Artifact GuideGLOBALETSI EN 319 401

ETSI EN 319 401 requirements map

A clause-level map of ETSI EN 319 401 V3.1.1 requirements for trust service provider governance, security, evidence, continuity, and supplier controls.

This page maps V3.1.1. ETSI published V3.2.1 in January 2026, so confirm the required edition before using it for an independent review, customer response, or conformity-assessment discussion.

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

ETSI EN 319 401 V3.1.1 is a general policy baseline for trust service providers. Map its common requirements to the actual service, then add the service-specific standard, legal duties, and assessment scheme. ETSI published V3.2.1 in January 2026, so do not combine requirement text or identifiers from the two editions without a documented change review. For the qualified signature/seal certificate reference route in Implementing Regulation (EU) 2025/1943, retain the cited EN 319 401 V3.1.1 and the applicable adaptations. Publication of V3.2.1 does not replace that legally cited edition.

Section 1

Define the service boundary before mapping requirements

Start the register with the trust service, trust service policy, practice statement, each type, subscriber and relying-party audiences, and every component used to provide the service. EN 319 401 applies across trust services such as certificates, time-stamps, registered delivery, signature validation, preservation, and related service components, while other ETSI standards can refine the requirements for a specific service type.

Do not map requirements to a generic compliance program. Map them to the TSP entity, the services it provides, the systems and facilities supporting those services, the external organizations supporting them, and the public statements made to subscribers and relying parties.

  • Identify the applicable trust service policy and the practice statement used to address it.
  • Separate customer-visible terms and conditions from internal procedures and security operating records.
  • List external support organizations, subcontractors, cloud services, and trust service component providers before assigning controls.
  • Record when a service-specific ETSI standard, conformity-assessment scheme, or legal requirement adds more detail than EN 319 401.
Section 2

Map clauses 5 and 6 to governance records

The first requirement group is governance, not tooling. Clause 5 requires risk assessment, risk treatment, security requirements, operational procedures, regular review, and management approval of residual risk. Clause 6 then turns those decisions into the practice statement, terms and conditions, and information security policy.

A useful requirements map should show which document or record proves each obligation: the risk assessment, management approval, trust service practice statement, published terms, notice process for material practice-statement changes, information security policy, asset inventory linkage, and configuration-check interval.

  • Risk assessment: identify, analyse, evaluate, treat, review, and obtain management acceptance of residual risk.
  • Practice statement: document how the TSP addresses the applicable trust service policy and external-support obligations.
  • Terms and conditions: include use limits, subscriber obligations, relying-party information, log retention period, liability limits, legal system, complaints, assessment status, contact information, and availability undertakings.
  • Information security policy: document, approve, implement, maintain, communicate, and review the policy and related asset inventory.
Section 3

Map clause 7 to operational control families

Clause 7 begins with internal organization. Map organization reliability, non-discriminatory practices, applicable financial-resource or liability-insurance duties, financial stability, complaint and dispute procedures, and segregation of conflicting duties before moving to human resources, assets, access, cryptography, physical security, operations, and networks.

Evidence must match both the requirement and its modality. Trusted roles require appointment and acceptance records; assets require applicable inventory fields; privileged access requires review records. V3.1.1 requires regular vulnerability scans, says they should occur quarterly, requires daily updates for the specified malware detection and removal software, and requires penetration testing after changes the TSP determines are significant.

  • Organization: retain financial-resource or insurance evidence where applicable, complaint and dispute procedures, and a segregation-of-duties map for conflicting responsibilities.
  • People and roles: maintain job descriptions, trusted-role appointments, segregation of duties, least-privilege access, security training, and remote-working conditions where remote work is allowed; V3.1.1 says threat and security-practice updates should occur at least every 12 months.
  • Assets and media: maintain classified asset inventories, acceptable-use and handling rules, storage-media lifecycle procedures, and return-of-assets procedures for staff or third-party changes.
  • Systems and access: document privileged accounts, strong authentication, access-right reviews, change control, patch decisions, configuration monitoring, and protection against malicious software.
  • Networks and facilities: maintain protected security perimeters, zones based on risk, rule-set reviews, separate administration networks, trusted channels, vulnerability scans, and penetration tests after significant changes.
Section 4

Treat incidents, evidence, continuity, and termination as mapped requirements

EN 319 401 places incident handling and audit evidence inside the requirement set. The map should therefore include continuous monitoring and logging, incident response, reporting, event classification, post-incident review, evidence collection, business continuity, backup, crisis management, and termination planning.

This part of the map should be concrete because it is often inspected after a problem. Include log categories, alert follow-up roles, reporting paths, documented incident records, root-cause reviews, UTC time synchronization for audit logs, record retention tied to terms and conditions, backup integrity checks, recovery-test results, crisis-management reviews, and termination steps for subscribers, relying parties, authorities, subcontractors, private keys, and evidence transfer.

  • Incident map: connect monitoring, alarms, response procedures, escalation, reporting, event reassessment, post-incident review, and critical-vulnerability handling.
  • Evidence map: retain records for legal evidence and continuity, protect confidentiality and integrity, synchronize audit-log time with UTC, and retain records for the period disclosed in terms and conditions.
  • Continuity map: define disaster recovery delays, backup locations and integrity checks, recovery testing, crisis roles, authority communications, and use of National CSIRT or competent-authority information where applicable.
  • Termination map: keep an up-to-date termination plan covering notifications, public termination information, subcontractor authorization, evidence maintenance or transfer, private-key destruction or withdrawal, service transfer where possible, and funding arrangements.
Section 5

Add compliance and supply-chain requirements to the same register

The register is incomplete if it stops at internal systems. Clause 7.13 requires evidence of applicable legal requirements, feasible accessibility for trust services and end-user products, and personal-data protection measures. Clause 7.14 adds supplier, ICT supply-chain, cloud-service, outsourcing, subcontractor, SLA, monitoring, and supplier-register requirements.

For supplier-dependent services, keep the TSP accountable in the map. EN 319 401 says a TSP using other parties to provide parts of its service maintains overall responsibility for conformance with the supply-chain policy, information security policy, and trust service policy requirements.

  • Compliance evidence: link legal-requirement evidence, accessibility considerations, and personal-data safeguards to the service boundary.
  • Supplier selection: map cybersecurity specifications, risk and classification levels, source diversification, vendor lock-in limits, and critical-supply-chain risk assessments.
  • ICT acquisition: request software-component information, implemented security functions, secure configuration requirements, validation methods, critical-component identification, origin traceability, and assurance that delivered products function as expected.
  • Third-party operation: keep agreements, liability terms, SLAs or audit mechanisms, security clauses, supplier monitoring, incident-driven reviews, and a current supplier-and-agreement register.
Section 6

Quality checks for an EN 319 401 requirements map

Before using the map in an assessment or procurement response, test whether every row can be understood without hidden context. Each row should identify the clause or requirement, service boundary, applicability decision, owner, control, evidence artifact, review trigger, and source.

Flag gaps instead of filling them with broad compliance claims. A TSP may need service-specific ETSI requirements, an eIDAS qualification context, a conformity-assessment scheme, or customer contract terms before a requirement can be interpreted precisely.

  • No orphan controls: every control should trace to an EN 319 401 clause, a service-specific requirement, or a documented internal risk decision.
  • No generic evidence: name the actual artifact, such as a practice statement, terms page, risk acceptance, access review, vulnerability-scan report, incident record, UTC clock log, backup recovery test, termination plan, supplier agreement, or supplier register.
  • No unsupported status claims: do not say the service is qualified, assessed, certified, or conformant unless the evidence names the scope, scheme, assessor, date, and service boundary.
  • No stale assumptions: review the map after material changes to the trust service, practice statement, supplier set, cloud environment, key management, network zones, incident process, legal context, or required EN 319 401 edition.
Primary sources

References and citations

etsi.org7 citations
Referenced sections
  • Primary source for EN 319 401 scope, requirement identifiers, TSP policy requirements, operational control families, evidence retention, continuity, termination, compliance, and supply-chain requirements.
  • Supports the page scope: EN 319 401 defines general operation and management policy requirements for Trust Service Providers and allows service-specific standards to refine them.
  • Grounds the governance mapping in clauses 5 and 6: risk assessment, practice statement, terms and conditions, and information security policy.
Show 4 more
  • Supports the control-family grouping from clause 7, including personnel, assets, access control, cryptography, physical security, operations, and network security.
  • Grounds the incident, evidence, continuity, and termination mapping in clauses 7.9 through 7.12.
  • Supports the compliance and supply-chain mapping from clauses 7.13 and 7.14, including supplier selection, ICT acquisition, cloud services, outsourcing, SLAs, and supplier registers.
  • Supports the validation criteria by tying requirement rows to the standard's clause structure, requirement identifiers, evidence duties, and review obligations.
"General Policy Requirements for Trust Service Providers"
More quoted passages
"operation and management practices of TSPs"
"management shall approve the risk assessment"
"TSP management and operation"
"Collection of evidence"
"maintain overall responsibility"
"requirements in the present document are identified"
eur-lex.europa.eu3 citations
Referenced sections
  • Primary EU legal context for trust services and qualified trust service providers, including the trust-service security and incident-notification context reflected in EN 319 401 Annex B.
  • Provides the EU legal context for trust services, qualified trust service providers, and the security and incident duties referenced by EN 319 401 Annex B.
  • Supports the EU trust-service incident context reflected in EN 319 401 Annex B, including notification of significant breaches of security or loss of integrity.
"electronic identification and trust services"
More quoted passages
"breach of security or loss of integrity"
eur-lex.europa.eu
Referenced sections
  • Article 1 and the Annex specify the adapted qualified signature/seal certificate reference route, including EN 319 401 V3.1.1. Recital 3 preserves other practices for demonstrating compliance; the reference route does not itself grant qualified status.
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