The Charter of Trust welcomes the opportunity to participate in the European Commission’s public consultation on the revision of the Cybersecurity Act. As a coalition united by the goal of strengthening digital trust, we are pleased to share our consolidated response and recommendations.

We support Policy Option 2, which focuses on targeted regulatory measures that address key challenges without creating unnecessary complexity. In this context, we emphasize the need to enhance the role and resources of ENISA, to ensure effective implementation of both current legislation and the European Cybersecurity Certification Framework (ECCF).

Our recommendations aim to improve transparency, collaboration, and efficiency across the EU’s cybersecurity landscape. These include:

- Introducing clear timelines for the development of certification schemes.

- Enhancing stakeholder engagement throughout the process.

- Establishing more structured communication channels between ENISA, the Stakeholder Cybersecurity Certification Group (SCCG), and sectoral ISACs (Information Sharing and Analysis Centers).

We call for a stronger ECCF, one that is transparent, inclusive, and aligned with international standards to foster global interoperability and ease compliance for organizations across borders. Equally critical is the harmonization of certification practices across EU member states and the mutual recognition of certifications to minimize regulatory fragmentation.

The Charter of Trust advocates for technically robust, standards-based certification schemes, with well-defined roles and responsibilities. We also stress the need for clarity on the interplay between voluntary and mandatory certifications, particularly in relation to the upcoming Cyber Resilience Act (CRA).

To streamline compliance and reduce administrative burden, we propose a unified, risk-based incident reporting regime that consolidates requirements under regulations such as NIS2, CRA, GDPR, and DORA. This would not only simplify reporting for organizations but also enhance the EU’s overall cyber resilience. In addition, we recommend incorporating liability protections and grace periods for incident disclosure.

Finally, we urge the Commission to strengthen supply chain security by adopting a risk-based classification approach and establishing baseline cybersecurity requirements for ICT suppliers.

The Charter of Trust remains fully committed to supporting the European Commission in shaping a secure, resilient, and trusted digital future for Europe. We look forward to continued collaboration in building a cybersecurity framework that meets the needs of all stakeholders, today and in the years to come.

In the face of rising global cyber threats, over 50 CISOs have called for greater international alignment of cybersecurity regulations to strengthen defenses and reduce fragmentation. This message was echoed at RSAC 2025, where experts from the OECD, European Commission, academia, and industry emphasized the need for principle-based collaboration. The Charter of Trust, a long-time advocate for regulatory harmonization, continues to support coordinated, effective approaches that prioritize clarity over complexity.

We are delighted to welcome Richard Skalt, Advocacy Manager at TÜV SÜD, as the new Leader of the Advocacy Workstream at the Charter of Trust. Richard steps into the role following María del Pino González-Junco, who recently assumed the position of Chair of the Global External Engagement Working Group.

With a strong background in advocacy and a forward-looking vision, Richard brings renewed energy to our mission of shaping a secure digital future. As he puts it:

“My motivation is to preserve and build upon the strong foundation of advocacy activities we’ve developed over the past years. At the same time, I’m committed to ensuring we’re in a position to shape the policies that will define how our business model and operations evolve in the future – including the cybersecurity of products and systems, the use, deployment, and distribution of robust AI solutions, as well as cloud security and secure datacenters.”

In a world defined by accelerating digital transformation and increasingly complex regulatory challenges, principled leadership and effective collaboration are more vital than ever. Under Richard’s leadership, the Advocacy Workstream will continue to engage policymakers, raise public awareness, and strengthen education around key issues such as cybersecurity, AI governance, and secure digital infrastructures.