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Assess cybersecurity risk in air traffic management (ATM) by tracing credible cyber scenarios through the systems and dependencies that deliver air traffic services, then evaluating their operational and aviation-safety consequences. The assessment should cover critical communications, navigation and surveillance (CNS), air traffic services (ATS) automation, data, facilities, people, suppliers and connections—not just the enterprise IT network—and lead to documented risk treatment, monitoring, response and recovery.

What belongs in an ATM cybersecurity risk assessment?

Set the boundary around the services being delivered and the infrastructure they rely on. Include systems and supporting arrangements that could affect service continuity, operational data or safety if they were lost, disrupted, modified or accessed without authorization.

  • CNS infrastructure: communications, navigation and surveillance systems used to support air traffic services.
  • ATS and information systems: automation supporting ATS, aeronautical information systems, and the operational data they use or exchange.
  • People and places: relevant personnel, facilities and the processes governing access to them and to operational data.
  • Technical dependencies: connected or virtualized components, IT/OT links, network zones, remote-access paths and external systems, where present.
  • Third parties and shared services: suppliers, service partners and infrastructure on which the provider depends.

ICAO’s ATM Cybersecurity Policy Template points states toward identifying critical CNS infrastructure and protecting automated systems that support ATS and aeronautical information. EASA’s ATM/ANS security-management provisions also address facilities, personnel and authorized access to operational data. The practical boundary is therefore the service and its critical dependencies, not a list of systems owned by one IT department.

How to carry out the assessment

Use a repeatable process that connects architecture and evidence to operational consequences and decisions. Record assumptions, responsible owners and the reasons for each risk rating so another reviewer can follow the analysis.

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  1. Define the scope. Name the services, locations and operating arrangements under assessment. Record what is in scope, what is out of scope, and the interfaces or organizations on which the scoped services rely.
  2. Build an inventory and dependency map. Identify relevant systems, data, facilities, personnel, suppliers and connections. Map data flows, interfaces, network zones and remote access. Include cloud, virtualization and data-sharing links only where they exist in the provider’s architecture.
  3. Develop credible risk scenarios. For each important service or dependency, consider accidental and deliberate events, plausible weaknesses and access paths, and effects that could originate in an external dependency. Consider loss, disruption, modification and unauthorized access to systems or data. Validate each scenario against the actual architecture; a generic threat list is not evidence that an operator is exposed.
  4. Trace consequences. Follow each scenario through the affected systems and dependencies to the air traffic service, continuity, operational data and possible aviation-safety effects. Consider confidentiality, integrity and availability, but state the operational consequence explicitly rather than using a generic IT score as the final result.
  5. Rate and prioritize risks. Apply documented criteria for likelihood, impact and existing controls, then record residual risk. Identify the assumptions behind the rating and who is authorized to accept any residual risk.
  6. Select and verify treatments. Choose measures tied to the scenario and its service or safety impact. Define how the measure will be implemented and what evidence will show that it works as intended.
  7. Maintain the assessment. Assign owners, preserve evidence and decisions, monitor incidents and changes, review controls and residual risks, and incorporate lessons. Reassess when systems, suppliers, interfaces or operating conditions change.

How to make scenarios operationally meaningful

A useful scenario describes more than a threat name or vulnerable component. It links a plausible event to a pathway, an affected service and a consequence. One way to document it is:

If a specified event affects a system or dependency, through a documented interface or access path, then a stated operational capability or data set could be affected, leading to a defined service-continuity or safety consequence.

For example, an assessment might examine how disruption to a critical communications dependency could affect the service that relies on it. The provider would need to confirm the dependency, pathway, available safeguards and actual operational effect; the example alone does not establish that any particular system is vulnerable.

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For each scenario, retain the evidence behind the analysis: relevant architecture and data flows, existing safeguards, operational or safety-impact assumptions, and any uncertainty that could change the rating. This makes it possible to distinguish a plausible risk from a broad sector concern that has not been demonstrated in the provider’s environment.

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How to evaluate and prioritize risk

Use criteria approved for the provider and applicable jurisdiction. The sources cited here do not establish one universal ATM numeric matrix or risk-acceptance threshold. A provider should document how it judges likelihood, impact, control effectiveness and residual risk rather than importing a generic score without explaining what the score means for its services.

CANSO’s Cyber Security and Risk Assessment Guide advises ANSPs to identify their greatest organizational and business risks and consider assessing controls against a recognized framework. It identifies the NIST Cybersecurity Framework as one option for describing current and target states, tracking improvement and communicating progress. That is a possible organizing tool, not evidence that one framework is mandatory or sufficient for every ATM provider.

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When choosing a framework, assessor or implementation approach, compare whether it:

  • covers the provider’s ATM services and CNS, ATS and information-system dependencies;
  • connects cyber scenarios to service and safety impact;
  • addresses relevant OT, legacy systems, suppliers, remote access, virtualization and data sharing;
  • fits applicable rules and the provider’s safety-support assessment;
  • produces repeatable evidence and supports monitoring and recovery planning; and
  • is practical for the provider’s architecture and staffing.

What risk treatments should the assessment consider?

Treatments should follow from the identified scenario and its consequences, rather than being selected as a generic checklist. Depending on the architecture and applicable requirements, the assessment may consider:

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  • security by design and review of technical or operational specifications as systems change;
  • supply-chain controls for relevant suppliers and dependencies;
  • network separation and limits on remote access;
  • controls on authorized access to operational data;
  • monitoring, breach detection and warning arrangements;
  • incident response and service recovery; and
  • reviews, lessons learned and measures to prevent recurrence.

For each treatment, record which scenario it addresses, who owns it, how it will be verified and what residual risk remains. A control that exists on paper but has not been checked against the relevant pathway should not be treated as proof that the risk has been reduced.

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How do ICAO and European rules shape the work?

ICAO: identify critical systems and assess protection

ICAO’s ATM Cybersecurity Policy Template advises states to identify critical infrastructure related to CNS for air traffic services, protect automated systems supporting ATS and aeronautical information, analyze threats and vulnerabilities in relation to effects on air traffic services, and review specifications as technology changes. ICAO says the template does not replace national regulation.

A 2025 ICAO seminar presentation reproduces Annex 17 Standard 4.9.1 and Recommended Practice 4.9.2. In that presentation, the standard concerns identifying critical ICT systems and data used for civil aviation and developing appropriate protection in accordance with risk assessment. The accompanying recommendation names confidentiality, integrity and availability, security by design, supply-chain security, network separation and limiting remote access. The presentation is a secondary rendering; for compliance decisions, consult the authoritative Annex and the applicable national aviation security program. ICAO describes Doc 9985 as a holistic ATM security manual combining physical security and cybersecurity elements; the manual is restricted.

European Union and EASA: confirm the provider’s scope

EASA’s consolidated ATM/ANS rules describe a security management system for air navigation service providers, air traffic flow management providers and the Network Manager. The specified system covers facilities and personnel, authorized access to operational data, risk assessment and mitigation, monitoring and improvement, reviews and lesson dissemination, breach detection and warnings, and response and recovery. The Regulation (EU) 2023/203 wording for ATM/ANS.OR.D.010 cited by EASA applies from 22 February 2026.

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EASA’s Part-IS regulatory page gives applicability dates of 16 October 2025 for organizations within the delegated-act scope and 22 February 2026 for other organizations and competent authorities covered by the implementing act. Those dates do not, by themselves, determine an individual provider’s obligations. Check the current consolidated rules and national authority guidance against the entity’s actual role and scope.

Wider transport and sector context

ENISA includes traffic-management control operators providing ATC services among aviation entities in the NIS Directive scope it describes. It also discusses ICT/OT convergence and growing external interconnections across transport. Treat these as reasons to examine relevant connections in context—not as proof of a particular operator’s vulnerability or a substitute for checking national NIS2 implementation and entity-specific obligations.

How should the assessment stay current?

ATM systems and dependencies can change as technology, suppliers and operating arrangements change. SEC-AIRSPACE focused on cybersecurity-enhanced ATM risk-assessment methods for virtualization and data sharing, and explored people analytics for security awareness. The European Commission’s CORDIS record says the project ran from 1 September 2023 to 28 February 2026. Those project dates and its recorded €999,765 total cost (€999,764 EU contribution) describe the project, not a measured level of ATM cyber risk or a demonstrated reduction in risk.

Keep the assessment live by reviewing relevant changes and incidents, checking whether controls still address documented pathways, and revisiting residual-risk decisions. Coordinate with civil and military authorities and service partners where applicable, and make responsibilities clear when services rely on shared infrastructure or another organization.

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