Why ELTON · FDA Traceability

Every finding traces
to its test case.

ELTON derives threats from the digital twin, test cases from the threats, and findings from the tests, so a reviewer can walk any verdict back to the design.

One finding, walked back
Finding
EL-2231 · Unsigned application binary accepted
Conditionally exploitable
Test case
Application binary and runtime-library integrity verification
TC-Jk4Tn-9wVbPFailed
Threat instance
Applications Binaries Modified on the dock gateway
TH-Qm7Lr-Xe2Bd
Threat and property
TID-301, mapped from PID-31
EMB3D
Twin component
Dock gateway, Vireo CP-7 release 4.2
Generic application
Example data on a fictional infusion system.
The chain

Five links,
one unbroken record.

Each link is generated from the one before it, so nothing in the report exists without a parent.

01Digital twincomponents, interfaces,data flows, assets02ThreatsEMB3D properties map tothreats, per component03Test casesgenerated for everythreat instance04Findingsa failed test casebecomes a vulnerability05Exploitabilityconditions and accessdecide the verdictA REVIEWER WALKS THE SAME CHAIN IN REVERSE
Twin, threats, test cases, findings, exploitability. The report is the chain read backwards.
Threat model

Threats come
from the twin.

Each component's EMB3D properties map to threats, and each threat becomes an instance on every component it applies to.

Example data on a fictional infusion system. The layout is the ELTON threat model, Instances view.
Test cases

Every threat instance
carries its test cases.

Open an instance and the mapping is on the page: the component, the property, the threat, and each test case with who ran it and what it returned.

The same instance, opened. Component to property to threat, then the test cases mapped to it.
From test to verdict

A failed test case
becomes a finding.

The finding is then analyzed for exploitability: which conditions it needs, and what access or attack surface produces them.

TEST CASEBinary integrity verificationTC-Jk4Tn-9wVbPrun on the dock gatewayFAILEDFINDINGUnsigned application binaryacceptedEL-2231 · CWE-862VULNERABILITYCONDITION AND ACCESSNeeds write access to theapplication partitionreached through the service USB portin maintenance modeVERDICTConditionallyexploitablecondition named and tracked
One failed test case on the example product, followed to its verdict.

Conditions

What has to be true before the flaw can be used. Each condition is named, and each one traces to the finding or setting that produces it.

Vulnerability Chaining →

Access and attack surface

Which entry vectors reach it: a network port, a radio, a service connector, hands on the case. The twin already holds them.

Digital Twin Traceability →

The verdict

Directly exploitable, conditionally exploitable, unexploitable weakness or mitigated weakness, proven on the device where the answer depends on it.

FDA Vulnerability Verification →
Verification, traced to the twin

FDA traceability, automated.

A finding is not closed by opinion. Every test case comes from the device’s own threat model, runs at the deepest tier you open, and lands as evidence: an unbroken chain from CVE to determination that reviewers can follow. Deeper access closes more findings as Not Affected, and every VEX statement gets stronger.

FULL REGULATORY TRACEABILITY · EVERY RESULT TRACES BACK TO THE TWINDigital TwinComponents, interfaces,data flows, assetsTest CaseEMB3D PID + LLM logic,tailored to this deviceExecuteAt the deepestavailable tierResultPASSFAIL+ evidence and narrativeFindingAffected / Not AffectedVEX OUTDEEPER ACCESS, HIGHER CONFIDENCE, MORE FINDINGS CLEAREDLEVEL 1Digital Twin MetadataArchitecture, SBOM, reachability andsecurity-profile overlay. Reason aboutexploitability from composition.CLOSED AS NOT AFFECTED30-40%Baseline confidenceLEVEL 2Code & FirmwareCustom harnesses from real code. Staticanalysis and emulation confirm which paths areactually reachable.CLOSED AS NOT AFFECTED50-65%Strong confidenceLEVEL 3Real Hardware RuntimeLive exploit attempts on the actual device.What truly works, and what does not, on realsilicon.CLOSED AS NOT AFFECTED70-85%Highest confidence
What FDA asks for

Traceability is
in the guidance.

Three of the eleven activities in every subscription exist to answer it.

ELTON activityWhat FDA asks forWhereHow ELTON evidences it
Threat-model-driven test case creationA threat model that informs the risk assessment and the test plan, so what gets tested follows from how the device can be attacked.Premarket guidance, Section V.A.1 Threat Modeling and Section V.A.3 threat mitigation testing.Test cases are generated from the twin's components and their EMB3D properties, so coverage reads as a list before testing starts.
Test case traceability to designTraceability from security requirements and design controls to the tests that verified them, kept in the design history file.Premarket guidance, Section V.A.3 and Appendix 2; QMSR, 21 CFR Part 820 incorporating ISO 13485 clauses 7.3.3 and 7.3.6, design inputs and design verification.Every test case maps to the twin component and the control it exercises, and the matrix exports with the report.
Vulnerability traceability to test casesFindings tied to the tests that produced them, including a security assessment of unresolved anomalies.Premarket guidance, Section V.A.3 test reports and Section V.A.1, assessment of unresolved anomalies.Every finding links to its test case, its evidence and its component, so a reviewer can walk from the vulnerability back to the test.
Anatomy of a verdict

Every finding carries its own receipts.

A verified ELTON finding is not a row in a spreadsheet. It is a package a reviewer can replay: the test case that ran, the execution log it produced, the observed result, and the VEX status that follows. Dismissals carry the same package, because not affected is a claim that needs proof too.

PROBABILITYopinions about likelihoodCVSS 9.8worst-case deployment, not your deviceEPSS 0.94population statistics, not your buildReachability estimatea static guess that never ranTHE LADDEReach tier must earn the next, upward is harderL1 · DIGITAL TWINNo path on this architecture? Dismissed with the reasoning.L2 · CODE & FIRMWAREPresent in the shipped build? Confirmed at the source.L3 · REAL DEVICEThe exploit executes, on the bench over TestLink™ or in our lab.a score enters at the bottom, only evidence leaves the topExecuted proof of conceptthis is what earns the word vulnerabilityFailed exploit, with whya weakness, dismissed on evidenceVEX your customers ingestmachine readable, replayable, current
The ladder from a number in a database to a result a reviewer can replay.

Each verdict also answers the questions SSVC actually asks. Is the attack automatable? Does it end in total compromise of the device? Which vectors reach the flaw? Is there a working proof of concept? Grounded in an executed test, those four answers turn a score into a decision you can defend.

Proof is the foundation the rest of the platform stands on. It is how ELTON can find the 1% that matter, why an FDA-qualified rating methodology holds up in review, and what separates the pipeline from a prompt. The mechanics live on the verification page.

Go deeper

Where the trace goes next.

The same chain carries the verification, the twin and the compliance map.

Get started

Walk a finding back to the twin.

Bring one device. We build the twin, derive the threats and test cases, and hand you a finding you can trace to the component it started on.

Questions

Common questions
about FDA traceability.

What does FDA mean by cybersecurity traceability?

FDA's premarket cybersecurity guidance asks for a threat model that informs the test plan, test reports in the submission, and an assessment of unresolved anomalies. Traceability is the ability to walk between them: from a design element to its threats, from a threat to the tests that exercised it, and from a finding back to the test that produced it.

How does ELTON generate test cases from a threat model?

The digital twin holds the device's components, interfaces, data flows and assets. Each component type carries MITRE EMB3D properties, each property maps to threats, and each threat becomes an instance on every component it applies to. Test cases are generated per instance, so coverage reads as a list before testing starts.

What happens when a test case fails?

A failed test case is promoted to a finding, and the result stays attached as its evidence. The finding is then analyzed for exploitability: the conditions it needs, and the access or attack surface that would produce them. The verdict is directly exploitable, conditionally exploitable, unexploitable weakness or mitigated weakness.

Can a reviewer follow a finding back to the design?

Yes. Every finding links to its test case, the threat instance the test case came from, the EMB3D threat and property behind it, and the twin component it sits on. The matrix exports with the report.

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