Legal ↔ Cyber interface

This is the page that justifies one site addressing two audiences. It formalises what each team owes the other, with deadlines and formats — because an unformalised exchange becomes, under pressure, an exchange that does not happen.

Cross deliverables

Deliverable Frequency Format Deadline
Validated, signed SBOM Every shipped version CycloneDX, plus SPDX export on request D+1 after release
Cybersecurity risk assessment Per product, at every major change Standard document Before the pre-market review
Annex I traceability matrix Per product and version Table Before the review
Vulnerability handling log and VEX statements Monthly Platform export D+5
Security test reports Per campaign Dated report D+10
Description of the update mechanism Per product Standard document Before the review
“Actively exploited” qualification On event Qualification sheet H+2
Technical justification of the support period Per product Memo Before the review
Deliverable Frequency Format Deadline
Criticality classification per product On entry to the catalogue Signed sheet Before development starts
Assessment route chosen Same Sheet Same
Licence policy and lists Quarterly Versioned policy D+5 after the review
Licence exception decisions On request Register entry 5 working days
Supplier clauses obtained Per contract Extract from the clause set On signature
Decision on SBOM disclosure Per product Decision Before placing on the market
Reporting decision and approved wording On event SRP form H+20, for submission at H+24
Support period committed Per product Register Before placing on the market

The two critical deadlines

Two rows determine compliance with Article 14, and deserve to be displayed:

H+2 — Cyber passes the qualification to Legal. H+20 — Legal returns the decision and approved wording. H+24 — the early warning is sent.

Any other arrangement of these intervals pushes the uncertainty into the final hours, which is the worst possible moment.

Shared vocabulary

Five terms the two teams use differently, whose common definition must be written down:

Term Cyber sense Legal sense Agreed definition
Vulnerability Any weakness a tool detects An exploitable weakness creating risk A weakness in a component; its exploitability is qualified separately by a VEX
Incident Any security alert An event to be notified An event that actually compromises product security; “severe” is a separate qualification
Product A repository, a service, an artefact What is placed on the market under your brand What is placed on the market, within the meaning of Article 3
Version A build identifier A commercial reference Both, explicitly linked in the register
Support Operational maintenance The support period under Article 13 Always say which: “commercial support” or “regulatory support period

The table looks trivial. It prevents incidents where one team says “the product is supported” while the other hears “you have a legal obligation to supply fixes”.

The escalation path

Where disagreement persists on a qualification, a reporting decision or a VEX arbitration:

  1. Head of PSIRT and legal lead, within two hours during an incident.
  2. CISO and general counsel, within four hours.
  3. Executive sponsor, within eight hours.
  4. If unresolved within the intervals compatible with the legal deadline: the default rule applies — report, do not place on the market, do not lift the block.

The default rule is what makes escalation safe: it guarantees that a disagreement never produces a breach through inaction.