Artifact GuideGLOBALETSI EN 303 645

ETSI EN 303 645 Secure Updates and Vulnerability Disclosure

A practical guide to clauses 5.2 and 5.3 for consumer Internet of Things (IoT) vulnerability intake, security-update mechanisms, support-period publication, and assessment evidence.

Based on ETSI EN 303 645 V3.1.3 and ETSI TS 103 701 V2.1.1. Use it as implementation and assurance guidance, not for legal interpretation.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Publish the vulnerability-reporting route and the , then connect both to the product's intake, monitoring, remediation, update, isolation, replacement, and user-notification evidence. EN 303 645 clauses 5.2 and 5.3 define the outcomes with a mix of shall and should provisions; TS 103 701 supplies the separate assessment method.

Section 1

What does ETSI EN 303 645 require for vulnerability disclosure?

Clause 5.2 starts with a public . EN 303 645 says the manufacturer shall make the policy publicly available and that it shall include contact information for reporting issues plus timelines for initial acknowledgement and status updates until reported issues are resolved.

The same clause says disclosed vulnerabilities should be acted on in a timely manner and manufacturers should continually monitor for, identify, and rectify vulnerabilities in products sold or produced and associated services operated during the . Timeliness is incident-specific. The explanatory text describes 90 days as a conventional completion period for a software solution, including patches and notification; it is not a fixed deadline for every report, and hardware or deployed-device fixes can take longer.

  • Publish the disclosure policy where anybody can access it without an account or gated support flow.
  • Include a reporting contact, an acknowledgement timeline, and a status-update timeline in the public policy.
  • Treat the 90-day discussion as explanatory context, not a universal deadline. Set report-specific actions from severity, remediation complexity, coordination needs, hardware constraints, and deployed-product realities.
  • Define how reported vulnerabilities are triaged, assigned, fixed, mitigated, or disclosed when a direct software fix is not possible.
  • Maintain a vulnerability-monitoring process for the product and associated services during the , with due care for the software, hardware, and selected third parties used in the product.
  • Keep public wording precise: EN 303 645 makes the policy mandatory and states the process outcomes as recommendations; it does not itself certify that a product is secure.
Section 2

What does ETSI EN 303 645 require for secure software updates?

Clause 5.3 says software components not made immutable for security reasons should be securely updateable. The device shall have a unless a resource constraint determined by the use case prevents one. Secure installation means measures that prevent an attacker from misusing the mechanism.

Where the relevant update feature exists, V3.1.3 addresses simple installation, an automatable secure mechanism, activation of automatic updates with user consent during initialization, post-initialization update checks, controls for automatic updates and notifications, cryptography, timely delivery, authenticity and integrity, trust relationships for network delivery, user notices, and disruption notices. It also states that the manufacturer shall publish the and that the model designation shall be clearly recognizable. Devices that cannot be updated have separate recommendations for publishing the rationale and replacement support, isolation, and hardware replacement.

  • Inventory software components and identify which are updateable, immutable for security reasons, or not practicably updateable.
  • Document each update path: direct device download, associated service or mobile app delivery, web interface, USB or other physical interface, and any network dependency.
  • Protect update mechanisms against misuse such as malicious update injection, downgrade attempts, or unauthorized installation.
  • Use cryptography suitable for the update use case and document how authenticity and integrity of updates are verified.
  • Tell users when a required security update mitigates risk and when applying an update will disrupt basic device functionality.
  • Publish the - the minimum support length or an end date - in a clear, accessible way; for devices that cannot be updated, publish the rationale and replacement-support period and method.
  • Keep the product model designation accessible so a user can match the device to the correct support-period and update information.
Section 3

How should teams separate EN 303 645 duties from TS 103 701 evidence?

Treat EN 303 645 as the provision source and TS 103 701 as the assessment method. EN 303 645 says what the manufacturer, device, or update process should or shall do. TS 103 701 describes how a Supplier Organization and Test Laboratory structure the assessment of a Device Under Test through identification, an Implementation Conformance Statement (ICS), Implementation eXtra Information for Testing (), test planning, conceptual tests, functional tests, and PASS, FAIL, or INCONCLUSIVE verdicts.

A public product page can state a support period and vulnerability reporting route. A non-public evidence pack should show the entries, design details, public-document locations, test observations, and confirmations that a TS 103 701 assessor would need to evaluate those claims.

  • Use EN 303 645 clause numbers for requirements and implementation commitments.
  • Use TS 103 701 terms such as DUT, SO, TL, ICS, , conceptual test, functional test, external evidence, and verdict only when discussing assessment evidence.
  • Prepare 2-UserInfo for public disclosure-policy and support-period locations.
  • Prepare 3-VulnTypes, IXIT 4-Conf, and IXIT 5-VulnMon for vulnerability action, confirmations, and monitoring procedures.
  • Prepare 6-SoftComp, IXIT 7-UpdMech, IXIT 8-UpdProc, and IXIT 9-ReplSup for software components, update mechanisms, update procedures, isolation, and replacement support.
Section 4

Implementation checklist for product and assurance teams

Review this checklist before making an EN 303 645 claim in a product page, procurement response, assessment workbook, or release gate. Each item should be tied to a specific product model, associated service, firmware stream, and support period.

Use concrete, versioned evidence: public URLs, release records, update-mechanism descriptions, cryptographic details, user-notification screenshots, component inventories, vulnerability triage procedures, and assessor-ready references.

  • Public policy: publish vulnerability-reporting contact details and timelines for initial acknowledgement and status updates.
  • Vulnerability workflow: record vulnerability classes, actions, time frames, third-party coordination points, and confirmation that the process is implemented.
  • Monitoring: document how the team continuously monitors, identifies, and rectifies vulnerabilities affecting the DUT and associated services.
  • Triage record: for each report, retain receipt, acknowledgement, severity and affected-version analysis, owner, status updates, remediation or mitigation decision, coordinated-disclosure contacts, release evidence, and closure rationale.
  • Update inventory: map each software component to an update mechanism or to a justified reason why updates are not possible.
  • Update security: document security guarantees, cryptographic details, trust relationships, anti-downgrade behavior, and functional misuse tests.
  • User experience: verify that update application is simple, update checks occur after or during initialization, user controls exist for automatic updates or notifications where supported, and disruptive updates trigger suitable notices.
  • Support publication: make the accessible, clear, and tied to recognizable model designations.
Section 5

Common mistakes that weaken EN 303 645 secure-update claims

Claims weaken when they mix provision language, evidence language, and marketing language. Avoid saying a product is conformant unless the scope, DUT, ICS support claims, evidence, test groups, and assessment outcome are clear.

Also avoid treating secure updates and vulnerability disclosure as isolated paperwork. EN 303 645 links security updates to vulnerability handling, support periods, user communication, associated services, and third-party components.

  • Do not publish a vulnerability form without acknowledgement and status-update timelines.
  • Do not equate the with a warranty, product lifetime, or promise of every software feature update.
  • Do not claim update support without a clear that a user can find before or during product use.
  • Do not describe an update mechanism as secure unless the authenticity, integrity, cryptographic details, and trust relationship can be evidenced.
  • Do not mark update-related provisions as not applicable merely because no update is currently available for the assessor to install.
  • Do not omit associated services, mobile applications, update servers, and third-party component vendors from vulnerability and update evidence.
  • Do not cite TS 103 701 as if it creates new product duties; it supplies the conformance assessment procedure for the EN 303 645 provisions.
Primary sources

References and citations

etsi.org6 citations
Referenced sections
  • Primary ETSI source for consumer IoT vulnerability disclosure, secure software updates, support periods, update user notifications, and constrained-device update handling.
  • Primary ETSI source for clause 5.2 vulnerability disclosure duties and clause 5.3 secure-update duties for consumer IoT products.
  • Primary source for software update provisions 5.3-1 through 5.3-16, including secure installation, update checking, user notification, and support periods.
Show 3 more
  • Primary source for the consumer IoT provisions that TS 103 701 assesses.
  • Primary source for support period, user notification, secure installation, and vulnerability disclosure requirements.
  • Primary source tying vulnerability disclosure, security update timeliness, support periods, associated services, and third-party component care together.
"Cyber Security for Consumer Internet of Things: Baseline Requirements"
More quoted passages
"The manufacturer shall make a vulnerability disclosure policy publicly available."
"All software components in consumer IoT devices that are not immutable due to security reasons should be securely updateable."
"The manufacturer shall publish, in an accessible way that is clear and transparent to the user, the defined support period."
"Manufacturers are expected to exercise due care for all software and hardware components used in the product"
etsi.org6 citations
Referenced sections
  • ETSI assessment source for DUT, SO, TL, ICS, IXIT, conceptual tests, functional tests, external evidence, verdicts, and TSO 5.2/5.3 test groups.
  • Assessment source for TSO 5.2, including public accessibility checks, IXIT 2-UserInfo, IXIT 3-VulnTypes, IXIT 5-VulnMon, and confirmation evidence.
  • Assessment source for TSO 5.3 test groups covering IXIT 6-SoftComp, IXIT 7-UpdMech, IXIT 8-UpdProc, IXIT 9-ReplSup, and IXIT 2-UserInfo.
Show 3 more
  • Assessment source defining Supplier Organization, Test Laboratory, DUT identification, ICS, IXIT, test planning, verdicts, and IXIT mappings.
  • Assessment source for the evidence concepts and test groups used in this implementation checklist.
  • Assessment source explaining ICS validity, N/A justifications, IXIT completeness, and the possibility of INCONCLUSIVE verdicts when information is insufficient.
"The present document is independent from an assurance scheme and seeks to contribute to a harmonised approach to assessing the conformance of consumer IoT products"
More quoted passages
"the publication of the vulnerability disclosure policy is available for anybody."
"This test group examines that at least one update mechanism for the secure installation of software updates exists."
"The Implementation eXtra Information for Testing (IXIT) contains additional necessary information to perform the assessment."
"The TL shall perform for each provision claimed as "Yes" in the ICS the corresponding test groups"
"For every "N/A" a justification shall be given in the "Detail" column by the SO."
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