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EU Cybersecurity Certification EUCC Guide: How Common Criteria Certification Works in the EU

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By NHI Mgmt Group, edited by Lalit Choda Updated 27 October 2026 10 min read
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EUCC is the first EU-wide cybersecurity certification scheme adopted under the Cybersecurity Act, and it replaced patchwork national Common Criteria arrangements with one set of rules, one label and ongoing vulnerability duties for every certificate holder. The scheme is set out in Commission Implementing Regulation (EU) 2024/482, amended by Implementing Regulation (EU) 2024/3144 and a further amendment adopted on 8 December 2025. This guide explains who EUCC is for, how an evaluation works, what evidence and partners a vendor needs, how to prepare, what ongoing obligations follow certification, and where EUCC sits beside the Cyber Resilience Act and other schemes. It is written for product security leads and PSIRTs at hardware and software vendors, and for buyers who specify certified products. It goes deeper than the EU Cybersecurity Act and EUCS Guide on this one scheme. Status line: checked on 27 October 2026 against ENISA's EUCC scheme page and the EUCC vulnerability management guidelines v1.1. This guide is not legal advice.

Key takeaways

  • Voluntary, product-level and Common Criteria based: ENISA describes EUCC as a voluntary scheme for ICT products such as chips, smartcards, hardware and software, built on the SOG-IS Common Criteria evaluation framework already used in 17 Member States.
  • Two assurance levels: the Cybersecurity Act levels substantial and high, with vulnerability assessment depth expressed through the Common Criteria AVA_VAN components (AVA_VAN.1 to AVA_VAN.5).
  • Three parties do the work: an accredited IT Security Evaluation Facility (ITSEF) evaluates, an accredited certification body (CB) certifies, and the National Cybersecurity Certification Authority (NCCA) supervises and authorises.
  • Certification is not the end: Articles 33 to 37 of the EUCC regulation require holders to run vulnerability intake, impact analysis and remediation proposals, with CB review and possible withdrawal.
  • State-of-the-art documents matter: ENISA publishes binding "final" and endorsed "draft" documents on accreditation, smartcards, hardware security boxes, cryptography and assurance continuity.

Who the certification is for

AudienceWhy EUCC matters
Vendors of secure elements, smartcards, HSMs and security boxesThe scheme's state-of-the-art documents cover these product types in detail, and they were core users of national Common Criteria schemes
Software and network product vendorsA single EU certificate and label recognised across Member States
Public and regulated buyersA comparable assurance statement for procurement, and an EU certificate list to check
Evaluation labs and certification bodiesAccreditation and NCCA authorisation requirements specific to EUCC
PSIRT teamsVulnerability handling becomes a certification obligation with deadlines

Identity relevance is direct: smartcards, secure elements and HSMs anchor keys for PIV-style authentication, FIDO authenticators, code signing and machine identity. See the Smart Card and PIV/CAC Authentication Guide.

Evaluation format and assurance levels

An EUCC evaluation is a Common Criteria evaluation run under EU rules. The vendor defines a security target (often claiming conformance to a protection profile), the ITSEF evaluates it, and the CB issues the certificate.

ElementWhat it means in EUCCSource
Assurance level substantialThe lower of the two Cybersecurity Act levels used by EUCCEUCC guidelines, Table 1
Assurance level highThe higher level, for products whose intended use carries higher riskEUCC guidelines, Table 1; ENISA scheme page
AVA_VAN.1 to AVA_VAN.5Common Criteria vulnerability analysis components referenced across both levels; vulnerability handling timeframes depend on whether the analysed component is met or failed at the certified levelEUCC guidelines, Table 1
AVA_VAN.4 and 5Highest vulnerability analysis depth, referenced by ENISA for certified protection profilesENISA scheme page
Protection profilesCertified and recommended profiles listed in the SOG-IS registerENISA scheme page
Attack potential bands0 to 9 critical, 10 to 13 high, 14 to 19 medium, 20 to 24 low, 25 or more beyond high, used to rate vulnerabilitiesEUCC vulnerability guidelines

The precise mapping of AVA_VAN levels to substantial and high is in the implementing regulation; confirm it against the current consolidated text before scoping a target.

Prerequisites and evidence

  • Accredited partners: choose an ITSEF accredited under ENISA's ITSEF accreditation document (v1.6c) and a CB accredited under the CB document (v1.6b). For high assurance, the CB also needs NCCA authorisation; ENISA publishes authorisation guidelines (v0.7) and a conformity assessment body finder.
  • Development evidence: security target, design documentation, lifecycle and configuration management evidence, and guidance documents, as Common Criteria requires.
  • Site security: for smartcards and hardware with security boxes, the Minimum Site Security Requirements (V2, final, December 2025) apply to development and production sites.
  • Cryptography: the EUCC cryptography guidelines (v2) set agreed mechanisms and add post-quantum recommendations.
  • A working PSIRT: Article 33(2) requires holders to maintain and publish methods for receiving vulnerability information. See the PSIRT Guide.

Preparation plan

  1. Decide the assurance level from buyer demand and the risk of intended use; ENISA says the level should follow the risk of the intended use.
  2. Pick a protection profile where one exists, to reduce scoping effort and improve buyer comparability.
  3. Engage an ITSEF and CB early to agree scope, evaluation plan and any state-of-the-art documents that apply (for example the Star Methodology or Application of Attack Potential to Smartcards).
  4. Gap-assess development evidence against the Common Criteria assurance components for your target.
  5. Stand up vulnerability handling that meets Articles 33 to 37 before the certificate is issued, not after.
  6. Plan product series and changes: ENISA's guidelines on evaluation methodology for product series and on assurance continuity for changes to certified products set out how to avoid a full re-evaluation for every release.
  7. Prepare labelling: the European Commission's EUCC brand book governs certification marks and labels.

Cost, validity and maintenance

Neither the ENISA scheme page nor the guidelines publish evaluation fees; costs are set commercially by ITSEFs and CBs and depend on assurance level, product complexity and site audits. Budget for the ongoing obligations below, which continue for the life of the certificate.

ObligationArticleWhat the holder does
Intake channelArt. 33(2)Maintain and publish methods for receiving vulnerability information
Record and analyseArt. 33(3)Record each potential vulnerability and carry out a vulnerability impact analysis
Composite productsArt. 33(4)Inform holders of dependent EUCC certificates
Cooperate with the CBArt. 33(5)Share relevant information on the CB's reasonable request
RemediationArt. 36Submit a proposal for appropriate remedial action; the CB reviews the certificate under Article 13
WithdrawalArt. 35(6), Art. 14If a vulnerability cannot be remediated, the certificate is withdrawn
DisclosureArt. 37, Art. 38CB discloses confirmed vulnerability information to the NCCA, without exploit details; NCCA shares with ENISA

The ENISA guidelines set maximum durations for impact analysis of 60 or 90 calendar days depending on the case, or a period agreed with the CB (defaulting to 90 days without agreement, and recommended to stay within 180 days). The NCCA may approve a further 60 or 90 day extension, and actively exploited, publicly known vulnerabilities must be reported to the CB without undue delay with analysis time cut to the minimum. Patching takes priority over recertification. Retain analyses showing no vulnerability for at least five years. Follow ISO/IEC 29147 for disclosure, and on withdrawal register remediated publicly known vulnerabilities in the European vulnerability database or another listed repository.

Certificate validity periods are set in the implementing regulation; confirm the current maximum in the consolidated text.

Where it fits on the certification landscape

Scheme or lawRelationship to EUCC
EU Cybersecurity Act (Regulation (EU) 2019/881)Legal basis; EUCC is a scheme under it
SOG-IS Common Criteria arrangementsThe evaluation framework EUCC builds on; protection profile register still referenced
EU Cyber Resilience ActENISA says the vulnerability guidelines will be updated to align with the CRA; see the EU CRA Product Classes Guide
EUCS (cloud services scheme)A separate candidate scheme for services rather than products
FIPS 140-3 (US)Cryptographic module validation; often run in parallel for HSMs

Decision guidance

  • Substantial vs high: choose high where buyers face capable attackers or regulations reference high assurance (secure elements, HSMs). Substantial suits general network or software products where buyers want comparability more than resistance to expert attackers.
  • Small vendors: start with a protection profile and a product-series strategy to keep re-evaluation costs down.
  • Buyers: check the certificate in ENISA's certificate list, the target of evaluation scope, and whether the holder's vulnerability obligations are being met, not just the label.

Mapping and metrics

EUCC elementNIST SP 800-53 Rev. 5NIST CSF 2.0
Evaluated products in procurementSA-4GV.SC-05
Holder vulnerability handlingRA-5, SI-2ID.RA-08
Developer security testingSA-11ID.IM-02
  • Median days from vulnerability report to completed impact analysis, against the 60 or 90 day limits.
  • Certified products with an assurance continuity plan.
  • Open remediation proposals awaiting CB review.
  • Share of security-relevant suppliers (composite components) with their own EUCC certificate.

Common failure patterns

  • Treating the certificate as a one-off project: the evaluation team disbands after issue, and nobody owns the Article 33 intake and impact analysis duties, so the first reported vulnerability misses the 60 or 90 day window.
  • PSIRT and certification teams not talking: a fix ships through the normal release train without the remediation proposal the CB expects under Article 36.
  • Composite blind spots: a vendor building on a certified chip or platform is not told about vulnerabilities in the underlying component, although Article 33(4) expects the base holder to inform dependent certificate holders. Agree the channel in the supply contract.
  • Scope surprise for buyers: procurement accepts the EUCC label without reading the target of evaluation, then deploys the product in a configuration that was never evaluated.
  • Re-evaluating every release: ignoring the product series and assurance continuity guidelines and paying for full evaluations that a change scenario would have covered.
  • Weak key custody around certified hardware: an evaluated HSM or secure element does not protect machine identities whose keys are exported, shared or unrotated. See the Secrets Management Guide.

Practitioner checklist

  • Confirm whether customers or regulations expect EUCC, and at which assurance level.
  • Identify an applicable protection profile and the state-of-the-art documents for your product type.
  • Shortlist accredited ITSEFs and CBs; for high assurance, confirm CB authorisation by the NCCA.
  • Publish a vulnerability intake channel and PSIRT contact before certification.
  • Write a procedure for impact analysis within the guideline timeframes and NCCA extension requests.
  • Plan product series and assurance continuity to avoid full re-evaluation.
  • Track amendments to Implementing Regulation (EU) 2024/482, including the December 2025 change.
  • Buyers: verify certificates on the ENISA list and read the target of evaluation scope.

Standards and references

Related NHI Mgmt Group resources: EU Cybersecurity Act and EUCS Guide · EU Cyber Resilience Act Guide · PSIRT Guide · Vulnerability Disclosure Maturity Model. This guide summarises the EUCC scheme under Implementing Regulation (EU) 2024/482 and is not legal advice.

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NHIMG Editorial Note
Researched and written by the NHI Mgmt Group editorial team using AI tools, under the editorial direction of Lalit Choda. Facts are drawn from the sources listed on this page and checked by our automated quality process. Last updated 27 October 2026. Spotted an error? Use our contact page.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM and Agentic AI security. nhimg.org

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