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CVD policy: what belongs in it

The coordinated vulnerability disclosure (CVD) policy tells reporters what they can expect and what you expect from them. The Policy field in your security.txt points to it. BSI TR-03183-3 sets out its minimum content in section 4.4.

Why a policy?

Anyone who finds a flaw wants to know whether reporting it is safe: whether they risk a complaint, whether anyone will reply and when the flaw becomes public. A clear policy answers this up front. It lowers the barrier for a proper report and helps prevent flaws from being published unannounced.

Under the TR the policy is mandatory (4.2.7) and needs its own web page, reachable without JavaScript and without login (4.5.2). For manufacturers under the Cyber Resilience Act, the regulation requires a coordinated vulnerability disclosure policy (Annex I, Part II, point 5).

Checklist under TR-03183-3 section 4.4

ContentLevelTR
Date of last change visible, policy clearly attributable to the manufacturer, reviewed yearlyRequired4.4.1
Notify the national CSIRT without undue delay for actively exploited vulnerabilities (in Germany CERT-Bund)Required4.4.2
PSIRT and CSIRT role mailboxes with keys and fingerprintsRequired4.4.3
Confidentiality, no disclosure of personal data without consent, no criminal charges if the policy is followed, no NDA, recommendation of encrypted e-mailRequired4.4.4
Listing in a hall of fame on requestRecommended4.4.4 f
What counts as a valid vulnerabilityRequired4.4.5
Code of conduct for reporters and consequences of non-compliance; reports are still handledoptional4.4.6
Accept e-mail and phone as reporters' contact; no report closed by a single analystRequired4.4.7
Personal reply within 5 working days, detailed feedback within 10 working daysRequired4.4.8
Easy-to-find anonymous reporting option with a note on limited processingRequired4.4.9
Publication of confirmed vulnerabilities within 90 days, at least in ENISA's EUVDRequired4.4.10
Conditions for closing the processRequired4.4.11

The TR also recommends a reward programme (bug bounty). Since March 2026 you can state in your security.txt whether you offer one, using the Bug-Bounty field.

The draft from the generator

Below the generator you can create a draft as a Markdown file with all required items of the checklist and your addresses and keys from the form, in English or German. Open items are in square brackets: manufacturer name, scope, fingerprints, privacy policy address.

The draft is a starting point, not legal advice. Check every commitment for whether you can keep it during holidays and with a deputy, and clarify open questions, such as waiving civil action, with your legal counsel. Our own policy shows what a finished one looks like: security-txt.eu/security-policy/.

Where the policy belongs

  • On its own page of your website, for example /security-policy, readable without login and without JavaScript (TR 4.5.2).
  • Linked from your reporting page and in the Policy field of your security.txt.
  • In a language users and market surveillance authorities understand (TR 4.1.1 c); English in addition makes sense, as researchers mostly report in English.

Sources