In this episode of What’s in the SOSS’ “Big Thoughts, Open Sources,” host CRob sits down with Vincent Danen, Vice President of Product Security at Red Hat, for a deep dive into the evolving landscape of open source vulnerability disclosure. Drawing on over two decades of open source security experience, Vincent reflects on the history and critical role of the CVE program while addressing modern challenges like the rise of alternative advisory systems and the flood of AI-assisted vulnerability disclosures. The conversation explores the shifting dynamics between upstream maintainers and downstream consumers, the practical utility – and missing user experience – of SBOMs, and how emerging regulations like the EU Cyber Resilience Act impact global software supply chain security.
Summary
Conversation Highlights
00:00 – Introduction & Open Source Origins
04:26 – The Evolution of CVE and Vulnerability Data
11:02 – Coordinated Vulnerability Disclosure in a Fast-Paced World
17:53 – AI’s Impact on Vulnerability Discovery & Response
27:20 – Realizing the Value of SBOMs and VEX
35:05 – Contextualizing Risk and Exploitability
42:55 – Regulatory Expectations and the Future of Supply Chain Security
Transcript
Intro Music & Promotional Clip (00:00)
Security was one of those things where we did not compete. It is table stakes for everybody. Our users deserve better than just like, “I’m gonna get this fix out faster than you because I’m not going to tell you about it.” None of us thought that and I believe today that still rings true – we don’t we don’t believe that. That’s part of the open source community that works.
CRob (00:25)
Welcome, welcome, welcome to Big Thoughts Open Sources, where we get the opportunity to talk with people from across the open source ecosystem, talking about supply chain security, software security, AI security, and a lot of other topics. Today, we are joined by a friend of the show and a longtime contributor and collaborator with the OpenSSF, Vincent Danen. You’re the Vice President of product security at Red Hat?
Vincent Danen (00:54)
Hey, CRob. Yes, yes, that is I have the dubious honor of being the VP of product security at Red Hat, as you well know, because we’ve known each other.
CRob (01:04)
A long time. Probably longer than some of the audience members are old.
Vincent Danen (01:09)
well, hopefully you didn’t say alive. I don’t think it’s been that long. We’re not that old.
CRob (01:15)
Hahaha
Well, so today we have a whole exciting series of questions. We’re going to have a great dialogue about broadly open source security. But before we get there, let’s kind of get in the way back machine. I want you to kind of describe to the audience. What is your open source origin story? How did you get into this whole little unique slice of heaven?
Vincent Danen (01:44)
Oh man, we’re going back, the way back machine is right. So I’ve been at, I mean, I’ve been a Red Hat for 17 years, was at Mandriva or Linux Mandrake when I joined them eight years prior to that. So I’ve been doing open source for over 25 years.
CRob (02:01)
Wow!
Vincent Danen (02:02)
Yeah, yeah, I think the first, actually it’s really funny, the first, not the first distro that I used, but the one that I used seriously, I was actually to run my BBS.
And that was like Red Hat Linux 5.
Yeah, it was Red Hat Linux 5, but it didn’t work with some of my SCSI drives. So I switched over to Linux Mandrake, which I think they were trying to be a little tempestuous, impetuous. They were like version six. And so I was using that, which is when I started volunteering, actually doing Package Management for Linux Mandrake while I was doing some Linux consulting on the side, I ran my own business. And they… enjoyed the work that I was doing. So they’re like, hey, you want to do that? Plus I was writing technical articles. If you go back like Tech Republic and a couple other outfits, I was writing a whole bunch of articles on Linux and open source, which was a ton of fun and learned a lot. And, and then I started working for Linux Mandrake doing packaging and documentation. And then one day they were like, Hey, one of these guys wants to be working on the kernel full time and not dealing with some of these vulnerabilities like in wu-ftpd and some of these older things are like, there’s only one per month roughly that you’re gonna have to do. you wanna take that on? And I was like, yeah, sure, whatever, I can do that. And that one a month turned into one a week, turned into one a day, turned into how many hundreds a day are we up to now? Like it’s a lot. So I kind of, fell into the whole security space by accident because somebody suckered me into it. And 25 years later, I’m still doing it. So I must’ve found my…found my niche.
CRob (03:41)
Yeah, well it’s something that I’ve had the opportunity to work alongside you. You’re very passionate about, which is important because it’s not a fun job all the time, right? It can be pretty hard.
Vincent Danen (03:52)
no, no, it’s definitely not a fun job. Almost all the time, at least these days, right? I mean, I think any honest security practitioner will tell you that. But I mean, the open source part of it is a blast, right? Like I, I mean, I have drunk all the Kool-Aid. I am a firm believer in open source, not just open source software, but like the open source ethos, the mythology around open source and the philosophy and the principles and
Man, these are things to live by and I love it.
CRob (04:26)
Yeah. So let’s start to dive into our topic today. Broadly, vulnerability disclosure. And let’s start off with kind of the elephant in the room, so to speak. So a lot of our work today in coordinating vulnerabilities goes through the CVE program, which is a program that’s funded by the US federal government. And there’s a couple of different
You have the CVE program, you have the National Vulnerability Database. But broadly, the CVE has been having some problems with funding, some uncertainty with politics. And in the meantime, the vulnerabilities are rapidly increasing. So from your perspective, and kind of with this 25 year history, what has worked well as part of vulnerability disclosure specific to CVE or not and kind of where are we starting to see it come apart at the seams.
Vincent Danen (05:31)
Great question. I think the actual CV part of it is very central to it, right? Because if I go back to those 25 years, when CV first started, it was basically in response to, we have a vulnerability, it’s called six different things, and nobody knows what they’re talking about, right? So I mean, like, I still remember old send mail vulnerabilities, which would have like a bug force ID and X force ID.
Bob’s ID, and then there was a CV name and the CV was that promise of we will have one name for every vulnerability. So when you’re asking about a buffer overflow or send mail, because Lord knows there was enough of them back then, which one are you talking about?
Right, so if I’m sitting here and I’m a defender and I’m supposed to fix it, I would like to know which patch you’re referring to so I can tell you whether or not that patch was applied, whether or not it’s applicable, all of those sorts of things. So CV was great, it lived up to that promise, every vulnerability got a CVE name, everybody knew what it was called and what it was referred to. I think nowadays the biggest challenge that we have is one, CV isn’t comprehensive.
CRob (06:40)
Yeah
Vincent Danen (06:41)
Right, so if you look at, and it drives me nuts, like GitHub security advisors. There’s a bunch of those without CV names. Valid vulnerabilities, right, but they don’t have a CV name. So when you’re looking at it, it’s like you have customers or people are asking you, have you fixed this GHSA?
And it’s an advisory, I don’t know, what’s the CV name, right? So we don’t necessarily treat everything as it doesn’t exist unless it has a CV, because that’s not how vulnerabilities work, but I find it very frustrating, and I think this is where we’re starting to see some cracks in the seams, is like, GHSAs are valid, and they are, but they don’t have a CV name and nobody cares. It’s like, they’re not out there, like, I don’t know, GitHub if you’re listening, you could have a mechanism as a CNA where you basically assign CVs to all these things, right? Or work with those maintainers to be able to say like, hey, you should have a CV or some kind of policy there. But when we’re looking at all of the noise that came out last year, right? With all the funding kerfuffle and all of this other stuff. And then everyone’s like, I know, I’m going to create a GCV or some other type of CVE or a…
Like we were going back to the bug force IDs and the X force IDs. Even this will probably make you laugh because this is a bit of a blast from the past to like the DWF. Right? Like CV worked and they were like, ah, no, we should have DWF too. And then like that didn’t work. And so I worry about all of these competing ecosystems when we had something that worked really, really well. It was basically a dictionary. It just described a thing and identified the thing.
And that’s it. That’s all we need. We don’t need any of the other stuff. Now I think that maybe CV is going a little bit off the rails and lean more into like NVD land where NVD was like, we’re going to enrich all this stuff. We’re going to give you this extra data. We’re going to give it a CVSS score and all this jazz. That was never what CV was meant for. It was never meant to say, this is the severity. This is a CVSS. Whatever it was like, this is the thing. This is the coded effects. Downstream users, upstream users, you figure it out. right? And that model works well.
CRob (08:56)
That’s been, I think, absolutely agree that CVE is that one identifier to rule them all. That way everybody had kind of that same shared understanding. And in Red Hat, that CVE may have these three effects and in Windows it might have these 12 other effects. But it was nice that everybody had, this is what the problem is. This is the root cause.
Vincent Danen (09:19)
Yeah, and when you, this is my beef with NVD, right? Because they started out as a database for the US government to rate things in the context of the government’s use. Everyone and their dog decided like, this is a cool database, we’re gonna use it too, right? And it was a very much one size fits all, right? And you noted different effects, like the thing I love about open source is it’s one, right? It is ubiquitous, it is everywhere and everybody is using it.
But, that means you’ve got different compilers. You’ve got different versions of interpreted languages, so like your Go’s, your Pythons, your Rubys. You have different operating systems with different security contexts, like Windows operates very differently than Linux does. Mac OS is similar, but there’s different compilers, right? And then everybody compiles these things differently. They have different hardening flags and all of these sorts of things. So unless you look at it from the vendor context of like, this is how it’s used. This is the security context around it. This is how it’s compiled. Those scores and those severities are going to be different. Like Mac OS doesn’t have SELinux, but we do. It’s enabled by default. Shame on you if you turn it off. It works really well. But I mean, we’ll rate those things in that context, right? Or with somewhat like the Fortify source or SSP or some of these other compiler flags. I mean, I’m not a Mac guy other than a user. Like I don’t develop on it.
Do those hardening flags exist in that C compiler? Literally no idea. But that’s going to change something from like remote code execution to a denial of service, right? In a lot of cases. So those have to be accounted for.
CRob (11:02)
Yeah, exactly. One thing, so from your perspective, you mentioned that you went from one CVE a week to one a day to one an hour. It’s interesting from your perspective and kind of your interactions with the upstream and downstream communities, how has this rapid acceleration of more information, more vulnerabilities being shared. How do you think that’s affecting people?
Vincent Danen (11:35)
Um…I think people are giving up on the notion of coordinated vulnerability disclosure
CRob (11:41)
Say it isn’t so.
Vincent Danen (11:42)
Which I actually think is terrible. No, I think it’s terrible. Think. The thing I think to realize when it comes to open source is you have up streams, you have down streams, and you have a wide variety of everything else. You’re never gonna be able to coordinate everything across everybody who’s a piece of open source, right? Like that’s just a fact. But there are, I’ll say congregations of different types of open source that are available from different vendors. And that’s where you have your commercial open source vendors, right? So whether it’s Canonical or SUSE or Red Hat or whatever, right?
They are large distributors who provide significant chunks of what that open source is being used out on the internet, particularly when it comes to critical infrastructure. I don’t know this for fact, but I do believe that like a nuclear reactor isn’t going to be updating from the Linux kernel directly, nor are they going to be building all of their source code, because why won’t they?
CRob (12:38)
Hope not.
Vincent Danen (12:40)
Their job is to make sure that nuclear energy is run safely and securely and…all of those sorts of things, their job is not to build an operating system or to maintain it, right? So they’re going to be going to a commercial enterprise open source vendor, and they’re gonna be going for that. So the notion that we’ve had for probably the last 20 years is, I don’t wanna call them cabals, because that sounds bad…
But like groups of people who dealt with embargoed vulnerabilities representing major open source vendors, that basically account for what I would say is 80, 90 % of the critical infrastructure that’s being used. Red Hat is one of them, but it is by no means unique. We would share information because we had these tenants, like I remember when I was back at Mandriva and I was working with Red Hat and I was working with SUSE and I was working with Debian, security was one of those things where we did not compete. We agreed very much that it is table stakes for everybody. Our users deserve better than just like, I’m gonna get this fixed out faster than you because I’m not going to tell you about it. And this is my competitive advantage. None of us thought that. And I believe today that still rings true. Don’t believe that. That’s part of the open source community that works. Right now, what I’m seeing is people are not disclosing to those channels and they’re just making things available online, right?
I don’t know when this is going to go live, so I don’t know in reference to time, but like last week is copy fail, that came out and that was just public and a lot of enterprise open source vendors were caught flat-footed because it was just disclosed, there was no coordination, right? Now I’m not saying that the Linux kernel is the only place that this is happening, it obviously isn’t, this one just happened to be pretty remarkable in terms of its publicity, right?
And I just think this is going to get worse unless we figure out how to make this better. And we do have those mechanisms, but it’s, I don’t know if it’s an education thing. I don’t know if it’s part of like some of the stewardship in, you know, CRA land, you know, where foundations are involved. But of course not all open source communities have foundations.
So it’s really complicated, but there’s a few places where people have traditionally gone, or they’ll go to a vendor, an open source enterprise vendor and report, like this happens to Red Hat all the time, people report vulnerabilities to us, and we will work with the community and kind of do that middleman coordination to make sure that everybody has a fair chance of understanding the vulnerability, contributing to its fix, and then having a standard date for when these things go public, right?
CRob (15:36)
Yeah.
Vincent Danen (15:37)
And I think we have to work harder at that because if we don’t, we get more copy fail like things where it’s like a zero day that shouldn’t have been.
CRob (15:48)
I have a personal hypothesis about this in that much like development today, we have a lot of non-traditional people kind of dabbling in the vulnerability disclosure space and they don’t have that experience or that understanding of how things work in the ecosystem. And that’s one of the things like I can say that we are working to try to help educate and provide these consistent means because it’s important. The whole idea about coordinated vulnerability disclosure is that everybody involved has the ability to have some type of solution so that when it goes public, the end users have the ability to get treatment and make themselves whole.
Vincent Danen (16:29)
Yep. Oh no, 100 percent. And I think it’s just going to get worse with the, I mean, you’ve seen what it looks like the last week or two. If you look at like a CV details and the number of CVEs coming in week over week now, like I think someone was telling me at least when it came to like Red Hat, just with some of the vulnerabilities that were like, we’ve almost eclipsed what we got all of last year already. Right. So I mean, like this is insane. And…
CRob (16:51)
already. Wow.
Vincent Danen (16:52)
Already. Right. So I mean, like this is insane. And
Like the coordination around all of this, like as much as I like to say AI is useful for a bunch of stuff, like it’s really great for finding things, right? AI doesn’t coordinate disclosure. People have to do that, right? So there’s still a, mean, people are wondering about human loop and value of security researchers, like that’s it, right? Part of it is the relational piece, the coordination, things like that. Like AI is good at finding it. Hopefully it’s good at fixing it, but we have to be able to coordinate and then everybody else has to be able to apply these things and everyone’s personal acceptance of AI is different as well. So do humans want to validate things?
I’m sure that some upstreams will want to do that. So you have to account for that as well. But it’s just the sheer volume is going to be the hard part. And I think people will get frustrated because, I’ve submitted my 3,800 CVs or CV, potential CV reports. No one’s getting back to me. So I’m just going to go dump these on Twitter or X now.
CRob (17:53)
And since you invoked the name of our shared friend, let’s pivot a little bit and talk about how AI is changing the economics of vulnerability discovery and not necessarily focusing on the economics of vulnerability response. So from a PSIRT perspective, which is a product security and incident response team, which is the organization that you represent within Red Hat.
How do you today kind of distinguish between something that AI helped with the research and versus the volume of just AI slop where you’re just getting a huge volume of reports and how can we help maintainers with this kind of situation?
Vincent Danen (18:40)
Yeah, I think that the usage of AI slop is diminishing, right? Like last year, 100%, lots of garbage was floating around. From what I’ve seen, a lot of the reports and things that even we’ve experimented with, it’s actually really good now. So there’s less slop, more true positives, those sorts of things, right? I think it’s going to get to a spot where there’s…
There’s a difference between the quality and the quantity. I think the quality has definitely gotten better. I would say as a recipient of a report, I would be asking for a proof of concept as well. Don’t just generate a bunch of things and then just shoot it over the wall. Years ago, people used to do that with fuzzing, They’d fuzz image magic or something like that, and then give us a tarball of all these fuzzed files and be like, hey, we think there’s some problems here.
Like, thanks, could you please point them out to me? Like, don’t just give me a million fuzzer files of random input and then like some of them crash and some of them don’t. Like you gotta weed through some of this stuff yourself first, right? So the notion of like test it first, like actually be able to reproduce it, make sure it’s valid is really good. Particularly since I think a lot of people are using AI tools. And this is my hypothesis. A lot of people are using AI tools right now to submit bugs to bug bounty programs and get their payouts. Right? In fact, we’ve seen some bug bounty programs close because they’re like, well, I mean, you guys are just going to be using AI for this stuff, not vetting it at all. We’re just going to stop paying these things. And I actually think we’re, I think the days of bug bounty programs are done.
CRob (20:28)
I think it’s definitely limited. would agree with that.
Vincent Danen (20:31)
You know, because all we’re doing then is we’re giving people money and they’re investing in these tokens to do all this work, knowing that they’re gonna get this payoff, right? And the incentive isn’t there. Now I’ve always been a, prior to AI, I’ve been opposed to bug bounty programs, just because if you’re gonna be doing this for open source, this is called giving back to the community, right? Like you shouldn’t get paid for this. You should like, you find, I find a bug in a piece of software, I feel like it’s my duty as the end user of that software, the recipient of that value that it gives me to give that to the maintainer, whether it’s a security bug or regular bug, right?
CRob (21:10)
Mmmhmm. Well, and that’s an interesting…we’ve heard a lot of feedback from the upstream community around the volume of these things. And thinking about it, unlike older tools like static analyzers, which sometimes required very expensive licenses for, and only, that was kind of the dominion of commercial enterprises, with these new large language models.
Some of them you could do open models, local things for free or low cost, but then even the well-known name brand frontier models, you can get in at $20 a month. So the economics for the research, the finding piece is greatly reduced. So, outside of a proof of vulnerability or concept, what else would you recommend for people that are trying to use these tools and are hoping to…build a relationship or at least have a good interaction with upstream.
Vincent Danen (22:07)
Yeah, it’s honestly vetting it, right? Like don’t just find it. Excuse me, find it and vet it. Like you gotta put a little bit of elbow grease in there because if you don’t, at the end of the day, you’re just telling my guys like, you gotta do it. Or you’re telling upstream, you gotta do it, right? And if you’ve got 100 different people submitting basically the same vulnerability, because I mean, we’re seeing that now, right?
CRob (22:29)
Mm-hmm.
Vincent Danen (22:31)
Interestingly, for a very long time, I’ve seen, you know, people will report a vulnerability and a month later, somebody else completely random, completely different reporting the same vulnerability. So this is not a new phenomenon exclusive to AI. Like it happened. It’s just the scale and speed of it is everything that’s speeding up. Right? So if we’re going to be dumping all of this stuff on maintainers or vendors or any other recipient of this, you got to do your due diligence. Like they’re going to have to do some level of human effort to triage these things.
I think it’s our responsibility and job to figure out how do we use these tools to help with that triage to make it faster, right? I was actually having a conversation with someone this morning, the same kind of idea, right? Where they’re like, well, I think that humans need to validate all of these things. And I’m like, I agree to an extent, but if we’re being flooded with this stuff, we literally can’t because then we’re all sitting on backlogs of stuff that we’ll call embargoed, but isn’t actually embargoed because somebody else is finding it and reporting it somewhere else.
And then we get into that whole, just even the coordination of CVE names, nevermind the coordination of responsible disclosure. So we have to get better at, like, how do we do rapid vulnerability assessments or judging the validity of a report with another agent or a series of agents? There was a talk, I actually think it was at the SOSS Fusion event maybe two years ago.
And someone was talking about this idea of AI decisions made by consensus, right? Where you have like three or four different agents that are designed differently, trained differently, looking at the same problem. And if all four of them or three of them or whatever your panel is agree that it is a thing, then you go do that thing.
CRob (24:22)
That’s interesting.
Vincent Danen (24:23)
If you have one of them disagree and it has valid, then it triggers a human review, right? And I think that if we…build systems like that, then we’re able to get through that backlog, do the triage quickly and reserve the things that maybe the models aren’t confident on. Then we get a human being to look at.
CRob (24:42)
Mmmhmm. And that’s been one. The great thing about open source is all the source code is freely publicly available that you can look at it, make changes and submit it back upstream. Bad thing about open source is that all the source code is publicly available and anybody can look at it and make changes,
Vincent Danen (25:00)
Yep.
CRob (25:01)
Which again, you mentioned that the kind of the duplicative reports has always been a problem. And even thinking about like the dawn of fuzzers, how all these tools create a large volume of information. You get a lot of data, but kind of identifying the wheat from the chaff is hard because you might have a critical vulnerability hidden inside of thousands of either knot bugs or very low things that would yield very little outcome for an attacker.
Vincent Danen (25:34)
Yeah, but these are the same problems we’ve always had, right? It’s just a tool that’s different, right? If I look at like a SAS T-scanners, right? I mean, my goodness, there’s so much noise in those things. It is a needle in a haystack trying to find a true positive, a true vulnerability in these things. You’ll find a lot of weaknesses, great defects, like, yes, we should improve the code and whatnot. But most of them are like, just, they don’t mean anything, right?
And so a lot of people get frustrated and I find a lot of these scanning tools run for compliance reasons, not for actual security reasons. Right. And this is actually one of the things that makes me really happy about some of these advances in these AI tools is like we can actually zero in on that signal and get rid of a lot of the noise, especially now, right? We’ll call AI slop noise. And there was some signal buried in there, but there was a lot of slop around it right now that that stuff is basically being fixed, it’s drained off, it’s better now. And I expect three
Three months from now, it’s going to be better. Six months from now, it be even better. A year from now, it’ll probably blow our minds because these things just keep iterating, and they just keep getting better. So we’re going to end up having better tools. I don’t think SAS tools have gotten better over the last decade. They’re basically the same thing. And now we have people talking about using AI to filter through SAS findings. Well, what does that tell you? Now we’re going to use AI to figure out how much of this is signal in here.
Now we’re going to use AI to figure out how much of this is signal.
CRob (27:01)
A tool to fix my tool.
Vincent Danen (27:03)
Totally, totally. But now we don’t even need that other tool because the tool that would have fixed that tool is actually doing a better job. Right. And so I actually think this is great. We just have to ride the wave and wait for it to come down, right? And normalize a little bit.
CRob (27:20)
Right. Well, and one thing that kind of offered a glimmer of hope to kind of improve the signal to noise ratio was one of our favorite topics, software bill of materials.
Vincent Danen (27:35)
Mm.
CRob (27:36)
And it was awesome. Like when it was initially presented, governments jumped on it and put requirements out. seeing with like the EU CRA, SBOMs are part of that requirement. But from upstream,There’s limited utility for an upstream maintainer to, they’re rarely if ever gonna use an SBOM. But as you work your way down the supply chain it becomes increasingly more important. From your perspective as one of those, you’re a downstream from upstream. What metadata from your perspective is required for people like you to be able to make these risk-based decisions based off of the…packages that you’re sharing and supporting for your customers.
Vincent Danen (28:23)
Yeah, I mean, it’s for me, it’s the basic stuff, right? It’s the name of the package, it’s the version, it’s a release. A git commit, right? So that as I’m traversing git history, I know like this version equates to this git commit and I can see, because then I can actually start trolling through the git commits for fixes and stuff to know which versions are affected by things and whatnot. And I think there’s some, I can’t remember who was talking about this at Vulcan a couple of weeks ago, but there’s a really neat, maybe it was the folks from Google, but like some very neat get graphing things where they can actually start to determine, because it git is messy with all of the branches and commits and forks and everything else. It’s like, what’s that window of risk? When was it introduced? When was it remedied? How many branches are in there so we can see if we’re on this branch, was it affected or not, right? That’s the sort of information that was useful for me as a downstream reproducer, right?
There’s a lot of stuff that is useful from like a legal compliance perspective, like licensing and whatever else. But I mean, I think fundamentally, folks who assemble a collection of open source don’t necessarily need an SBOM from upstream, right? Because they’ll be assembling all of these things. if I look at it from my perspective, I produce an SBOM for RHEL, like for the operating system. I don’t produce an SBOM for OpenSSH or an SBOM for OpenSSL, right? That’s a component in my SBOM, right? Because nobody’s looking for you know, where is ssl.c in my compiled code, right? They’re just looking for like, where’s my open ssl library? Where do I have it all over my estate, right? The difference will be for some of these, and different ecosystems are different, but like the ones that come to mind are like npm, where you take all of these different dependencies for a project.
and you smush them all into one file to minimize it. And I don’t really, can’t tell what’s in there or what’s not. SBOMB for that would be really helpful because I might need to fix a vulnerability in one of those dependencies that I’m as a downstream, I’m just pulling the one package that’s inclusive of a bunch of other things. Go is another example, right? All of these things shoved into one binary and like there are tools to be able to determine what it was and whatnot, but I have to go look at the binary itself.
That means I can’t do an analysis if I have like an SBOM aggregator tool where I’m like, where is this Go module used in my estate? I can’t go and interrogate all these Go binaries all over the place. Like I just, want like a text file that tells me these things, right? So I mean, like for some upstreams, SBOMs would be super, super handy. For some of them probably doesn’t matter so much. Really critical for the producers.
And also really important that, you know, end users actually start using them. Like there was a promise for SBOMs that has never been realized. And it’s been like a decade plus, right? Certainly the impetus on it for the last five, six years, right? And I don’t see that it’s actually been well used other than saying, I have my SBOM, my compliance box is ticked, but we’re not actually using it for anything.
CRob (32:06)
And that’s been, I would say we’ve been involved with this SBOM space for almost a decade now. There’s been a lot of focus on producing it. Make the SBOM and you’ve got a lot of different permutations and you can go down and do transitive and transitive dependencies. But there’s been very little focus on using these things, aggregating it and then kind of extracting wisdom as a operator. Like how do I find out exactly where I need to go jiggle the handle or deploy a fix somewhere.
Vincent Danen (32:37)
Yeah, when you said jiggle the handle, I was thinking of a toilet. Right?
CRob (32:40)
Right, exactly. We’ve got to flush out vulnerability.
Vincent Danen (32:43)
But it means it’s true. Like to date, topics around SBOMs have been largely engineering focused or academic. Nobody’s putting on their UX hat and going, how would a user use this? What are the tools for this? Like if I can give a personal story that will throw a Red Hat a little bit under the bus. Yeah, I mean, it’s okay. Like they’ll work for me, so it’s fine. Like when we were producing VEX documents,
CRob (33:11)
Mm-hmm.
Vincent Danen (33:11)
right? Like we created them to the CSAF VEX standard. We published them. We did all of these things. I’m like, this is awesome, you guys. I love this. What are we using that a customer could use to actually interpret these files? And the answer I got back was like, I don’t know. I mean, you could go to CSAF and see if they have any tools. I’m like, are you kidding me?
This is the answer, like you guys engineered a solution that, I mean, I was not a believer in it at first, but they proved me wrong, right? It happens, and I’m glad for it. But then they weren’t giving me the tool to use it. So then I went off and I was like, well, forget this, and I wrote my own, right? So now there’s a VEX reader Python module that I wrote
CRob (33:54)
Oh nice
Vincent Danen (33:54)
That would actually do that because I’m like, how do I tell a customer to use this? And we’re like, here’s a document. And they’re like, okay.
CRob (34:04)
and
Vincent Danen (34:05)
And it has all the information that you want, period, run away. That felt a lot like the way we thought about SBOMs. We’ll create the SBOM, like, yeah, you can go use the SPDX tooling for that. Okay, I mean, that’s great. So I can take some JSON and spit it into text. I can grep around it, I guess. What else can I do with it? And we just, never told them.
Right, which made it of limited use.
CRob (34:34)
Mmhm. Yet it got baked into a lot of international regulations and requirements selling to governments.
Vincent Danen (34:43)
Right, because it sounds good and it is the right thing to do, but there’s so much more that can be done with it other than just having it. Right, like the mental picture I always have is like, here Mr. Mrs. Customer, here’s your SBOMB. They’re like, thank you. They throw it in the filing cabinet and they walk away. Right, like we might as well just print it out on paper for all the good it’s gonna do most. Now, I mean.
I don’t want to brush every single customer with the same, or like some of them are probably using it, but like as an industry, I don’t see SBOM usage being anywhere near what it should be.
CRob (35:29)
No. I agree.
Vincent Danen (35:21)
Like we should, we should be able to tell as like users of enterprise software or open source software, like I know precisely where in my, especially with containers…
CRob (35:33)
Mm-hmm.
Vincent Danen (35:33)
Because that has exploded the size. And we used to talk about what our real estate looked like, right? And now It’s like tent cities, not skyscrapers, right? Like there’s things everywhere. And it’s like, where are all the things? Like I see this with vulnerability scans for like Kubernetes clusters. And they’re like, my God, there’s like thousands of vulnerabilities here. It’s like, well, actually there’s dozens. They just show up a hundred times because you have a hundred containers, but you don’t normalize your list, right? And like, those are the things that we…
You need to know where these things are and it becomes that much more important in this containerized world.
CRob (36:16)
Mmhmm. So an interesting adjacent topic. Let’s talk about exploitability. And I’m in a container, I’m on bare metal, I’m on a phone. Exploitability can mean different things to different people. Could you maybe think about from your perspective when you’re given instructions by global regulators or
questions from customers. When you’re thinking about exploitability, what does that mean to like you and your crew?
Vincent Danen (36:48)
Yeah, this is a topic of hot debate, right? Because in theory, in theory, academically, every vulnerability is technically exploitable, right? Because if it wasn’t technically exploitable, it wouldn’t be a vulnerability, it would be a weakness, or it would be a bug. Our philosophy, and we are by no means alone, is that they are not all created equal.
Right, so like this CVE, that CVE, and this CVE are not all the same. Some will be remote code execution without authentication. Some will be local privilege escalation. I need to have shell access first. Right, so we have to start there when it comes to exploitability. In some of these things, it doesn’t matter if it’s exploitable. Right, if there’s sufficient security context and constraints around it.
Like I always say, nobody runs their there’s banking systems naked on the internet, absent any web application firewalls or traditional firewalls or anything, because they wouldn’t be in business long, right? So we have to assume there’s a certain moat of some size. And I know that some people, I saw this on LinkedIn the other day, some people were like, well, the walls don’t work. We have to adopt zero trust architectures and assume that attackers are in there. I mean, that’s true to an extent, right? Because you have insider threats, you’ve got…secretaries clicking links that they shouldn’t be and fishing is still the number one source of breaches. So I mean, that tells you that that’s not a software vulnerability. That’s a human thing, human trickery and susceptibility and then misconfigurations. Those are probably the two biggest things for exploitation. Software exploitation is, I mean, it’s getting worse. If you look at like Verizon’s DBIR, the numbers are turning higher in terms of software exploitation, but it’s still not necessarily easy. And when you look at things like a local privilege escalation inside a container, right?
When you’re in a container, you’re not expected to have shell access, right? So if an attacker can get shell access into your container, isn’t that the problem you should be solving? More so than the privilege escalation within the container and provided it is not a route privileged container, still not gonna get you a ton of privileges, right? So like these are some of those security contexts that are around things or privileged container.
So when we’re looking at it from exploitability, there are so many different factors, right? Like bare metal versus container versus a virtual machine, right? Like how far down the stack can I go? Can I do a container escape or break out of a virtual machine if I’m already on the bare metal server itself? Like all of those different considerations. I think the worst thing in this is gonna be really something to pay attention to in the age of AI, right? Because…
If we do get a thousand vulnerabilities a week when we used to get a hundred, right? We’re looking at a 10 X increase. We can’t treat them all the same because nobody can patch a thousand every week, right? And I’m not talking about the vendors. I’m talking about downstream consumers, right? Cause everybody I talked to, they’re not, they don’t do updates in YOLO mode. They want to test this stuff first, which means people have to fire it up, download it, test it, do all their things.
and propagate it to production, monitor, make sure it works properly. And then they can’t just turn around and be like, there’s the next patch and do it again. Nobody’s business model is to apply patches. Their business model is to run their business. They have to do their security due diligence, of course, but that’s not their job. So we really have to be looking at things in terms of what is the actual impact of exploitation for this thing, and then decide what are we going to do…
Like the old promise of CVSS prioritization, not risk. Right? Exactly. Exactly. So like, it’s a it’s a guide. It’s useful from given 1000 things, which ones do I attack first, maybe CVSS is the right way to do it. Well, you know, within like, those that are critical, which ones have the highest CVSS, I work my way down, then I’m back to the importance or whatever. Or I’m looking at it in terms of my business context, which is another reason why SBOMS are helpful. Like,
CRob (40:56)
Mm-hmm.
Vincent Danen (40:57)
Prioritization, not risk. Right?
CRob (40:59)
Exactly. It’s the string, not the number.
Vincent Danen (41:02)
Exactly. Exactly. So like, it’s a it’s a guide. It’s useful from given 1000 things, which ones do I attack first, maybe CVSS is the right way to do it. Well, you know, within like, those that are critical, which ones have the highest CVSS, I work my way down, then I’m back to the importance or whatever. Or I’m looking at it in terms of my business context, which is another reason why SBOMS are helpful.
Like…What does this vulnerability mean to me? Where is it deployed? Is it only deployed in a testing environment or a QE environment? Maybe I don’t care as much unless it’s in production. Like I was talking with a customer the other day and there are probably going to be times when we have to apply these fixes in production as soon as they’re available.
CRob (41:43)
Yep
Vincent Danen (41:45)
How do we know which ones to do that for? And I’m like, your business context?
CRob (41:)
Mmhm
Vincent Danen (41:45)
You knowing what you’re running? And then I would be going for the ones that we label critical first. Like at the end of the day, that’s it, right?
CRob (41:59)
Yeah. It always amuses me that we still today there are, and it may be a researcher trying to break into the industry, or where people make a giant deal out of a vulnerability that you have to be root to do. A root user could install a malicious package. Yes. Right, they could do that anyway. They don’t care.
Vincent Danen (42:16)
Yep. It’s like, cool. They could do that anyways.
CRob (42:19)
Right. They could do that anyway and they don’t care.
Vincent Danen (42:21)
Oh yeah. No, mean, and it’s, and it’s funny, right? And we’ve, we’ve, you’ve been doing this long enough. I’ve been doing this long enough. There’s like, there was the one ghost script vulnerability that had the cool song and I can’t remember what the name of it was, but it had the, song and like the logo and you know, everyone’s trying to make a name for themselves. And I mean this with the greatest respect for the security researchers. Some of them do fantastic jobs and give you the facts.
CRob (42:47)
Mm-hmm.
Vincent Danen (42:47)
Some of them hype it up because it looks good on a resume if they found a dozen critical vulnerabilities. And then turns out that they’re actually low, right? But they’re gonna hype it up and they’re gonna get everybody’s attention because they don’t, a job interview depends on it or whatever, right? Like, I don’t know.
CRob (43:04)
And exactly as you described, the risk that a downstream user incurs is solely based on their context. They can have firewalls or processes and monitoring. They can have a lot of things that would reduce that down to a critical, yes, we need to fix, but it’s not something I need to shut the whole business down today to go install a bunch of patches.
Vincent Danen (43:28)
Totally, totally. And it’s really important to have that context. Otherwise, due to sheer panic, people will make poor decisions like, I read this thing on the internet and now I’m downloading some random code that purports to fix it. Because my vendor isn’t fixing it fast enough. Because you know your vendor is actually testing these things before they ship it out to you, right?
CRob (43:49)
Testing it exactly.
Vincent Danen (43:51)
So that you don’t have to do as much testing yourself. We’ll make sure that we don’t bork your system when you do the upgrade. But the alternative of like, oh, Billy Bob said, you know, if I run this Ansible playbook or this script, that’ll fix it. And I’m a panicked, unskilled person and I go run it. That’s the stuff of nightmares because you might have just created a bigger problem for yourself, right? So like, how do we used to call this? Like the sensibility, calm, bringing calm to panic and stuff like that seesaw program we had customer security awareness that we used to do.
CRob (44:28)
Mm-hmm. Yep, the seesaw, yeah, Again, giving people the information so they can make decisions on their own based off of their own context and data.
Vincent Danen (44:37)
Yeah, informed decisions.
CRob (44:40)
Mm-hmm. Speaking about interesting new big things, it’s 2026, and this is the year where our friend, the EU Cyber Resilience Act is coming into effect. Where there are some vulnerability reporting requirements that are in place for manufacturers like Red Hat and others. So, um thinking about that, how can PSIRTS or upstream, downstream, how can we all coordinate so that when there is something that falls into that threshold that you need to report and react to, that exploited vulnerability, how can we work together to try to help? Everybody in the supply chain to react to these things so that we all can achieve the regulatory goals that the EU set out, for example.
Vincent Danen (45:31)
Yeah, I mean, I don’t know. I mean, that’s it. That’s my honest answer, right? Because prior to all of the growth and vulnerabilities discovered by AI that we’re not slopping, we’re actually good, right? Like, it’s just like, we’ve to find the right avenue, you know, whether it’s like SIRTS, Vince platform, or there are some existing mechanisms to do this. So we should probably still try to use them as much as we can. But with the volume part included in that, like, I mean,
Can Vince, not me, the other Vince, search Vince, can it handle a thousand a week? 10,000 a week. Or 10,000 not every week, but one week, right? Like can it handle that level of coordination? I literally don’t know. So like there’s going to be challenges there that I think we’re, like we’re going to stumble and trip and figure some of these things out as we go because we never design most of these systems for scale.
CRob (46:30)
Yeah, correct. Well, and then again, the whole exploited aspect of it, we’ve all in IR, we’ve always thought about, you know, if something is being if we have evidence, something’s being actively exploited, you know, we throw all the switches, we all hands on deck, it’s an emergency. But, those were rare situations. had a couple a year maybe where something was being actively exploited. But now, theoretically, just the language, anything could be exploited, as you mentioned. And now we all, some of us are on the hook for more consequences than others of us. But how are we gonna work together to kind of, again, all participants in the ecosystem?
Vincent Danen (47:17)
So I’m gonna throw something out that’s maybe a little controversial.
CRob (47:20)
Woo!
Vincent Danen (47:21)
I think rather than putting the burden on vendors to go report to a government body that their software is being exploited, right? Because, I mean, we might know, but it literally depends on a customer telling us, right? And maybe they have other things that they’re focused on if they’re being exploited, right? If they’re suffering a breach because of some exploited software.
Services out there like CISIS, Kev is one. Vulncheck has a Kev that’s a little bit more timely, a little more comprehensive than CISIS, right? There are sources out there, right? Gray Noise, Accorded Future. There’s a bunch of other places that governments could be going to for that information like, hey, give us the signals of things being exploited, right? I don’t know that every vendor can do what…Those guys do, because that’s their business.
So for me, it feels like maybe you’re asking the wrong person to do this. And I understand there’s the accountability aspect that they want and is appropriate for vendors. But to tell you, the moment something is being exploited, I may literally not know. VulnCheck may know before me. And in fact, I might be finding out from VulnCheck, because it might not be my customer who’s using this piece of open source software. It might be some other customer of some other vendor that’s using it, but I still ship that piece of software and may be also vulnerable in that way. So I depend on these services to tell me whether or not I should be paying attention to something or fixing it faster. To me, that feels like those are the people that should be feeding those government agencies awareness from that perspective.
Now it’s a little different when it comes to a security incident, right? Because that’s very much like something happened to Red Hat or something happened to SUSE or something happened to Fedora or some upstream community, right? But if it happens to me, then I know about it and I can tell you. Exploidable open source that a whole bunch of people ship, I may not know and might not be the first person to tell you. And then are they going to sit there and take on that coordination effort to say like, hey guys, XYZ open source vendor is reporting exploitation of this piece of software, are they gonna go back to every other manufacturer and tell them? Like I don’t think they’re gonna take on that level of coordination. So it makes me wonder, why do we have to do that in the first place? There are better ways to do this, right? That’s my hot take.
CRob (49:55)
I like it. Well, and again, Vincent, this was an excellent conversation on some very timely topics. As we wind down, any final thoughts you want to share with either upstream maintainers, downstream consumers, or your peers?
Vincent Danen (50:12)
Yeah, yeah, one, please let’s not fracture the CV ecosystem, right? I have lived through all the different IDs, meaning the same thing. I never wanna go back to those. Those were the dark days, the dark ages of security disclosures. I don’t wanna go back to that, right? The other thing is I think we have to figure out how to make coordinated responsible disclosures a thing again, because…
It doesn’t matter. Like, again, it’s not a competitive nature between companies or even upstream downstream, right? Like we’re not trying to make upstream look bad. Upstream shouldn’t necessarily be trying to make us look bad. Open source is being used and we’re all happy, right? Like that’s why we do it. It shouldn’t be a competition because there are literally tens of millions of systems that depend on us being the adults in the room and doing this stuff the right way. And so I don’t know what that looks like, but I think we have to figure it out and I actually think we have to figure out.
CRob (51:19)
I agree. Well, I really look forward to collaborating with you and our other ecosystem friends as we kind of think through some of these things.
Vincent Danen (51:27)
Yeah, me too.
CRob (51:29)
And with that, this is a wrap. I want everyone to stay cyber safe and sound out there. Thank you, Vincent, for all the work you have done and all the work we’re gonna get to do together. And I hope everyone out there, happy open sourcing.
Vincent Danen (51:42)
Awesome, thanks, CRob. Thank you.
Summary
The clock is ticking toward the European Union’s Cyber Resilience Act (CRA) deadlines, yet a staggering 66% of organizations remain completely unaware of what is coming. In this episode of What’s in the SOSS? host Sally sits down with Roman Zhukov, co-chair of the OpenSSF Global Cyber Policy Working Group and Security Communities Lead at Red Hat, to demystify this sweeping regulation. Using a brilliant “community garden” analogy, Roman breaks down the distinct roles of maintainers, stewards, and manufacturers under the law, illustrating why the traditional “consume and forget” model of open source is officially dead. They dive deep into the newly released 2026 CRA Awareness and Readiness Report, exposing the staggering $250,000+ engineering tax of maintaining private forks and detailing how active upstream collaboration is no longer just good citizenship—it’s a business and legal necessity. Tune in to discover actionable strategies, free educational resources, and how we can collectively bake “compliance as code” into the open source ecosystem.
This episode is part 2 of a four-part series on the CRA:
1. CRA Readiness: Practical Strategies for Open Source Communities with Megan Knight
3. Private Forks, CRA Deadlines, and the True Cost of Open Source Compliance with Dave Russo
4. Navigating the New Era: The EU Cyber Resilience Act Explained with Madalin Neag
Conversation Highlights
00:23 – Introduction: The CRA Countdown is On
02:04 – Tomatoes, Gardens, and Restaurants: Defining the CRA Personas
06:40 – Reality Check: Shocking Findings from the 2026 Readiness Report
10:12 – The Awareness Gap: Why Are We Ignoring the Warning Signs?
15:01 – The End of “Consume and Forget”
17:49 – The Private Fork Tax: A $250K Engineering Trap
23:34 – Red Hat’s Blueprint & Free Community Security Tools
28:44 – Taming the AI Vulnerability Tsunami
31:27 – Build Your Program Now: Action Steps for Manufacturers
36:12 – Supporting SMEs & Navigating Free Resources
40:30 – Carrying the Torch as an OpenSSF Ambassador
43:35 – Rapid Fire & How to Get Involved
Episode Links
- Roman Zhukov’s LinkedIn page
- Cyber Resilience Act – Implementation
- Global Cyber Policy Working Group
- Linux Foundation 2026 CRA Awareness and Readiness Report
- Case Study: Defending the Open Source Supply Chain in a New Regulatory Era
- OpenSSF’s Global Cyber Policy Working Group European Union Cyber Resilience Act (CRA) Information, Resources & Guides Page
- Open Source Project Security Baseline (OSPS)
- SLSA
- Gemara
- GUAC
- OpenSSF Projects
- Understanding the EU Cyber Resilience Act (CRA) (LFEL1001)
- Global Cyber Policy GitHub Repository
- Get involved with the OpenSSF
- Subscribe to the OpenSSF newsletter
- Follow the OpenSSF on LinkedIn
Transcript
Sally (00:23)
Hello, hello, and welcome to What’s in the SOSS, an OpenSSF podcast, where we get to talk to some amazing people who make up this great open source security ecosystem. And today I have a very special guest. But before we get into that, here’s what I want you to know. The clock is ticking towards a massive cybersecurity deadline.
Research shows that 66% of organizations don’t even know what it is. Love it or hate it. It’s the European Cyber Resilience Act or the CRA. This is important because how do we navigate this shift? Stick around because today we’re going to talk to someone who has a CRA plan.
Roman Zhukov. Roman, thank you so much for being here. Why don’t you introduce yourself to everybody?
Roman Zhukov (01:21)
Certainly, thanks for having me here. Hi everyone, my name is Roman and I work for Red Hat. I do some cybersecurity things on the internet. But approximately two years ago I joined this NICE effort, as we all now call the EU Cyber Resiliency Act. So it is quite a journey, but having fun.
Sally (01:44)
Well, I love that you say it is fun. And yes, it has been quite a journey. And we are going to unpack some of that today and try to help the audience so they can better be prepared. So I guess let us just start with the basics, right? The European Cyber Resilience Act, CRA. How do you define that? And how does it fit in with the various personas who show up to meetings with you or maybe are not aware but need to be aware. I know there are manufacturers, open source stewards, and individual maintainers in this persona group. Can you define those?
Roman Zhukov (02:23)
Yeah, absolutely. and you are right, that is a lot, a lot of roles, a lot of ambiguity. But let us start with the basics. The CRA is the regulation set up to essentially safeguard European customers of digital products by establishing mandatory cybersecurity requirements for companies that operate in the European Union. and suddenly, if not compliant, those hardware and software vendors will be unable to sell their products in the EU market after December 2027. I think it is worth to mention that the first requirement actually kicks in even earlier, a few months from now, September 2026, all of those organizations need to report vulnerability and severe incidents to the authorities. I would use the analogy for the CRA.
And I mean that is so complex, but I will try to break it down to a few things that should be familiar to almost everyone to understand how the series defines the role or roles that you just mentioned. Let us use the analogy of a community garden. Think of the maintainer as the hobbyist gardener. These are developers who cultivate a beautiful, let us say, patch of tomatoes just because they love gardening and they want to share the harvest with the neighbors and the CRA recognizes those actors and the CRA recognizes that forcing them to pay for legal compliance would kill the garden eventually. Therefore, if you are an independent maintainer doing some non-commercial work, you are completely exempt. So you are out of scope.
Contributor or maintainer, if you don’t charge any money for anything for your open source project, just keep planting the code, right? Just keep doing this, you’re out of scope. Now there is an essential role of the open source software steward or simply steward that we call it in the community. You can think of them as a guard garden association, right? There are foundations like OpenSSF or Linux Foundation, they could be big companies, they do not own the veggies themselves, but they provide the land, the fencing, the water supply, you name it, and you know they protect the ecosystem. So under the CRA, a steward is responsible for setting up the baseline policies and basic health checks for the projects they host, acting, you know, as a trusted buffer, I would say, between the community, those planting veggies and the corporate interests.
Now, finally, the most important actor under the CRA that actually has the most obligations and most liability is the manufacturer. We can think in our little example of them as a commercial restaurant, right? This is like basically any company that walks into the free community garden, scoops up the tomatoes, puts them into the premium pasta sauce.
And sell it to paying customers. So the CRA is kind of crystal clear here. If you make money out of software and you know you just sell the software to the European market, you bear the full legal liability for these things. You are the manufacturer and you must run the safety gates to ensure that your product does not give your customers the let’s say the digital equivalent of food poisoning, if it would happen for community garden. So that’s those are the roles under the law.
Sally (06:12)
Love it, Roman. That really makes it make sense for me. I used to love the farm to table restaurants. That’s what I kept thinking of when you were using that metaphor. That’s such a great metaphor. Thank you for explaining it. Yeah, I want to get out into the garden now. Okay, so we have the 2026 CRA Awareness and Readiness Report, which launched on June 8th. Roman, you wrote the introduction for this report, what was the most surprising finding for you?
Roman Zhukov (06:52)
Right. I would start off with writing the introduction to this report was an incredible honor to me. And it was at the same time the sovereign experience because the data what really matters and the data gave us a massive reality check. There are a lot of really mind-blowing findings, I would say. So I encourage everyone to dive into the whole thing. It is hard to pick up.
The one thing, but the biggest finding to me personally was like really the contradictory shocking nature of findings when you combine them all together. Not single number, but when you look at them and you see the full picture, that is fascinating.
while critical enforcement milestones are rushing really towards all of us, as I mentioned, the September 2026, the first vulnerability reporting obligations will be enforceable. At the same time, the global awareness has completely stalled, right? Like over 60% of respondents still entirely unfamiliar with this CRA, which is fascinating.
Compounding this the organizations that are aware on the other hand are attempting to what they think like ease compliance by burying code inside the private forks. Unfortunately I have been hearing this kind of perception or understanding by some companies that you just can simply fork and kind of escape some of the obligations, right?
But the reality check, backed up by numbers in this report is the report explicitly provides that maintaining these isolated codebases can be really a disaster from economical perspective to a company, draining an average of more than $250k dollars per release cycle in pure engineering depth or kind of simply the l the losses if you would.
But I am glad to see this new report came out actually, as it sends an undeniable message, as far as I see it, to executives and to all the companies worldwide, because the traditional checkbox compliance exercise, as well as that we used to call “consume and forget” for open source, right? Those models are coming away actually. And we should stop treating the open source like a free vending machine.
That is going to simply give you some candies for free without any collaboration, anything else, and therefore now for all the companies that are affected by the law, it would be really hard to deny active upstream collaboration, because it is now something baked in the law and not optional.
Sally (09:50)
Thanks for that, Roman. Yeah, there’s a lot to unpack here. The one thing that stood out to me is you said over 60% of respondents are still unfamiliar with the CRA. Why do you think this awareness gap persists even as the deadlines approach?
Roman Zhukov (10:07)
Yeah, first of all, to me as a co-chair of OpenSSF Global Cyber Policy Working Group, which is a home for collaboration between all of those actors that I mentioned, manufacturers, maintainers and other community members, to me that awareness gap means that we as a working group have so many things to do. I feel we kind of do some work on the awareness front, but there is so much more to be done on that front.
But to be serious, I think this persistent awareness gap comes down to a few typical behaviors that we have seen every day in the software world specifically. First of all, that is like somebody calls it the compiler warning syndrome. That means like in software development, I think
A lot of us are famous for ignoring warnings like compiler flags, all of this that is not that red but yellow, something like that. I will fix that later, and along these lines. I think many global companies are treating the CRA compiler warnings to that extent, right? Because the active enforcement and fines and everything will be starting in
2027 and still of companies saying okay, this is not a this year thing, right? We will come to it as it goes. So they are basically waiting for the build. You know, yeah, they are simply waiting for maybe others to start off and pave the way, but also waiting for the actual lag enforcement date, which is wrong of course.
Yeah, that is unacceptable. The another thing that I think is hidden here is the problem to parse the law actually and to convert the CRA to some of the actionable items. And the lack of the clearly lack of the implementation guidance and the standards. Now the EU authorities are working on the standards and some of the other clarifications that would help manufacturers to navigate this the CRA. But so far a lot of them are still in draft mode.
That means all of these companies are simply left in front of the CRA text itself and it could be ambiguous, it is not concrete. I often got these questions like, okay, we read the CRA one hundred times, but we do not understand what we should do exactly because there are a lack of the technical details on it. So this also adds, I think, to this kind of
Awareness gap, I mean we have heard about this CI, but we don’t know what exactly that means and how exactly we would approach this. And the final piece is the geographic kind of illusion. at least previously I have heard a lot of misunderstanding about this, and I think it’s backed by the report itself.
over seventy percent of North American software producers aren’t familiar with the CRA, right? And this is a belief that okay, I you know, I’m in America, I don’t deal maybe with the EU and it doesn’t affect me, but the CRA is so complex it affects the whole supply chain and there is a non zero probability that even if you don’t sell anything directly to the European Union, you are maybe one of the suppliers of those who do, or you simply maybe the contributor to open source or open source steward for instance. Those also have some obligations. So that also adds to the lack of awareness, I think, generally.
Sally (14:02)
Yeah, it does. Thank you for that, Roman. you brought up a critical point that the report mentions the traditional consume and forget model of using open source and that it’s no longer viable under the CRA. How does this regulation change how companies must interact with upstream projects, if you will?
Roman Zhukov (14:23)
Yeah, absolutely. I mentioned it already. I like the analogy between the consumer forget and kind of free vending machine, right? You push a button and something pops out and you just drop it into your commercial application and that is it. You never thought about the maintainers.
And I personally talk to a lot of companies out there and I frequently ask the question, hey, who is consuming open source? Everybody, right? Because open source is everywhere. But when I ask the question who contributes back, significantly less hands, right? But now under the CRA if you sell a product containing the code, you know, you’re kind of legally responsible for your products, that means effectively for all kind of all of the components.
And if something breaks, even if it is third party to you, if it is an open source component, you hold the whole liability to customers, to your consumers. And I think the CRA has a good chance to end this consume and forget paradigm by transforming open source security into nto the obligations, actually, right?
And yes, historically you are right, commercial consumers operated under the assumption that because open source components work fine for years, someone else would always take care. Now there are certain obligations, like for example, if vulnerability is found in the open source, you need to report back to upstream.
If you produce a fix as a manufacturer of the product, then you actually have to upstream this fix back to the maintainers. And this is a huge push and I think a huge paradigm shift from pure consumption to actually collaborating with upstream and with open source projects.
Sally (16:37)
You talked about the cost of private forks. I was wondering if we could dive deeper into that. According to the data, maintaining private forks cost organizations an average of $250,000 per release cycle. Or actually more than that, $258,000. I’m looking at the research. What is the business case for moving that work to upstream contribution instead? Can you talk a little bit deeper on that?
Roman Zhukov (17:03)
Yeah, that is a perfect finding. That actually to me is one of the most compelling findings in this report: the hidden tax of the private forks. As a long-term open source supporter, I am personally convinced that working upstream, as I do and as we do here at Red Hat, for example, is the only path to go, right?
But now the CRA report backs it up with the numbers and provides the actual business reasons for everybody else besides me and the companies that already contribute to upstream instead of forking things. Yeah, the maintaining private forks may cost organizations more than $250,000 US dollars in labor, which is a big amount of money actually. I would justify the business case for why you should actually contribute upstream instead. I can start with the basics, right? And the basics is that maintaining a private fork forces typically engineering teams to pay a continuous rebase tax.
That means that every time that upstream project releases a new version, right, your developers must manually port your customer patches over, resolve conflicts, and et cetera, and et cetera. On the flip side, by actually merging your features or your or whatever you do new for the project directly into the upstream.community eventually inherits the maintenance and etc. And then you subsequently consume back the newer version where everything is integrated and your code is updated automatically and you don’t spend this additional money to maintain all of these forks. The other business reason could be the engineering velocity that we call in the industry.
That means when developers burdened under the technical depth of the private fork, that significantly affects the product roadmaps. Right? You just have limited amount of resources typically, so you want to spend them wisely and by contributing upstream instead, it shifts your engineering resources from defense like fixing broken mergers to more
Building revenue generating features, if you will, for your products to focus on the core innovations and etc. Those are the basics I think that are under the core incentives why you should contribute upstream. But now the icing on the cake is the CRA factor. Because under the CRA maintaining a private fork would
Increase dramatically, I would say legal risk exposure for you as a product manufacturer. Because pretend if you integrate an open source library into a product, it is third party for you in the meaning of the CRA. That means like the biggest obligation that you would need to form against this dependency, this third party is to perform due diligence, which is
Kind of the one obligation. As long as upstreaming fix things, and hopefully you help also upstream to do these fixes. So you are not responsible for vulnerability management, you are not responsible for secure by design and by default, and etc. Now imagine with a fork, right? Your organization would hold hundred percent legal accountability for this library.
That is now part of your product because you forked it, it is now kind of your property, your responsibility. And nobody cares if you actually do not know the architecture, you may not know the design of this component or even you write the product within a different framework, right? Now you should still do secure by design
Risk assessment, vulnerability management, and full conformity assessment because of the CRA. And now the scale factor, imagine now you have 1000 of these open source libraries you are ingesting every day. And you need to assess it, if it would be even feasible to ensure full engineering compliance support for all of them. So that is the massive shift and the massive push towards better upstream collaboration
backed up by the real kind of business case and business considerations from that point.
Sally (22:04)
Thanks, Roman. Well, you and Emily and me worked on an OpenSSF case study based off of Red Hat’s framework for depending the open source supply chain in this new era of regulations, what is the most important lesson other enterprise organizations can learn from Red Hat’s approach?
Roman Zhukov (22:28)
I would encourage everyone to read this case study which is published under OpenSSF now. But if I picked the only one thing that enterprise organization need to take away, it would be something like this: true software supply chain security requires enterprises to transition from passive consumers into active open source contributors, supporters with the focus on practical security.
If it seems like overhead from the you know as it looks like but it is actually not really overhead if you think it is from occasionally watering your community garden coming back to our lovely example in if you think of occasionally taking care of this community garden in your town so that yourself and others can enjoy these lovely tomatoes at the end, that is a different explanation. Yes, companies like Red Hat take up their responsible stewardship approach, for example, because we naturally support and are committed to do so, some of the open source projects that run the entire world, right.
But we understand that voluntary maintainers do not have compliance team, they do not have legal departments, and quite often the case they lack security background, right, to actually deal with complex mandates and policy and things like CRA. So for other companies, I would suggest to actually break one of the myths.
That I constantly hear say, we are not able to contribute to open source because we are not subject matter experts. Or we use the different programming language. It is kind of an excuse, I would say. Instead, think of there is a lot more you can help with actually, starting just from your questions, right? Just asking your questions is good.
Or raising your CRA concerns, or going down to the frameworks, to the white papers. So we have in the communities we have so much work to be done, both from like collaboration perspective and also on the on the practical security front. So you know, that is kind of natural that the companies that of all sides can actually contribute meaningfully to all of this work.
And I would also add that enterprise compliance has historically relied on manual forms to some extent, right? All these GRC questionnaires, legal declarations, spreadsheets. And this approach is not working for the CRA right now. The lessons from our own journey on the CRA is to focus on the tools, on the practical security things.
Because by implementing automated machine readable security tools and specs and frameworks, organizations can shift the burden of evidence away from voluntary communities to themselves, which is kind of the goal of the CRA. By the way, you cannot offload the liability to the community. So you as a company need to figure out this thing by yourself eventually.
Good news here, there are many open source security standards and tools that can help you to do so. Just to name a few under OpenSSF, we have Open Source Project Security Baseline (OSPS), we have SLSA framework, we have Gemara compliance framework, we have GUAC, and a number of other projects that actually can help both maintainers of the projects to do security better, but also can help companies as they as they adopt them.
Sally (26:43)
Love that. I’d love to hear the good news and all of the areas where we can help make this feel easier for the enterprises and for the whole ecosystem. And you know, I don’t think it would be a conversation in 2026 under open source security if we didn’t talk about AI, right?
There is a massive spike in reported vulnerabilities due to AI-driven tools. How can open source projects realistically manage this influx of disclosures?
Roman Zhukov (27:24)
Yeah, you are right to the point. To handle the massive tsunami of AI driven vulnerability reports and disclosures hitting the open source ecosystem now actually even harder than the enterprises, projects have to adjust their vulnerability management practices and of course tooling to adopt what I call the “post Mythos era” we are entering right now.
A few practical recommendations that I would stress out is first, you need to have a robust intake filter to do the basic sanity checks. It is clear that now a lot of AI agents are operating out there, and not all of them produce actually high-quality reports or high-quality pull requests, etc.
And as a maintainer, you need to introduce some of the filters and checking for things like okay, I do require the proof of concept, I do require affected versions, I do require reproduced steps and a couple of other things. If there are ants in the report, they just simply reject them. So as a maintainer I do not have capacity to deal with these reports.
Now of course automation would help. Automation of looking into some metrics even for the reporters themselves, like reputation, maximum number of emojis even in the report and in the pull requests. I have noticed that a lot of AI assisted contributions are flooding with the emojis, right? Maybe that is because some AI tools just like emojis, something like that.
Checking some of these things would actually help to reject anything that is suspicious bluntly for you as the reporter. So those would be my recommendations.
Sally (29:23)
Yeah, I have to tell my AI assistant, no emojis, no more emojis. They flood it. That’s interesting. Okay, so for the fewer than half of the manufacturers that were surveyed are expected to be fully compliant by the December 2027 deadline. What should these uncertain organizations focus on right now?
Roman Zhukov (29:48)
That is a hard question. I would say I think organizations need to stop looking at the CRA as just a 100-page legal monster something, or perceive it as a next GDPR with this cookie pop-up thingy that you need to implement, which CRA is far from actually. And organizations need to start treating it as a standards software engineering refactoring project. I would be that ambitious.
The EU commission itself actually keeps saying that the intention of the CRA is to make sure that companies invest in the real security improvements. And then compliance shall follow naturally. So start exploring the CRA in great detail right now.
Including all of the implementing acts that we have right now. And you will realize that scope is broader than you eventually think. There are a lot of terms, a lot of complexities in the intersection between the software as a service that are technically out of scope, but there are some of the components that we call remote data processing solution that could potentially make some of the cloud solutions be in scope, right?
And the open source is technically out of scope, but there are many cases when open source can be in scope. So understanding your role, whether you are a manufacturer, distributor, importer, maintainer, steward, contributor, is crucial, right? Because obligations differ dramatically.
But I would suggest to remember the one simple thing, liability always flows downstream. That means you cannot really offload the liability of anything to open source, for example. As a manufacturer, you are ultimately responsible for anything. So one of the advice that I can give to all the companies is to just stop harassing maintainers and asking them how they are doing about the CRA, right? It is not their responsibility to make sure they are CRA compliant.
To draw kind of a bottom line here, do not wait. Build your CRA program now. It is because it is definitely a cross-functional effort. I can speak from our experience. Yes, we are a big company, right, but buy-in from across the different functions inside the company is really vital to set a CRA program up for success. Right. And let us be honest, CRA did not invent brand new security practices. Some of the timelines like 24-hour reporting obligations of actively exploited vulnerabilities and severe incidents are hard. But in essence we all should be implementing all of the things like security by design or security by default, and doing proper vulnerability management as well as SBOMs for years now, right? So apply what is available right now to your products, to your practices. And again is good news. There are plenty of mature frameworks and a lot of open source tools actually that can help you, right?
If you do not know what to do the simple thing is just cooperate upstream. Join me, join my company and others, other peers at initiatives like OpenSSF, Global Cyber Policy Working Group, to learn more and to learn how to start. But yeah, there are plenty of things that you should do right now to prepare yourself to be compliant. 2027 is around the corner, really.
Sally (34:06)
I do feel more hopeful now hearing from your perspective and the things that people can do. One last thing that struck me from the report that I wasn’t expecting was that over half of the European small and medium enterprises, those SMEs, remain unfamiliar with the CRA. So how can the open source community best support these smaller type of organizations that lack a large legal team?
Roman Zhukov (34:30)
That is exactly where the community can actually help and help significantly. For example, as part of our OpenSSF Global Cyber Policy Working Group effort, we are creating digestible white papers, checklists, simple guidelines dedicated to different roles under the Cyber Resiliency Act, and they are meant to be easily consumable by those people in those organizations that are not necessarily familiar with the complex legislations or even unfamiliar with the sophisticated security concepts.
I would say one of the biggest and successful assets that we collaborated on and produced under this effort is the free CRA class that is now hitting way over 5,000 of enrollments, and this is really a good starting point specifically for small and medium organizations because it is again short, concise, sticks to the points and is free completely for everybody to take. It teaches you about the basics of the Cyber Resilience Act.
Also in our group we do regular briefings on what is new in the CRA development. Which is again super important to small and medium organizations because they simply do not have time and capability and desire to learn what is happening in the legislation every day. Therefore, we also do the workshops and brainstorming sessions, both offline and online, to handle cases that the members of our community actually bring to us. And this is a real thing. I would encourage all the SMEs that have questions to just come to our group and ask your questions. Bring up your case and we will do our best to provide our community advice for what you should do about this.
In addition, we also collaborate across multiple OpenSSF projects and broader industry initiatives to work on tools that would help companies, specifically smaller companies, because they are meant to handle or automate the large portion of the CRA compliance, at least we believe so. By standardizing and integrating community tools like the open source project security baseline or OSPS and now actively developed due diligence solution for manufacturers directly into the templates, into the development practices.
We actually as a community can bake compliance into the code, right? And finally reach the point when we can tell, okay, this is compliance as code, and we have all the evidence produced automatically. And this transforms to my personal understanding, a huge portion of complex CRA requirements into free, off the shelf, to some point click to deploy guardrails that can allow smaller companies to stay compliant with the CRA and more importantly actually implement the good security practices like secure by default and etc without needing the huge security teams or the army of lawyers or something.
So that is what can really help SMEs to navigate the Cyber Resiliency Act.
Sally (38:16)
That’s really helpful, Roman. Thank you. All right, let’s shift gears here. I want to talk about something that first off, just want to give you a huge congratulations for that you were just recently became part of our OpenSSF ambassador program, named to the first cohort. A quick question, I guess. What are you thinking you’re gonna do with this new role?
Roman Zhukov (30:40)
Thank you. Well, it is so natural to me as I feel I have been an ambassador in OpenSSF for quite a few years now already. I joined an OpenSSF fan club with the introduction of the first they call it beta or alpha version of the scorecards, a tool that analyzes the security health of open source projects in an automated fashion.
Years later I helped to roll out OpenSSF Scorecard across a few companies of different sizes. Right? So that is how my joining naturally started with OpenSSF. So now that is how I get into it. And you know the drill, right? Once you are in, it is really hard to escape from doing these good things.
With the community and for the community essentially. But to be serious, yeah, I am very proud to be named as an official OpenSSF ambassador. It is an incredible honor to me and also a huge responsibility. In this role I hope to provide what we call the open source way. And educate everybody that the open source way is not just a methodology for writing code, but also it is the most effective framework that we have now for solving global security and regulatory challenges, which we do not have a shortage of at the moment. As you mentioned, all of these AI vulnerabilities and regulatory compliance challenges across the world, they add up to the whole picture.
So by bringing a pragmatic engineering centric voice and approach that I personally really try to follow every day by bringing this to the table. I hope we can ensure that the security becomes an active feature of the ecosystem we all depend on so heavily, right? Rather than a blocking thing that is still perceived by some organizations.
So I have done security for twenty plus years now and it is so close to my heart and I just wanted to carry this torch and I want to spread the word about the beauty of security and all of the open source tools and collaborative nature of it so that it can be easily digestible and implemented across the other companies.
Sally (41:32)
Love that. Okay, that wraps wraps up our main deep dive. But before I let you go, Roman, we have a little thing called rapid fire on the OpenSSF What’s in the sauce podcast. So just first thing that comes to your mind, I’m gonna ask you a series of questions. This is fun stuff, not work stuff. All right, are you ready?
Roman Zhukov (41:52)
Mm-hmm. Yes, love it!
Sally (41:54)
Okay. Tea or coffee.
Roman Zhukov (41:56)
Coffee.
Sally (41:57)
Oh, I wasn’t expecting that. Cheers. I love it.
Roman Zhukov (41:59)
Oh really?
Sally (42:00)
Yeah, I was thinking tea. You’re in Ireland, right?
Roman Zhukov (42:07)
But I love coffee as well. I can drink it every day actually. Yes.
Sally (42:111)
I love coffee too. Really? Okay. I love that. Favorite open source mascot.
Roman Zhukov (42:16)
CRA-fish
Sally (42:17)
Yeah, good one. Star Trek or Star Wars?
Roman Zhukov (42:21)
it is hard but Star Wars, I think.
Sally (42:26)
The tracks. All right. So we talked a lot about your metaphor with the food. I loved that and with growing in the garden. If you’re gonna use one of those tomatoes and make salsa, would it be mild or spicy?
Roman Zhukov (42:39)
Spicy, one hundred percent.
Sally (42:41)
Love it. Okay. well, thank you so much, Roman. To wrap it up for listeners who want to leverage OpenSSF resources, like what you mentioned, the cyber global cyber policy working group, or maybe the new awareness sig, the training course. What’s the best place for them to start today?
Roman Zhukov (43:02)
Right. I would I I would end nearly where I started with again going back to my community garden analogy. with a community garden typically you don’t need any approvals or special permissions, you just show up, learn and see where you can actually help as like everyone else with the tomatoes to make sure they they are good then to eat and to enjoy.
Right, that’s essentially what we do in the community. And despite the scary policy compliance angle, we are super friendly at the OpenSSF Global Cyber Policy Working Group. and you have to trust me to here. just join one of our calls to learn what’s going on. It is free, open to everyone. You don’t have to be a member of anything at all. Just just show up, join.
To name a few specific entry points that could can help you depending on what you need or what you’re building. We have the one stop shop hub that we call it policy.openssf.org/CRA. This is the one stop shop that can get a handle on the landscape of the CRA, what’s happening around with the news without the getting dive into the legal text and all of these complexities.
Of course, explore our GitHub repository. Under OpenSSF, we have Global Cyber Policy Working Group. If you want to dive into the governance, check out what we’re working on, like go to this repo. There are a lot of materials published there. As I mentioned, checklists, guidelines and links and all that you need to know how to further participate in the community. Like we have the bi weekly calls of our main working group. We have also calls for our SIGs, which are awareness SIG and also standardization SIG. They all do a great job in their remit. So please consider joining these efforts if you wanted to dive a little bit deeper into either awareness things.
One of the examples I would as an opportunity I would show you is right now at the very moment we’re looking for collaborators for the blog post series that we plan for the CRA. If you would like to be the co-author, please join us and help to spread the word over there. Finally, we also do a lot of meetups across the globe and throughout the year.
But we also have the workshops and online webinars like EU CRA Monthly Tech Talks, when we actually have the guests speakers speak about everything that can be related and can be helpful on the CRA implementation, again from the different companies, from the different entities and different actors on this space. So just keep an eye out on the announcements.
We always have a lot of stuff to share, but also we have a lot of work to be done. Please come join us and collaborate on the overall effort of making this CRA meaningful and actionable for everyone.
Sally (46:42)
Brilliant, Roman. I feel much better about CRA awareness. Thank you. And until next time, stay secure and happy open sourcing. That’s a wrap.