EU CVD Policy Template
A CVD policy template specifically written for EU manufacturers placing products on the European market. References EU-specific obligations (CRA, NIS2 intersection, ENISA), using terminology aligned with EU regulatory guidance.
Policy Overview
Article 13(1), Recital 63[COMPANY NAME] operates a Coordinated Vulnerability Disclosure (CVD) programme in accordance with the EU Cyber Resilience Act (Regulation (EU) 2024/2847), ISO/IEC 29147, and ENISA guidelines on coordinated vulnerability disclosure.
This policy is publicly accessible and describes:
- How to report security vulnerabilities in [COMPANY NAME] products
- How [COMPANY NAME] handles and responds to vulnerability reports
- The rights and protections afforded to security reporters
Single Point of Contact: [[email protected]] | [PORTAL URL]
Reference EU regulatory instruments specifically. 'Single Point of Contact' is CRA Article 13 language — using it verbatim shows alignment with the regulation. Listing the point of contact prominently is a hard requirement.
Products Covered
Article 13(4)This policy applies to all [COMPANY NAME] products with digital elements placed on the EU market, including:
Hardware products:
- [HARDWARE PRODUCT 1] (model [X], EU Declaration of Conformity: [DOC NUMBER])
- [HARDWARE PRODUCT 2]
Software products:
- [SOFTWARE PRODUCT 1] (versions [X.X]+)
Associated services:
- Cloud interface at [DOMAIN]
- Mobile applications: [APP STORE LINKS]
Products that have reached end-of-support are listed at [SUPPORT LIFECYCLE URL]. Reports for end-of-life products are accepted but response timelines may differ.
Referencing your EU Declaration of Conformity in the scope section links your CVD policy to your market placement documentation — useful for audits. Including end-of-life products with different SLAs is CRA best practice.
Reporting a Vulnerability
Article 13(1)To report a potential security vulnerability in a [COMPANY NAME] product:
Preferred method (fastest acknowledgment): Submit via our vulnerability disclosure portal: [PORTAL URL]
Alternative: Email [[email protected]] PGP fingerprint: [FINGERPRINT] (key available at [URL])
What to include:
- Product name and version
- Nature of the vulnerability (CWE category if known)
- Steps to reproduce
- Estimated severity and impact
- Proof-of-concept (optional)
- Whether you believe the vulnerability is already being exploited
Reports are accepted in: English [, German, French — edit as applicable]
ENISA guidelines recommend offering encrypted reporting channels. Asking whether exploitation is occurring helps you identify Article 14 obligations early.
Acknowledgment and Response Timelines
Article 13(1)[COMPANY NAME] commits to the following response milestones in accordance with ISO/IEC 29147 and CRA Article 13:
| Milestone | Timeline | |-----------|----------| | Acknowledgment of receipt | Within 48 hours | | Initial severity assessment | Within [5] business days | | Notification of in-scope determination | Within [10] business days | | Progress updates | Every [30] days until resolved | | Notification of patch release | Upon availability | | Security advisory publication | Within [30] days of patch |
Timelines may be extended for complex vulnerabilities affecting multiple products or upstream components. We will communicate any extensions proactively.
A table format is easy for reporters and auditors to scan. Explicitly referencing ISO 29147 and the CRA anchors your commitments to recognised standards.
Mandatory Reporting to Authorities (Article 14)
Article 14In accordance with Article 14 of the EU Cyber Resilience Act, [COMPANY NAME] is required to notify ENISA and the relevant national CSIRT when:
- A vulnerability in our product is actively exploited in the wild
- A severe security incident has occurred affecting our products
Notification timelines (from becoming aware):
- 24 hours: Early warning to ENISA
- 72 hours: Full notification with severity assessment
- 14 days: Final report with root cause and remediation
If your vulnerability report triggers an Article 14 notification, we will inform you (unless doing so would compromise an ongoing investigation or law enforcement action).
Authority notifications are made to: ENISA Single Reporting Platform and [NATIONAL CSIRT — see list at enisa.europa.eu/topics/csirts-in-europe]
Including this section in your public policy is increasingly expected by regulators and procurement frameworks. It demonstrates your Article 14 process is operational, not just planned.
Researcher Rights and Safe Harbour
[COMPANY NAME] recognises the value of good-faith security research. Researchers who comply with this policy have our commitment that:
- We will not pursue civil or criminal action against them for vulnerability research conducted in accordance with this policy
- We will not make reports to law enforcement agencies arising from their research under this policy
- We will work collaboratively with them throughout the disclosure process
In return, we ask researchers to:
- Access only data necessary to demonstrate the vulnerability
- Avoid intentional disruption of our services or exposure of user data
- Allow us a reasonable time to address vulnerabilities before public disclosure
- Comply with applicable EU and national law
This safe harbour does not extend to researchers who exploit vulnerabilities maliciously or engage in activities beyond good-faith security testing.
Framing safe harbour as 'researcher rights' is positively received in the EU security research community, which has been advocating for legal protections aligned with the EU Directive on the resilience of critical entities.
Security Advisories and CVE Assignment
Annex I[COMPANY NAME] publishes security advisories for confirmed vulnerabilities at [ADVISORY URL] in CSAF 2.0 format (OASIS Common Security Advisory Framework).
Advisories include:
- CVE identifier (we assist with CVE assignment through [CNAs/CVD Portal])
- CVSS 3.1 and/or 4.0 severity scores
- Affected products and versions
- Remediation guidance and patch links
- Reporter acknowledgment (with permission)
Advisories are published when a patch is available. For severe vulnerabilities, we may publish advisories with workarounds prior to patching.
CSAF 2.0 is increasingly the expected format for EU market advisories. Machine-readable advisories enable downstream operators to automate vulnerability response — a significant value-add.
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