Artifact GuideGLOBALETSI EN 319 401

ETSI EN 319 401 Conformity assessment bodies and TSP evidence scope

A focused answer on how to read references in ETSI EN 319 401 without overstating what the standard covers.

Based on ETSI EN 319 401 V3.2.1 and the current consolidated eIDAS Regulation. Assessment scope, accreditation, the applicable scheme, and the supervisory body's decision remain separate.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

ETSI EN 319 401 V3.2.1 tells a trust service provider what general policies and operating controls to maintain; it does not set the 's method, competence, accreditation, or evidence-access rules. For an EU qualified trust service, eIDAS defines the conformity assessment body as an accredited body competent to assess qualified TSPs and their qualified services. Use EN 319 403-1 and the applicable assessment scheme for the assessor's requirements, and keep the supervisory body's qualified-status decision separate from the CAB report.

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4 of 4 questions
Question 1

What does EN 319 401 say about conformity assessment bodies?

EN 319 401 V3.2.1 sets service-independent policy requirements for TSP operation and management. Its scope expressly excludes the independent assessment method, information that must be made available to assessors, and requirements imposed on those assessors.

A TSP therefore cannot use EN 319 401 alone to prove that a CAB is accredited, competent for the service, or following the required scheme. For EU qualified services, check the CAB's accreditation and scope, the scheme used, the services and locations covered by the report, and the supervisory body's qualified-status decision.

  • Use EN 319 401 to define the TSP policy, practice, security, recordkeeping, continuity, compliance, and supplier evidence that may be reviewed.
  • Do not treat EN 319 401 as the source for CAB accreditation, independence, sampling, audit-method, or assessor-competence rules.
  • When a customer asks for CAB status, separate the TSP's conformance evidence from the assessor's own authority, scope, and conformity assessment scheme.
Question 2

What evidence can a TSP prepare for assessor review?

EN 319 401 identifies TSP evidence even though it does not prescribe the CAB process. Start with the assessment scope, applicable trust service policy, practice statement, management approvals, risk assessment and treatment plan, policy set, supplier controls, incident and continuity records, and public documentation needed to demonstrate conformance.

The terms and conditions must state, for each supported trust service policy, whether the service has been assessed as conformant and, if so, through which scheme. Keep that statement aligned with the actual CAB report. Do not extend it to a different service, policy, site, supplier, or period.

  • Map the assessed service to the trust service policy being applied and the practices used to address that policy.
  • Keep management approval, publication, review responsibilities, and change-notice decisions traceable to the practice statement.
  • For customer-facing claims, ensure the terms and conditions identify whether conformity has been assessed and the conformity assessment scheme used, when such an assessment exists.
  • Avoid disclosing sensitive implementation details publicly; EN 319 401 allows relevant documentation to demonstrate conformance without requiring disclosure of sensitive aspects.
Question 3

What should not be claimed from EN 319 401 alone?

For EU qualified trust services, eIDAS requires an audit at the qualified TSP's expense at least every 24 months. The TSP must submit the CAB report to the supervisory body within three working days of receipt and inform that body at least one month before a planned audit. Those legal rules do not make every EN 319 401 assessment an eIDAS qualified-service audit.

A CAB report also does not itself grant qualified status. Under eIDAS, the supervisory body verifies compliance and grants the provider and service qualified status; the service may begin as qualified after that status appears on the trusted list. Check the current trusted-list entry as well as the report.

  • Verify CAB accreditation, competence, assessment scheme, report date, covered service, policy, sites, and exclusions outside EN 319 401.
  • Do not imply that an assessment covers all services unless the trust service policy, assessment scope, and scheme say so.
  • For outsourced service parts, keep the TSP's retained responsibility, agreements, supplier security requirements, monitoring evidence, and inclusion or exclusion from the CAB scope explicit.
  • Review the evidence package after practice-statement changes, information security policy changes, supplier changes, incidents, or changes to service provision.
Question 4

Questions and answers

Does ETSI EN 319 401 define how a CAB performs the assessment?

No. EN 319 401 defines general TSP policy and operating requirements but excludes the independent assessment method, assessor evidence-access requirements, and assessor requirements. Use EN 319 403-1, the CAB's accreditation scope, and the applicable conformity assessment scheme for those questions.

Does a CAB report make a trust service qualified under eIDAS?

No. A provider intending to start a qualified trust service submits a CAB report to the supervisory body. The supervisory body verifies compliance, grants qualified status to the provider and service, and updates the trusted list; the provider may begin offering the service as qualified only after the status appears there.

How often is an EU qualified TSP audited?

eIDAS requires a qualified TSP to be audited at its own expense at least every 24 months. It must notify the supervisory body at least one month before a planned audit and submit the resulting CAB report within three working days of receipt. The supervisory body may also audit or request an assessment at any time.

Primary sources

References and citations

etsi.org4 citations
Referenced sections
  • Primary ETSI source for EN 319 401 scope, TSP policy requirements, assessor boundary language, terms-and-conditions assessment disclosure, records, compliance evidence, and supplier controls.
  • Clause 1 excludes independent assessment methods, assessor evidence requirements, and assessor requirements from EN 319 401 and points to EN 319 403-1.
  • Clauses 6.1 and 6.2 require the practice statement, controlled disclosures, and the terms-and-conditions statement about assessment status and scheme.
Show 1 more
  • Supports the assessment boundary and retained TSP responsibility for outsourced or subcontracted service parts.
"General Policy Requirements for Trust Service Providers"
More quoted passages
"does not specify how the requirements identified can be assessed"
"whether the TSP's trust service has been assessed"
"maintain overall responsibility for conformance"
eur-lex.europa.eu3 citations
Referenced sections
  • Binding EU source for the CAB definition, qualified-TSP audit cycle, report submission, planned-audit notice, supervisory decision, and trusted-list status.
  • Article 3(18) defines a CAB for qualified trust services by accreditation and competence; Articles 20 and 21 distinguish the CAB report from supervision and the grant of qualified status.
  • Articles 20 and 21 establish the qualified-service audit interval, report-submission timing, advance audit notice, supervisory verification, grant of qualified status, and trusted-list condition.
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