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 document set: who publishes what
Section titled “The document set: who publishes what”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 reference | EUROCAE counterpart | Scope | First publication |
|---|---|---|---|
| DO-326A | ED-202A | Airworthiness Security Process Specification | 2014 |
| DO-356A | ED-203A | Airworthiness Security Methods and Considerations | 2018 |
| DO-355A | ED-204A | Information Security Guidance for Continuing Airworthiness | 2014, revised (ED-204A, 2022) |
| DO-392 | ED-205A | Cybersecurity Process Standard for ATM/ANS Ground Systems | recent |
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.
Regulatory anchors
Section titled “Regulatory anchors”EASA: from CRI F-19 to CS 25.1319
Section titled “EASA: from CRI F-19 to CS 25.1319”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.
Civil rotorcraft and engines
Section titled “Civil rotorcraft and engines”| Aircraft type | Specification | Security provision |
|---|---|---|
| Large aeroplanes (transport category) | CS-25, 14 CFR Part 25 | CS 25.1319 / Part 25 Section 25.1319 |
| Large rotorcraft | CS-29, 14 CFR Part 29 | CS 29.1319 / Part 29 Section 29.1319 equivalent |
| Engines | CS-E, 14 CFR Part 33 | covered via system integration on the airframe side |
| Small aeroplanes | CS-23 | airworthiness 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 SecRA | Architecture-driven assessment, mitigation allocation |
| SSA (System Safety Assessment) | Final SecRA | Compliance demonstration, residual risk |
| Safety architecture (partitioning, redundancy, dissimilarity) | Security architecture (segregation, defence in depth) | Architectural decisions implemented in software / hardware |
| Verification of safety properties | SecVer (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 class | Effect on aircraft / occupants | Security implication |
|---|---|---|
| Catastrophic | Aircraft loss, multiple fatalities | Highest security measures, deepest verification, independence required |
| Hazardous | Large reduction of safety margins, serious injury | High security measures, structured verification |
| Major | Significant reduction of safety margins, occupant discomfort | Moderate security measures |
| Minor | Slight reduction of safety margins, minor inconvenience | Light security measures |
| No Safety Effect (NSE) | No safety consequence | No specific airworthiness security objective |
TARA: Threat Analysis and Risk Assessment
Section titled “TARA: Threat Analysis and Risk Assessment”DO-356A defines the TARA framework that underpins the SecRA. The TARA structures the analysis around four standard attacker-capability tiers.
| Attacker capability tier | Characterisation |
|---|---|
| Basic | Limited resources, off-the-shelf tools, no insider knowledge |
| Enhanced | Skilled attacker, public exploit toolchains, some target knowledge |
| High | Organised group, custom tooling, persistent access, targeted reconnaissance |
| Extended | Nation-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.
Asset classification
Section titled “Asset classification”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.
Required plans and deliverables
Section titled “Required plans and deliverables”DO-326A imposes a defined set of plans, analyses, and summaries, mirroring the documentary structure of DO-178C on the software side.
| Deliverable | Purpose |
|---|---|
| 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 Plan | Describes the methodology to conduct the TARA and the SecRA. |
Analyses and verification
Section titled “Analyses and verification”| Deliverable | Content |
|---|---|
| SecRA (Security Risk Assessment) | TARA, threat scenarios, attacker capability, residual risk, security measures and their allocation |
| Security Architecture Document | Description of security measures embedded in system architecture: segregation, cryptography, authentication, defence in depth |
| SecVer Reports | Records of verification activities, with traceability to security objectives |
| Security Compliance Summary | Consolidation of evidence at the end of the cycle, equivalent of the SAS for software |
Continuing airworthiness (ED-204A)
Section titled “Continuing airworthiness (ED-204A)”| Deliverable | Content |
|---|---|
| In-Service Security Plan | How the security posture is maintained after entry into service |
| Vulnerability Handling Process | Discovery, assessment, response, communication with operators |
| SOC interfaces | Security Operations Centre engagement, monitoring, incident response |
| Configuration management | Software 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.
| Aspect | DO-326A / ED-202A | DO-355A / ED-204A |
|---|---|---|
| Phase | Type certification (before entry into service) | Continuing airworthiness (after entry into service) |
| Audience | Type certificate applicant | Operator, maintainer, software part loadable supplier |
| Output | Security Compliance Summary, certification basis evidence | In-service security plan, vulnerability handling process |
| Authority interaction | EASA / FAA certification team | EASA / FAA continued airworthiness oversight |
| Companion methods | DO-356A / ED-203A | Operator-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.
Programme integration: when to do what
Section titled “Programme integration: when to do what”| Milestone | Security activity | Output |
|---|---|---|
| Concept | Preliminary threat identification, security scope definition | Input to ARP4754A allocation |
| PDR (Preliminary Design Review) | First version of PSecAC, preliminary TARA, preliminary SecRA | PSecAC v1, preliminary SecRA |
| CDR (Critical Design Review) | PSecAC finalised, security architecture frozen, security measures allocated | PSecAC final, Security Architecture Document |
| TRR (Test Readiness Review) | SecVer Plan executed, evidence collected | SecVer Reports |
| Certification | Security Compliance Summary submitted with type certification dossier | Security Compliance Summary |
| Entry into service | Switch to ED-204A continuing airworthiness regime | In-Service Security Plan active |
| Post-EIS update | TARA refresh after any change affecting attack surface | Updated 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.
Frequent pitfalls
Section titled “Frequent pitfalls”| Pitfall | Consequence |
|---|---|
| Treating cybersecurity as a bolt-on after the safety architecture is frozen | Late re-architecture, partitioning decisions invalidated, programme slip |
| Missing PSecAC at CDR | Authority 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 controls | Vocabulary mismatch, gaps in airworthiness coverage |
| No TARA refresh after a software update or supplier change | Stale SecRA, residual risk under-estimated, finding during surveillance |
| No SOC plan or interface for ED-204A continuing airworthiness | In-service vulnerability cannot be triaged or responded to |
| Confusing attacker capability tiers with safety DAL | Security measures over-engineered or under-engineered relative to the actual threat |
| Sequencing security verification after safety verification | Conflicting test environments, duplicated effort, late discovery of architectural conflicts |
| Ignoring CS 25.1319 default applicability post-August 2024 | Filing without security deliverables, certification basis rejected |
| Treating ground-side and airborne-side cybersecurity as a single document set | DO-392 / ED-205A scope missed for ATM/ANS ground systems |
Going further
Section titled “Going further”- DO-178C and DO-254, airborne software and hardware: the safety-side pipelines that DO-326A interfaces with at system level
- Risk management, ISO 14971, IEC 31010, FMEA, FTA: the broader risk-assessment families
- CMMC and UK Cyber Essentials: corporate cybersecurity baselines, distinct from product airworthiness security
- Glossary: definitions of PSecAC, SecRA, TARA, ED-202A, ED-203A, ED-204A, CRI
See also
Section titled “See also”- DO-178C and DO-254: avionics software and hardware
- IEC 62443 (ISA-99), industrial control cybersecurity
- Common Criteria (ISO/IEC 15408): IT security eval
- Cyber Resilience Act (CRA): EU baseline for digital
- MIL-STD-461 and MIL-STD-464, defense EMC standards
- AEC-Q100, Q101, Q200: automotive component qualification
- IATF 16949: automotive quality management
- ISO 26262: automotive functional safety
Sources & references
- RTCA DO-326A, Airworthiness Security Process Specification (2014) , RTCA www.rtca.org/
- EUROCAE ED-202A, Airworthiness Security Process Specification (2014, European counterpart of DO-326A) , EUROCAE www.eurocae.net/
- RTCA DO-356A / EUROCAE ED-203A, Airworthiness Security Methods and Considerations (2018) , RTCA / EUROCAE www.rtca.org/
- EUROCAE ED-204A, Information Security Guidance for Continuing Airworthiness (revised 2022) , EUROCAE www.eurocae.net/
- EASA Certification Specifications CS-25, Amendment 25/29 (CS 25.1319, August 2024) , EASA www.easa.europa.eu/en/document-library/certification-specifications
- 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
- SAE ARP4761A, Guidelines and Methods for Conducting the Safety Assessment Process on Civil Airborne Systems (2023) , SAE International www.sae.org/standards/content/arp4761a/