January 27, 2025

Steven Bentley

Sofema Aviation Services (SAS) www.sassofia.com considers fundamental issues related to the challenge to address cyber security threats within EASA Regulated Design Organisations

Introduction

AMC 20-42 serves as a structured framework for identifying, assessing, and mitigating information security risks in aviation products and systems. By leveraging EUROCAE/RTCA standards, it ensures airworthiness and safety are maintained against evolving cybersecurity threats while aligning with European regulatory requirements.

  • AMC 20-42 provides guidance on performing airworthiness information security risk assessments for aviation products, parts, and systems.
  • It is published under ED Decision 2020/006/R and serves as an acceptable means of compliance (AMC) for meeting the regulatory requirements concerning information security in civil aviation.

Purpose

  • Compliance Framework – AMC 20-42 outlines a non-mandatory yet acceptable method to show compliance with applicable airworthiness certification rules for managing information security risks.
  • Scope of Application:
    This AMC applies to manufacturers, design approval holders (DAHs), and other aviation stakeholders seeking certification for:

    • New products (e.g., aircraft, engines, propellers).
    • Supplemental type certificates (STCs).
    • Changes to existing products or equipment under ETSO (European Technical Standard Orders).
    • Systems susceptible to information security threats that may impact airworthiness.

Key Aspects of AMC 20-42

Product Information Security Risk Assessment (PISRA):

AMC 20-42 introduces the concept of PISRA to address intentional unauthorized electronic interaction (IUEI) that could pose a safety risk. The process includes:

  • Determining the security environment.
  • Identifying assets and attack paths.
  • Assessing safety consequences of security threats.
  • Evaluating risks and proposing mitigation measures if necessary.
  • Iterating the process until residual risks are deemed acceptable.

Reference: PISRA aligns with the process outlined in EUROCAE ED-202A and is further supported by ED-203A for guidance.

Risk Acceptability

The acceptability of risk is based on:

  • Severity: The safety effect of an incident (e.g., major, hazardous, catastrophic).
  • Threat Level: Likelihood and difficulty of exploitation.

For example, a threat with major safety effects may be unacceptable for CS-25 (large aircraft) but acceptable under other contexts like CS-29 (rotorcraft).

Reporting Requirements

  • Operators must report information security occurrences to the designer or certificate holder.
  • Designers must analyze impacts and notify EASA if unsafe conditions arise, ensuring timely corrective actions under 21.A.3A of Annex I (Regulation (EU) No 748/2012).

Instructions for Continued Airworthiness (ICA):

To maintain an acceptable security risk level, manufacturers must:

  • Develop security procedures for operations, monitoring, and auditing.
  • Address in-service occurrences that may result from IUEIs.
  • Assess new threats and communicate mitigation solutions promptly to operators and competent authorities.

Guidance Reference: Continued airworthiness guidance aligns with EUROCAE ED-203A/RTCA DO-356A and ED-204/RTCA DO-355.

Validation and Verification

To ensure the effectiveness of mitigation strategies:

  • Security verification methods include analysis, robustness testing, inspections, and adversary-focused security testing.

Referenced Standards

AMC 20-42 acknowledges EUROCAE and RTCA standards as acceptable means of compliance:

  • ED-202A / DO-326A: Airworthiness Security Process Specification.
  • ED-203A / DO-356: Airworthiness Security Methods and Considerations.
  • ED-204 / DO-355: Information Security Guidance for Continuing Airworthiness.

Next Steps

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