
2 CONTINUOUS
CYBERSECURITY
CERTIFICATION
Continuous cybersecurity certification is a concept
inspired by the “Continuous Auditing” notion men-
tioned by ENISA during the creation of the EUCS
(ENISA, 2020). It refers to cybersecurity require-
ments related to continuous monitoring, with the in-
tended meaning of “automatic monitoring”. This in-
volves 1) gathering data at discrete intervals with suf-
ficient frequency, 2) comparing the gathered data to
a reference, 3) reporting deviations for timely analy-
sis, 4) initiating a process to fix any non-conformity
discovered and 5) notifying the CAB (Conformity As-
sessment Body) of a major non-conformity.
Continuous certification offers significant advan-
tages by providing an ongoing evaluation and audit-
ing process, unlike the current certification process,
which is typically conducted in larger fixed interval,
e.g., one year. In the current process, cybersecurity
requirements are assessed and audited in a discrete
manner. In contrast, continuous certification allows
internal or external auditors to perform certification-
related activities on a more continual basis.
Achieving continuous cybersecurity certification
requires overcoming significant challenges in in-
teroperability, regulatory coherence, and evidence
reuse. Frameworks like EMERALD, which build
upon the findings of projects such as MEDINA (Orue-
Echevarria et al., 2021), offer promising solutions
by introducing automated evidence collection, cer-
tification graphs, and adaptive compliance mecha-
nisms. The EU has acknowledged these challenges
through initiatives like the EU CSA, promoting con-
tinuous certification methodologies. However, de-
spite technological advancements, European compa-
nies often face barriers to entry, whether as consumers
or providers of cloud services. Lack of interoperabil-
ity, market fragmentation, and the absence of com-
prehensive, reusable evidence frameworks are signifi-
cant hurdles that limit trust and thus participation and
growth in the cloud ecosystem.
2.1 Context and Need
Cloud computing services have become indispensable
across industries, with advanced functionalities such
as machine learning (ML) and natural language pro-
cessing (NLP) being integral to modern applications.
According to Eurostat, the adoption of cloud services
in large enterprises increased by 21 percentage points
since 2014, highlighting a paradigm shift in opera-
tional frameworks. Cloud-based systems now encom-
pass intricate layers of infrastructure, business pro-
cesses, and application code, amplifying the need for
robust security measures.
2.2 Challenges and Gaps
The transition to continuous cybersecurity certifica-
tion is fraught with several challenges, ranging from
technological interoperability to regulatory fragmen-
tation. In the following, we list four key issues.
1. Fragmentation in Certification Schemes: The co-
existence of various certification schemes, such
as ISO standards, the Cloud Security Alliance’s
Cloud Controls Matrix (CCM) (Cloud Security
Alliance, 2021), and country-specific frameworks
(e.g., German BSI C5, Spanish ENS, French
SecNum Cloud), complicates compliance efforts.
The EU Cybersecurity Certification Scheme for
Cloud Services (EUCS) by (ENISA, 2020), aims
to address this fragmentation but lacks detailed
implementation guidelines for achieving high-
assurance levels.
2. Interoperability Challenges: Cloud systems rely
on a diverse range of tools and technologies, cre-
ating interoperability issues in continuous moni-
toring and assessment. The Open Security Con-
trols Assessment Language (OSCAL) originally
developed by (Piez, 2019) offers potential solu-
tions but has not gained widespread adoption (es-
pecially in Europe), leading to inconsistencies in
data formats and evaluation methods.
3. Stakeholder Specific Barriers: Both, consumers
and providers of cloud services, face dispropor-
tionately high entry barriers. As consumers,
stakeholders struggle with limited expertise and
resources to secure operations effectively. As
providers, they often lack visibility and face chal-
lenges in integrating with larger systems, exac-
erbating interoperability and compliance difficul-
ties.
4. AI Integration Complexities: The integration of
AI technologies, such as LLM, ML and NLP,
further complicates certification processes. AI
models require specialized evaluation methods
to ensure robustness against adversarial attacks,
bias, and data poisoning. While frameworks like
the AI Cloud Service Compliance Criteria Cata-
logue (AIC4) address these concerns, they remain
nascent and fragmented.
Current and future research must focus on har-
monizing certification, establishing standards for ev-
idence management, fostering stakeholder inclusive-
ness, and addressing AI-specific challenges.
EMERALD: Evidence Management for Continuous Certification as a Service in the Cloud
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