediation Development
Obligations tracker
§9.3
Remediation testing
The manufacturer shall test remediation before release to verify effectiveness and absence of regression.
RMD-3
Remediation Test
Obligations tracker
§10.1
Security update release
The manufacturer shall release security updates promptly and communicate availability to users.
RLS-1
Security Update Release
Obligations tracker
§10.2
Security advisory publication
The manufacturer shall publish machine-readable security advisories for disclosed vulnerabilities.
RLS-2
Release Information
CSAF advisories
§11.1
Post-release monitoring
The manufacturer shall continue monitoring for vulnerabilities in released products throughout their support lifetime.
PRA-1
Post-Release Actions
Obligations tracker

How CVD Portal satisfies each clause

§4.1 – §4.5, §7.1

Vulnerability intake and CVD policy

CVD Portal provides a branded public submission portal, CVD policy page, PGP-encrypted communication, and full submission tracking with acknowledgment timers.

§5.1 – §5.3

Product and component identification

SBOM upload and management, hardware component registry, and product identification records are maintained directly in the portal.

§6.1 – §6.2

Security testing and update distribution

Scheduled security review tracking with configurable frequencies, reminder automation, and CSAF 2.0 advisory publication for update distribution.

§7.2 – §7.6

Vulnerability monitoring and impact assessment

Monitoring source configuration, EU Vulnerability Database integration, threat intelligence, SBOM-based impact assessment, and coordinator assignment.

§8.1 – §8.2

Triage and risk assessment

Built-in CVSS calculator, severity scoring, priority assignment, and reporter communication tracking per submission.

§9.1 – §11.1

Remediation and disclosure

Structured remediation decisions, timelines, test tracking, CSAF advisory generation for machine-readable disclosure, and post-release monitoring records.

Part of the EN 40000 series

EN 40000-1-3 is the vulnerability-handling part of the wider EN 40000 series, the horizontal harmonised standards CEN and CENELEC are drafting for the Cyber Resilience Act. The companion part for the product security and risk requirements is prEN 40000-1-2.

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