Coordinated Disclosure Policy Template
A vendor-neutral CVD policy based on ISO/IEC 29147 and ENISA good practice, suitable for manufacturers who want to align with international standards rather than a purely CRA-framed document. Covers the full coordinated disclosure lifecycle from report intake through advisory publication and supply chain coordination.
Introduction & Scope
Article 13(1)[ORGANISATION NAME] is committed to working collaboratively with the security research community to identify and remediate security vulnerabilities in our products and services.
This Coordinated Vulnerability Disclosure (CVD) policy is based on ISO/IEC 29147:2018 (Vulnerability disclosure) and ISO/IEC 30111:2019 (Vulnerability handling processes), and reflects ENISA good practice guidance on coordinated vulnerability disclosure.
This policy applies to:
- All software and hardware products developed or maintained by [ORGANISATION NAME], including [PRODUCT LIST]
- Associated cloud services and APIs operated at [DOMAIN(S)]
- Mobile applications published under [ORGANISATION NAME] on [APP STORE(S)]
This policy does not cover:
- Products manufactured by third parties and sold under the [ORGANISATION NAME] brand without modification
- Products that have reached end-of-life (see [SUPPORT PAGE URL])
- Physical security vulnerabilities not exploitable remotely
Explicitly anchoring to ISO/IEC 29147 and ISO/IEC 30111 signals to researchers, auditors, and regulators that your policy follows a recognised international standard. Keep the scope statement comprehensive — gaps in scope may be treated as admissions of exclusion.
Reporting Channel
Article 13(1)To report a security vulnerability, please use one of the following channels:
Preferred method: Submit a structured report via our vulnerability disclosure portal: [PORTAL URL]
Email: [[email protected]] Please encrypt sensitive reports using our PGP key: Fingerprint: [KEY FINGERPRINT] Available at: [KEY URL] and keyserver hkps://keys.openpgp.org
security.txt: A machine-readable disclosure contact record is published at: https://[YOUR-DOMAIN]/.well-known/security.txt
We accept reports in [LANGUAGE(S)]. Reports should be treated as confidential and will not be shared outside our security team without the reporter's consent.
Please do not disclose vulnerability details publicly or to third parties before coordinating with us.
ISO 29147 requires a clearly identified, accessible reporting channel. Publishing a security.txt file (RFC 9116) is increasingly expected and simplifies automated discovery. Offering PGP encryption removes a barrier for reporters handling sensitive vulnerability details.
Triage & Acknowledgment (48-Hour Commitment)
Article 13[ORGANISATION NAME] commits to acknowledging receipt of every vulnerability report within 48 hours of receipt.
Our acknowledgment will confirm:
- That your report has been received and assigned a tracking reference ([REFERENCE FORMAT, e.g. VULN-2025-XXXX])
- The name or alias we will use to credit you (if you wish to be credited)
- An initial assessment timeline
Following acknowledgment, our security team will triage the report to determine:
- Whether the reported behaviour constitutes a security vulnerability
- Whether the affected component is within scope
- An initial severity estimate based on CVSS 3.1 or 4.0
We will inform you of the outcome of triage within [5] business days of acknowledgment.
The 48-hour acknowledgment commitment is aligned with both ISO 29147 and CRA Article 13 expectations. Providing a tracking reference establishes a shared record that supports audit trails and dispute resolution. Offering credit at acknowledgment stage avoids awkward retroactive discussions.
Severity Assessment
[ORGANISATION NAME] assesses vulnerability severity using the Common Vulnerability Scoring System (CVSS) version [3.1 / 4.0].
Severity bands and associated response priorities:
| CVSS Score | Severity | Target Remediation Time | |------------|----------|-------------------------| | 9.0 – 10.0 | Critical | [15] calendar days | | 7.0 – 8.9 | High | [30] calendar days | | 4.0 – 6.9 | Medium | [60] calendar days | | 0.1 – 3.9 | Low | [90] calendar days |
Where a vulnerability is of a type not well captured by CVSS (e.g. logic errors, privacy vulnerabilities), we will apply qualitative assessment and document our reasoning.
We will share our severity assessment with the reporter and invite them to contest it if they disagree.
Publishing your severity bands signals the seriousness with which you treat different vulnerability classes. Inviting reporters to contest your severity assessment prevents disputes and demonstrates good faith — a key element of ISO 29147's coordinated approach.
Remediation Commitment
Article 13[ORGANISATION NAME] commits to remediating confirmed vulnerabilities within the target timeframes set out in the Severity Assessment section.
Our remediation process includes:
- Root cause analysis — identifying the underlying flaw, not just the surface symptom
- Fix development and review — including code review and, for Critical/High vulnerabilities, peer review by a second security engineer
- Regression testing — ensuring the fix does not reintroduce the issue or introduce new vulnerabilities
- Release and deployment — delivering the fix to affected customers via [UPDATE MECHANISM]
If we cannot meet a committed remediation timeline, we will notify the reporter promptly, explain the reason for the delay, and agree a revised timeline. We will not ask for timeline extensions of more than [30] days without good cause.
For vulnerabilities that cannot be fully remediated (e.g. due to architectural constraints), we will provide documented mitigations and workarounds.
Being explicit about remediation steps — including root cause analysis and regression testing — demonstrates maturity to auditors and researchers. The commitment not to seek indefinite extensions is important for researcher trust.
Coordinated Disclosure Timeline (90-Day Default)
Article 13[ORGANISATION NAME] follows a 90-day coordinated disclosure model by default, consistent with ISO/IEC 29147 and CERT/CC guidance.
The coordinated disclosure clock starts from the date we acknowledge receipt of a valid vulnerability report.
Default timeline:
- Day 0: Report received and acknowledged
- Day 5: Initial triage outcome communicated
- Day 45: Interim status update provided (or earlier if remediation is complete)
- Day 90: Coordinated public disclosure (regardless of patch status, unless exceptional circumstances apply)
Exceptions and extensions:
- For Critical vulnerabilities under active exploitation, [ORGANISATION NAME] may request an accelerated disclosure timeline. We will inform the reporter immediately.
- For complex vulnerabilities requiring supply chain coordination, we may request a timeline extension of up to [30] additional days, with the reporter's agreement.
- If a vulnerability is publicly disclosed before the 90-day window, we will make best efforts to release a patch or mitigation simultaneously.
At no point will [ORGANISATION NAME] request indefinite embargo.
A 90-day default is now industry standard (Google Project Zero, CERT/CC). Documenting the clock start date and explicit exceptions prevents ambiguity. The prohibition on indefinite embargo is critical for researcher trust and differentiates you from organisations that have misused the coordinated disclosure process.
Safe Harbour
[ORGANISATION NAME] authorises good-faith security research on [ORGANISATION NAME] products and services conducted in accordance with this policy.
We will not initiate or recommend legal action against security researchers who:
- Act in good faith and comply with this policy
- Report discovered vulnerabilities to us before any public or third-party disclosure
- Limit testing to what is strictly necessary to confirm the vulnerability exists
- Do not access, modify, or delete data belonging to users other than themselves
- Do not perform testing that degrades the performance or availability of [ORGANISATION NAME] services
- Do not use social engineering against [ORGANISATION NAME] personnel
[ORGANISATION NAME] waives any claim under [APPLICABLE COMPUTER MISUSE LAW / CFAA / Computer Misuse Act / etc.] against researchers acting in accordance with these conditions.
If you are uncertain whether your intended research falls within this safe harbour, please contact us at [[email protected]] before proceeding.
A safe harbour provision is essential for a credible CVD programme. Without legal protection, researchers have strong incentives to disclose publicly rather than coordinate. Some jurisdictions allow explicit safe harbour language to provide meaningful legal protection — consult your legal team.
Advisory Publication
Annex I, Article 13Upon remediation (or, in the case of 90-day disclosure, upon the coordinated disclosure date), [ORGANISATION NAME] will publish a security advisory for all vulnerabilities rated Medium severity or higher.
Advisories will be published at: [ADVISORY URL / CSAF FEED URL]
Each advisory will include:
- CVE identifier (requested from [CVE NUMBERING AUTHORITY] or MITRE)
- CVSS base score and vector string (CVSS 3.1 or 4.0)
- Affected products and versions
- Description of the vulnerability
- Remediation guidance (patch version, upgrade instructions, or workaround)
- Credit to the reporter (where consent has been given)
- References to related advisories or upstream patches
Where possible, advisories will be published in CSAF 2.0 format (OASIS Common Security Advisory Framework) to enable automated tooling to process them.
CSAF 2.0 publication is referenced in CRA Annex I as an expected practice. CVE assignment establishes a globally trackable identifier. Providing credit by default (with opt-out) is both good practice and a meaningful incentive for researchers to report.
Supply Chain Coordination
Article 13(4)Many [ORGANISATION NAME] products include third-party and open-source components. Where a reported vulnerability originates in or affects an upstream component, [ORGANISATION NAME] will:
- Notify the upstream maintainer or vendor within [5] business days of confirming the vulnerability and its upstream origin
- Coordinate disclosure timelines with the upstream party
- Not publicly disclose upstream vulnerabilities before the upstream maintainer has had a reasonable opportunity to respond (minimum [45] days, unless active exploitation requires earlier disclosure)
Downstream notification: Where [ORGANISATION NAME] acts as a component supplier to downstream integrators or OEM customers, we will notify affected downstream parties of confirmed vulnerabilities within [5] business days of confirmation, under a mutual non-disclosure obligation pending coordinated disclosure.
Reporters who believe a vulnerability originates in an upstream component are encouraged to include component name, version, and any known CVE identifiers in their report.
Supply chain coordination is a CRA requirement and a practical necessity. Products increasingly depend on hundreds of upstream components. Documenting your upstream and downstream notification processes demonstrates that your CVD programme extends beyond your own code.
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