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DO-326A and ED-202A: avionics cybersecurity airworthiness

Guide - Avionics cybersecurity airworthiness

Civil avionics cybersecurity is no longer a Special Condition tacked onto individual programmes. With CS 25.1319 (EASA Amendment 25/29, effective August 2024) and the corresponding 14 CFR Part 25 Section 25.1319 on the FAA side, airworthiness security is now a default certification requirement for new large aeroplanes and major changes, with DO-326A / ED-202A as the accepted process Means of Compliance and DO-356A / ED-203A as the methods companion. The framework reaches further: DO-355A / ED-204A governs the continuing airworthiness side (in-service patching, vulnerability handling), and DO-392 / ED-205A extends the same logic to ATM/ANS ground systems. This guide maps the document set, the regulatory anchors, the certification deliverables (PSecAC, SecRA, Security Architecture, SecVer, Security Compliance Summary), the TARA framework, the failure-condition mapping to attacker capability, the articulation with DO-178C and DO-254 on the safety side, and the recurring pitfalls observed during certification reviews.

The airworthiness security framework is structured by RTCA on the US side and EUROCAE on the European side, with each document published in a harmonised pair so that one specification serves both regulators.

RTCA referenceEUROCAE counterpartScopeFirst publication
DO-326AED-202AAirworthiness Security Process Specification2014
DO-356AED-203AAirworthiness Security Methods and Considerations2018
DO-355AED-204AInformation Security Guidance for Continuing Airworthiness2014, revised (ED-204A, 2022)
DO-392ED-205ACybersecurity Process Standard for ATM/ANS Ground Systemsrecent

These four documents operate as a coherent set. DO-326A defines the process: what activities must occur, what artefacts must be produced. DO-356A defines the methods: how to conduct each activity, how to score attacker capability, how to structure verification. DO-355A defines the continuing airworthiness layer: what happens after type certification, when the aircraft enters service and faces evolving threats. DO-392 extends the framework to ground-side ATM/ANS systems.

A type certification programme today typically invokes DO-326A and DO-356A together for the airborne side, with DO-355A invoked separately for in-service maintenance. None of the documents replaces the others.

Before 2024, EASA managed airworthiness security on a programme-by-programme basis through Certification Review Items, the most common of which was CRI F-19, Airworthiness Security. The CRI imposed DO-326A / ED-202A as the Means of Compliance and listed the deliverables expected.

EASA Amendment 25/29, effective August 2024, introduced CS 25.1319, Equipment, systems and installations - aeroplane intentional unauthorised electronic interaction. The new paragraph elevates airworthiness security to a default CS-25 requirement: any new large aeroplane and any major change submitted under CS-25 must include the corresponding security assessment in the certification basis, without a CRI being needed to introduce it. CS-29 carries the equivalent provision for civil rotorcraft.

The acceptable Means of Compliance pointed to are DO-326A / ED-202A (process), DO-356A / ED-203A (methods), and ED-204A (continuing airworthiness).

FAA: 14 CFR Part 25 Section 25.1319 and AC 119-1

Section titled “FAA: 14 CFR Part 25 Section 25.1319 and AC 119-1”

On the FAA side, individual programmes had historically been handled through Special Conditions issued under 14 CFR 21.16 for the Boeing 787, the Airbus A350, and other systems with high integration of e-Enabled functions. The 2024 update incorporates 14 CFR Part 25 Section 25.1319 with substantively equivalent content to CS 25.1319, making airworthiness security a default Part 25 requirement.

AC 119-1, Airworthiness and Operational Authorization of Aircraft Network Security Program (ANSP), provides operator-side guidance on the continuing-airworthiness aspects, complementing the type-certification view.

Aircraft typeSpecificationSecurity provision
Large aeroplanes (transport category)CS-25, 14 CFR Part 25CS 25.1319 / Part 25 Section 25.1319
Large rotorcraftCS-29, 14 CFR Part 29CS 29.1319 / Part 29 Section 29.1319 equivalent
EnginesCS-E, 14 CFR Part 33covered via system integration on the airframe side
Small aeroplanesCS-23airworthiness security on a case-by-case basis through Special Conditions

Process layers: parallels with DO-178C / DO-254 safety

Section titled “Process layers: parallels with DO-178C / DO-254 safety”

DO-326A mirrors the safety pipeline of ARP4754A and ARP4761A at system level, with security replacing safety. The two pipelines are co-developed.

Safety side (ARP4761A)Security side (DO-326A)Output
FHA (Functional Hazard Assessment)TARA (Threat Analysis and Risk Assessment)Identification of failure conditions / threat scenarios
Failure condition severity (Cat / Haz / Maj / Min / NSE)Threat scenario severity (same five-tier scale)Allocation of assurance level / security measures
PSSA (Preliminary System Safety Assessment)Preliminary SecRAArchitecture-driven assessment, mitigation allocation
SSA (System Safety Assessment)Final SecRACompliance demonstration, residual risk
Safety architecture (partitioning, redundancy, dissimilarity)Security architecture (segregation, defence in depth)Architectural decisions implemented in software / hardware
Verification of safety propertiesSecVer (pen test, code review, analysis)Verification evidence

The conceptual symmetry is deliberate. DO-326A reuses the failure-condition vocabulary of ARP4761A so that security and safety assessments can be cross-referenced. A threat scenario that leads to a Catastrophic outcome drives the same severity tier as the equivalent safety failure condition, and therefore the most stringent security measures and verification effort.

Failure-condition mapping for threat scenarios

Section titled “Failure-condition mapping for threat scenarios”
Failure condition classEffect on aircraft / occupantsSecurity implication
CatastrophicAircraft loss, multiple fatalitiesHighest security measures, deepest verification, independence required
HazardousLarge reduction of safety margins, serious injuryHigh security measures, structured verification
MajorSignificant reduction of safety margins, occupant discomfortModerate security measures
MinorSlight reduction of safety margins, minor inconvenienceLight security measures
No Safety Effect (NSE)No safety consequenceNo specific airworthiness security objective

DO-356A defines the TARA framework that underpins the SecRA. The TARA structures the analysis around four standard attacker-capability tiers.

Attacker capability tierCharacterisation
BasicLimited resources, off-the-shelf tools, no insider knowledge
EnhancedSkilled attacker, public exploit toolchains, some target knowledge
HighOrganised group, custom tooling, persistent access, targeted reconnaissance
ExtendedNation-state level resources, supply chain access, multi-vector campaigns

A threat scenario is then characterised by:

  • the assets at risk (data, function, integrity, availability),
  • the attack path (entry point, propagation, target),
  • the failure condition triggered if the scenario succeeds,
  • the attacker capability required,
  • the likelihood given the capability and exposure,
  • the residual risk after security measures are applied.

The TARA is refreshed at each major design milestone and after any change that affects the attack surface (architecture change, new external interface, supplier substitution). Missing a TARA refresh after a software update is a frequent finding during continued airworthiness reviews.

Assets are classified by the criticality of the failure condition they would trigger if compromised, not by their intrinsic technical category. A simple log file may be Catastrophic-critical if its tampering masks an attack on a flight-critical function, while a complex display subsystem may be only Minor-critical if its corruption does not propagate to flight-critical systems. The TARA logic is consequence-driven, not technology-driven.

DO-326A imposes a defined set of plans, analyses, and summaries, mirroring the documentary structure of DO-178C on the software side.

DeliverablePurpose
PSecAC (Plan for Security Aspects of Certification)Contractual interface with the authority; describes the security process, the standards applied, the deliverables, the schedule, the organisation. Equivalent of the PSAC in DO-178C.
Security Verification Plan (SecVer Plan)Describes the verification strategy: penetration testing, code review, fuzzing, static analysis, security analysis. Equivalent of the SVP.
Security Risk Assessment PlanDescribes the methodology to conduct the TARA and the SecRA.
DeliverableContent
SecRA (Security Risk Assessment)TARA, threat scenarios, attacker capability, residual risk, security measures and their allocation
Security Architecture DocumentDescription of security measures embedded in system architecture: segregation, cryptography, authentication, defence in depth
SecVer ReportsRecords of verification activities, with traceability to security objectives
Security Compliance SummaryConsolidation of evidence at the end of the cycle, equivalent of the SAS for software
DeliverableContent
In-Service Security PlanHow the security posture is maintained after entry into service
Vulnerability Handling ProcessDiscovery, assessment, response, communication with operators
SOC interfacesSecurity Operations Centre engagement, monitoring, incident response
Configuration managementSoftware part loadable updates, signing, deployment, rollback

Interface with safety: co-development, not sequence

Section titled “Interface with safety: co-development, not sequence”

The most frequent architectural error is treating security as a downstream addition to a safety-assessed architecture. Security measures (cryptographic isolation, authentication, intrusion detection, audit logging) often introduce new failure modes that need their own safety assessment under ARP4761A. Conversely, safety partitioning decisions (e.g. ARINC 653 partitioning under DO-178C) often constrain the placement of security measures.

The two pipelines must be co-developed:

  • joint system architecture review with safety and security teams,
  • shared failure-condition catalogue, so that a threat scenario can be checked against an existing safety failure condition,
  • shared architectural rationale, with explicit justification when a security measure changes a safety partitioning decision,
  • joint verification planning, to avoid duplicated test campaigns and conflicting test environments.

For the safety side that DO-326A interfaces with, see DO-178C and DO-254 and the broader risk assessment framework in ISO 14971, IEC 31010, FMEA, FTA.

DO-326A versus DO-355A / ED-204A: scope boundary

Section titled “DO-326A versus DO-355A / ED-204A: scope boundary”

These two documents are routinely confused in scoping discussions, because both carry the word security. They occupy different layers of the certification lifecycle.

AspectDO-326A / ED-202ADO-355A / ED-204A
PhaseType certification (before entry into service)Continuing airworthiness (after entry into service)
AudienceType certificate applicantOperator, maintainer, software part loadable supplier
OutputSecurity Compliance Summary, certification basis evidenceIn-service security plan, vulnerability handling process
Authority interactionEASA / FAA certification teamEASA / FAA continued airworthiness oversight
Companion methodsDO-356A / ED-203AOperator-side AC 119-1 and equivalents

A common scoping error is treating DO-326A as covering in-service patching, which it does not. The in-service layer is the responsibility of ED-204A and the operator-side guidance.

DO-326A versus ISO 27001: not interchangeable

Section titled “DO-326A versus ISO 27001: not interchangeable”

A second common confusion is mapping DO-326A objectives to ISO/IEC 27001 controls. The two frameworks have different vocabularies and different scopes:

  • ISO 27001 is an organisational ISMS standard: it certifies that an organisation manages information security at the management-system level, with risk-based controls applied across the enterprise.
  • DO-326A is a product / aircraft airworthiness security process: it produces evidence on a specific type design, with security measures implemented in the airborne system itself.

A supplier holding ISO 27001 certification on its corporate IT does not satisfy DO-326A objectives on a specific aircraft programme. Conversely, DO-326A compliance on a programme says nothing about the supplier's enterprise security posture. The two can coexist (and often must) but they do not substitute.

For the enterprise cybersecurity baselines on the corporate IT side, see CMMC and UK Cyber Essentials.

MilestoneSecurity activityOutput
ConceptPreliminary threat identification, security scope definitionInput to ARP4754A allocation
PDR (Preliminary Design Review)First version of PSecAC, preliminary TARA, preliminary SecRAPSecAC v1, preliminary SecRA
CDR (Critical Design Review)PSecAC finalised, security architecture frozen, security measures allocatedPSecAC final, Security Architecture Document
TRR (Test Readiness Review)SecVer Plan executed, evidence collectedSecVer Reports
CertificationSecurity Compliance Summary submitted with type certification dossierSecurity Compliance Summary
Entry into serviceSwitch to ED-204A continuing airworthiness regimeIn-Service Security Plan active
Post-EIS updateTARA refresh after any change affecting attack surfaceUpdated SecRA, updated SecVer Reports as needed

Missing the PSecAC at CDR is the single most cited finding in early airworthiness security reviews, because the document is the contractual interface that defines the process to be followed. Without it, no downstream evidence can be assessed.

PitfallConsequence
Treating cybersecurity as a bolt-on after the safety architecture is frozenLate re-architecture, partitioning decisions invalidated, programme slip
Missing PSecAC at CDRAuthority finding, security process undefined, downstream evidence unassessable
Confusing DO-326A (airworthiness) with DO-355A / ED-204A (continuing airworthiness)In-service patching process missing or under-resourced
Mapping DO-326A objectives one-to-one to ISO 27001 controlsVocabulary mismatch, gaps in airworthiness coverage
No TARA refresh after a software update or supplier changeStale SecRA, residual risk under-estimated, finding during surveillance
No SOC plan or interface for ED-204A continuing airworthinessIn-service vulnerability cannot be triaged or responded to
Confusing attacker capability tiers with safety DALSecurity measures over-engineered or under-engineered relative to the actual threat
Sequencing security verification after safety verificationConflicting test environments, duplicated effort, late discovery of architectural conflicts
Ignoring CS 25.1319 default applicability post-August 2024Filing without security deliverables, certification basis rejected
Treating ground-side and airborne-side cybersecurity as a single document setDO-392 / ED-205A scope missed for ATM/ANS ground systems

Sources & references

  1. RTCA DO-326A, Airworthiness Security Process Specification (2014) , RTCA www.rtca.org/
  2. EUROCAE ED-202A, Airworthiness Security Process Specification (2014, European counterpart of DO-326A) , EUROCAE www.eurocae.net/
  3. RTCA DO-356A / EUROCAE ED-203A, Airworthiness Security Methods and Considerations (2018) , RTCA / EUROCAE www.rtca.org/
  4. EUROCAE ED-204A, Information Security Guidance for Continuing Airworthiness (revised 2022) , EUROCAE www.eurocae.net/
  5. EASA Certification Specifications CS-25, Amendment 25/29 (CS 25.1319, August 2024) , EASA www.easa.europa.eu/en/document-library/certification-specifications
  6. FAA 14 CFR Part 25, Airworthiness Standards for Transport Category Airplanes , Federal Aviation Administration www.ecfr.gov/current/title-14/chapter-I/subchapter-C/part-25
  7. SAE ARP4761A, Guidelines and Methods for Conducting the Safety Assessment Process on Civil Airborne Systems (2023) , SAE International www.sae.org/standards/content/arp4761a/