--- title: "ETSI EN 319 401 Compliance Playbook for Trust Service Providers (TSPs)" canonical_url: "https://www.sorena.io/artifacts/global/etsi-en-319-401/compliance" source_url: "https://www.sorena.io/artifacts/global/etsi-en-319-401/compliance" author: "Sorena AI" description: "How to operationalize ETSI EN 319 401 compliance for Trust Service Providers: scope definition, governance, risk assessment to control mapping." published_at: "2026-03-04" updated_at: "2026-03-04" keywords: - "ETSI EN 319 401 compliance" - "trust service provider compliance program" - "TSP security policy" - "trust service practice statement" - "information security policy REQ-6.3" - "risk assessment REQ-5" - "monitoring and logging REQ-7.9.1" - "incident response REQ-7.9.2" - "24 hour breach notification REQ-7.9.3" - "vulnerability scan quarterly REQ-7.8-14" - "penetration testing REQ-7.8-17" - "evidence retention REQ-7.10" - "audit log UTC sync REQ-7.10-06" - "Trust Service Provider" - "Audit readiness" - "Monitoring and logging" - "Incident reporting" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # ETSI EN 319 401 Compliance Playbook for Trust Service Providers (TSPs) How to operationalize ETSI EN 319 401 compliance for Trust Service Providers: scope definition, governance, risk assessment to control mapping. *Artifact Guide* *GLOBAL* ## ETSI EN 319 401 Compliance A compliance playbook for Trust Service Providers that produces defensible evidence by default. Focus: turn REQ-5/6/7 into operating controls, verification, and evidence that stays current as your services and infrastructure evolve. ETSI EN 319 401 compliance is an operating system: risk assessment drives security requirements, policies and practices define how you operate, monitoring and incident response prove you can detect and react, and evidence retention plus supply-chain governance show that the control system remains defensible over time. This page is written for TSP security, engineering, and audit teams who need a repeatable compliance program, not a one-time documentation sprint. ## 1) Define scope like an auditor (services, systems, and external support) Start with a scope definition that mirrors how trust services are actually delivered: production systems, management/admin networks, facilities, staff in trusted roles, and the external organizations that support the service. Your scope statement should be stable across audits and flexible across versions: it should reference service lines (e.g., certificates, timestamps, registered delivery) and the systems that implement them. - Inventory: trust services provided, relying parties/subscribers, and critical service dependencies - System boundary: trustworthy systems, admin systems, development/test segregation, and supporting networks/zones - External support: cloud providers, security tooling providers, subcontractors, and their obligations - Reference the current EN 319 401 V3.1.1 publication scope and record which services are qualified, non-qualified, or mixed in the same operating environment ## 2) Make risk assessment (REQ-5) the control engine REQ-5 requires a risk assessment that identifies/analyzes/evaluates trust service risks and drives risk treatment measures that are commensurate to risk. The compliance trick is to make risk outputs directly generate controls, procedures, and evidence requirements. If your risk assessment is not connected to control changes, you will fail on paper only compliance: policies exist but do not drive engineering or operations. - Risk register tied to assets and services: threats, vulnerabilities, impacts, and likelihoods - Risk treatment plan that maps to: policy updates (REQ-6) and operational controls (REQ-7) - Management approval and residual risk acceptance evidence (REQ-5-05) ## 3) Build a policy stack you can operate (REQ-6.1, 6.2, 6.3) ETSI EN 319 401 expects a Trust Service Practice Statement and Terms & Conditions that are approved, published, and communicated appropriately. It also requires an information security policy system that is documented, implemented, maintained, and reviewed. Treat policies as versioned system components: each policy has owners, review cadence, change control, and downstream operational procedures. - Practice statement: how you address applicable trust service policy requirements and external support obligations - Terms & conditions: including event log retention period, limitations, dispute process, and availability undertakings - Information security policy: third-party communications for relevant changes; planned reviews; configuration compliance checks ## 4) Operational controls that dominate audit outcomes (REQ-7.8 to 7.10) Most findings appear in the operational clauses: network security, vulnerability management, monitoring/logging, incident response and reporting, and evidence retention. The operational clauses extend beyond monitoring and logging. A mature EN 319 401 program also has to manage business continuity, cessation planning, and supplier controls where subcontracting, outsourcing, cloud use, or trust service components are involved. - Network security (REQ-7.8): zones, restricted communications, disabling unneeded services, and trusted channels between trustworthy systems - Security testing: vulnerability scanning with evidence of competence/independence; default quarterly cadence; pen tests after significant changes - Monitoring/logging (REQ-7.9.1): continuous monitoring, alarms, log coverage, automated log processing and alerting - Incident response/reporting (REQ-7.9.2-7.9.3): containment/eradication/recovery, comms plans, 48-hour critical vulnerability handling, 24-hour breach notification procedure - Evidence retention (REQ-7.10): integrity, confidentiality, availability for proceedings, and daily UTC sync for audit log time - Supplier and outsourcing controls (REQ-7.14.3): documented agreements, service levels, security obligations, and review of supplier cybersecurity practices ## 5) Operating cadence (what to do weekly, monthly, quarterly) Turn REQs into calendarized operations so compliance stays true between audits. A good program defines scheduled controls and can show evidence for every period. Use your risk assessment to tune cadence, but be careful: ETSI EN 319 401 contains concrete expectations (e.g., quarterly vulnerability scanning as a recommendation) that auditors will expect you to address explicitly. - Weekly: review critical alerts, privileged access changes, and key monitoring dashboards - Monthly: configuration compliance checks and policy-violation change detection reviews - Quarterly: vulnerability scanning evidence, risk assessment review delta, and incident tabletop exercises - Post-change: penetration testing triggers after significant upgrades/modifications and remediation follow-through - After significant service or infrastructure change: re-check pen test triggers, supplier dependencies, and whether conformity evidence needs refresh before the next audit window ## 6) Evidence pack structure (make it easy to share and hard to dispute) Evidence should be attributable (owner + timestamp), versioned (linked to services and system versions), and complete (covers scope). The best evidence is operational evidence generated by your systems. Avoid document sprawl. Build a single evidence index that links each REQ category to its artifacts and latest verification results. - REQ index: REQ -> control narrative -> verification method -> evidence link(s) - Operational evidence: monitoring/log summaries, scan reports, pen test reports, incident records, and post-incident reviews - Retention proof: log immutability controls, backups/off-site storage, and UTC time synchronization evidence - Conformity-assessment context: keep an assessor-friendly evidence index that aligns with EN 319 403-1 expectations for TSP assessments *Recommended next step* *Placement: after the compliance steps* ## Turn ETSI EN 319 401 Compliance into an operational assessment Assessment Autopilot can take ETSI EN 319 401 Compliance from operationalizing the guidance into a tracked program to a reusable workflow inside Sorena. Teams working on ETSI EN 319 401 can keep owners, evidence, and next steps aligned without copying this guide into separate documents. - [Open Assessment Autopilot for ETSI EN 319 401 Compliance](/solutions/assessment.md): Start from ETSI EN 319 401 Compliance and turn the guidance into owned tasks, evidence requests, and review checkpoints. - [Talk through ETSI EN 319 401](/contact.md): Review your current process, evidence gaps, and next steps for ETSI EN 319 401 Compliance. ## Primary sources - [ETSI EN 319 401 V3.1.1 (Official PDF via ETSI Deliver)](https://www.etsi.org/deliver/etsi_en/319400_319499/319401/03.01.01_60/en_319401v030101p.pdf?ref=sorena.io) - Primary source for the requirements and operational expectations referenced in this compliance playbook. - [ETSI EN 319 403-1 (Official PDF via ETSI Deliver)](https://www.etsi.org/deliver/etsi_en/319400_319499/31940301/01.05.01_60/en_31940301v010501p.pdf?ref=sorena.io) - Reference standard for conformity assessment bodies assessing Trust Service Providers. - [ETSI IPR Database](https://ipr.etsi.org/?ref=sorena.io) - IPR due diligence reference for ETSI deliverables. ## Related Topic Guides - [ETSI EN 319 401 Audit & Conformity Assessment (Evidence Pack + Checklist)](/artifacts/global/etsi-en-319-401/audit-and-conformity-assessment.md): Audit readiness guide for ETSI EN 319 401 Trust Service Providers: how conformity assessment works in practice, what auditors sample. - [ETSI EN 319 401 FAQ for Trust Service Providers (TSPs)](/artifacts/global/etsi-en-319-401/faq.md): Frequently asked questions about ETSI EN 319 401 for Trust Service Providers: what a Trust Service Practice Statement is, how risk assessment drives controls. - [ETSI EN 319 401 Requirements (REQ-5/6/7 Map for Trust Service Providers)](/artifacts/global/etsi-en-319-401/requirements.md): Clause-by-clause ETSI EN 319 401 requirements mapping for Trust Service Providers (TSPs): risk assessment (REQ-5). - [ETSI EN 319 401 vs eIDAS (Mapping to Article 19 & 24 TSP Obligations)](/artifacts/global/etsi-en-319-401/etsi-en-319-401-vs-eidas.md): Practical mapping of ETSI EN 319 401 requirements to the EU eIDAS Regulation (EU) No 910/2014. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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