CRA Conformity Assessment Policy Mapping
Status: Draft Owner: Policy + Documentation Last updated: 2026-04-30
Purpose
This guide maps Stella Policy gates, scopes, metrics, and attestations to CRA control evidence used by the conformity-dossier-v1 export. It is a mapping contract for evidence assembly, not a legal conclusion and not a harmonised standards claim.
Authoritative bundle contracts:
Planning and route decisions:
- CRA gap closure plan
- EU compliance decisions log
- EU compliance sprint execution directions
- CRA product classification ADR
Operating Boundary
- The CRA requirement identifiers below are Stella-local mapping keys derived from the local CRA gap plan. They are not harmonised standard clauses.
- A mapped gate shows that Stella can produce evidence relevant to a CRA requirement. It does not, by itself, prove conformity of a product.
- Evidence refs MUST be immutable or content-addressed and verifiable offline. Mutable URLs, screenshots, or live service state are not sufficient dossier evidence.
- Module A can use this mapping for self-assessment declared controls. Module B+C still requires notified-body or test-certificate evidence. Module H still requires QMS evidence; Policy can provide only the control-effectiveness slice.
- Customer products remain customer/manufacturer responsibility. Stella supplies evidence and export tooling; the customer owns applicability decisions, declarations, notified-body submissions, and tenant-supplied evidence.
CRA Reference Vocabulary
Use these identifiers in declaredControls[].craRequirements and evidenceLinks[].craRequirements in the conformity dossier:
| Identifier | Local meaning |
|---|---|
I.I.1 | Secure-by-design and secure-by-default baseline. |
I.I.2.a | Confidentiality protection, including cryptographic protection where configured. |
I.I.2.b | Integrity of stored, transmitted, and processed evidence. |
I.I.2.d | Data minimisation and exposure reduction. |
I.I.2.e | Availability, resilience, and operational continuity evidence. |
I.I.2.g | Logging of security-relevant internal activity. |
I.I.2.h | Security update integrity and support-lifecycle evidence. |
I.I.2.j | Vulnerability mitigation techniques and exploitability reduction. |
I.II.1 | Machine-readable SBOM availability. |
I.II.2 | Vulnerability handling without delay. |
I.II.3 | Security testing, review, and effectiveness evidence. |
I.II.4 | Public disclosure of fixed vulnerabilities. |
I.II.5 | Coordinated vulnerability disclosure policy. |
I.II.6 | Vulnerability information sharing and reachable security contact. |
Mapping Contract
Policy-sourced mappings MUST be represented in the conformity dossier as declared controls plus evidence links. The minimum shape is:
{
"controlId": "CRA-POLICY-REACHABLE-CVE",
"title": "Reachability-aware vulnerability release gate",
"ownerRole": "policy-owner",
"craRequirements": ["I.II.2", "I.II.3", "I.I.2.j"],
"evidenceRefs": [
"evidence://policy/verdicts/reachable-cve/latest",
"evidence://scanner/reachability/latest-release"
],
"status": "declared"
}
Evidence links for the same control MUST carry matching controlIds[], craRequirements[], content hash, media type, and an immutable ref.
Gate And Evidence Mapping
| Stella control source | Local contract or guide | CRA refs | Dossier use | Conservative limit |
|---|---|---|---|---|
SBOM presence and SBOM quality gate (SbomPresenceGate) | Policy architecture, signed SBOM archive | I.II.1, I.II.2, I.I.2.b | declaredControls, evidenceLinks, and CRA tech-file sections/07-sbom.json | Requires an actual SBOM ref, accepted format, schema validation, and preferably signed archive evidence for production. |
Signature-required evidence gate (SignatureRequiredGate) | Policy architecture, policy verdict attestations, evidence hooks | I.I.2.b, I.I.2.g, I.II.3 | Evidence integrity control and audit-signature support | Signature-looking metadata is not enough; verifier and trust roots must succeed or the evidence is incomplete. |
CVSS threshold gate (CvssThresholdGate) | Policy architecture, CVSS v4 policy notes | I.II.2, I.II.3 | Vulnerability triage and risk-assessment evidence | CVSS alone is a severity signal. It must be paired with affectedness, reachability, and disposition evidence for release decisions. |
| Reachability requirement and reachable CVE gates | Reachable CVE gate, Policy architecture, hybrid reachability attestations | I.II.2, I.II.3, I.I.2.j | Exploitability and mitigation evidence for Module A controls | Missing or stale reachability evidence must be recorded as unknown or blocked, not converted into an allow decision. |
| KEV blocker gate | KEV blocker gate | I.II.2 | Actively exploited vulnerability handling evidence | KEV membership is a prioritisation signal. It does not replace product-specific affectedness analysis. |
| EPSS threshold gate | EPSS threshold gate | I.II.2 | Vulnerability prioritisation evidence | EPSS is predictive risk input, not conformity proof. Keep the score snapshot and feed timestamp in evidence. |
| CVE delta gate | CVE delta gate, SBOM/VEX diff rules | I.II.2, I.II.3, I.I.1 | Regression prevention and release comparison evidence | Baseline identity is mandatory. First-release bootstrap must be explicit in the policy evidence. |
| Release aggregate CVE gate | Release aggregate CVE gate | I.II.2, I.I.1 | Release-level vulnerability posture evidence | Aggregate counts must not hide reachable critical issues; pair with per-finding gates. |
Evidence freshness gate (EvidenceFreshnessGate) | Policy architecture, runtime guide, feed snapshot thresholds | I.II.2, I.II.3, I.I.2.g | Freshness and replayability evidence | Freshness uses pinned snapshots and explicit timestamps. Do not call live feeds during dossier generation. |
| Minimum confidence gate and Unknowns budget gate | Policy architecture, budget attestation, determinization architecture | I.I.1, I.II.2, I.II.3 | Unknown-risk and confidence control evidence | Unknowns are first-class. If the budget is exceeded, the dossier should cite the blocker or accepted exception. |
| Execution evidence gate | Execution evidence gate, execution evidence contract | I.II.3, I.I.2.g, I.I.2.j | Runtime test/observation evidence | Production promotion evidence should name the source environment and trace-quality thresholds. |
| Beacon verification rate gate | Beacon rate gate, execution evidence gate | I.II.3, I.I.2.e, I.I.2.g | Runtime coverage and canary-observation evidence | Low sample sizes must be represented as insufficient evidence, not a full pass. |
| Policy lifecycle shadow, coverage, reviewer, determinism, and publication gates | Policy lifecycle, policy runs, policy verdict attestations | I.II.3, I.I.2.g, I.I.2.b | Control-effectiveness and approval evidence | Lifecycle evidence proves Policy governance, not product conformity by itself. |
| VEX trust and verdict rationale evidence | VEX trust model, verdict rationale, verdict attestations | I.II.2, I.II.3 | Affectedness and justification evidence | VEX conflicts must preserve source provenance; do not merge away disagreement. |
Non-Policy Evidence Needed In The Same Dossier
Some CRA controls are not Policy gates. The conformity dossier should link these local contracts or legal docs directly instead of forcing them into Policy metadata:
| Evidence area | CRA refs | Local source |
|---|---|---|
| Product CVD policy and security contact | I.II.5, I.II.6 | Product CVD policy contract, product security metadata contract |
| Public product advisory or fixed-vulnerability disclosure feed | I.II.4, I.II.6 | CRA gap closure plan A1 |
| Support lifecycle and security update policy | I.I.2.h | Product lifecycle contract, product support policy, EOL policy |
| CRA technical file sections outside Policy | Varies by section | CRA technical file v1 |
| Offline verification and attestation proof chain | I.I.2.b, I.I.2.g, I.II.3 | Attestor proof chain, offline verification |
Module-Specific Use
Module A
Use this guide to populate overlays/common/declared-controls.json and overlays/common/evidence-links.json. A Module A dossier is only complete when each declared Policy control has:
- one or more immutable evidence refs
- a policy run or verdict attestation ref
- a stable policy bundle or gate configuration identity
- an explicit status of
declared,blocked, oraccepted-exception
Module B+C
Use the same Policy mappings for production-conformity evidence. The EU type-examination overlay still requires certificate or test-report refs under testCertificates[]; Policy evidence cannot satisfy that requirement alone.
Module H
Use Policy mappings as the control-effectiveness slice for QMS evidence. Module H still requires full QMS process evidence and, where used, the ISO/IEC 27001 control-effectiveness mapping. Do not claim Module H completeness from Policy gates alone.
Optional Gate Frontmatter
The CRA gap plan references future gate-doc metadata in this shape:
crm:
cra:
- I.II.2
The current gate docs under Policy gates do not contain comparable machine-readable frontmatter. Their --- markers are markdown section separators near the footer, not metadata blocks. Until a Policy docs metadata schema is introduced, this guide is the authoritative mapping source.
Follow-up scope when a metadata schema is approved:
- Add frontmatter to each focused gate doc using the mapping table above.
- Keep the
crm.cra[]values identical to this guide unless a reviewed mapping update lands first. - Add a markdown lint or doc sanity check that confirms every frontmatter CRA identifier is present in the vocabulary table above.
Export Checklist
- [ ] Dossier route matches the approved product classification and selected module.
- [ ]
declaredControls[].craRequirementsuse only identifiers from this guide. - [ ] Every Policy control has an immutable policy-run, verdict, evidence, or attestation ref.
- [ ] Evidence links include hashes and media types and are resolvable offline.
- [ ] Missing upstream evidence is recorded as a blocker, not omitted.
- [ ] B+C and H overlays include their non-Policy evidence requirements before being marked complete.
- [ ] No mapping cites unpublished harmonised standards as implemented coverage.
