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Threat Models as Mandatory Disclosures: A Vision for Security Transparency

By Dinis Cruz and ChatGPT Deep Research · · 31 min read

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Contents · 7 sections
  1. Executive Summary
  2. Historical Parallels: From Opaque Risk to Mandatory Transparency
  3. Roadmap to Regulatory Norm: From Ad-Hoc to Mandatory Threat Models
  4. Stakeholder Perspectives: Benefits and Trade-offs
  5. Technical Enablers for Security Transparency
  6. Partial Disclosure and Safe Transparency
  7. Conclusion: From Vision to Reality – Next Steps

Executive Summary

Digital products today suffer from a lack of security transparency, creating a classic “market for lemons” scenario in cybersecurity. Vendors often know far more about their product’s security (or lack thereof) than buyers do, leading inferior security offerings to thrive and outcompete higher-quality ones. This information asymmetry erodes trust and leaves consumers unable to distinguish secure products from insecure ones. To correct this market failure, we propose a long-term vision where publishing threat models becomes a regulatory requirement for companies – much like financial statements and food ingredient labels are mandated today. Requiring organizations to disclose standardized threat models would introduce a reliable signal of security quality into the market, allowing customers, investors, and regulators to make informed comparisons. Publishing a threat model provides concrete evidence of the threats a company has considered and mitigated, substantiating security claims that today are often vague or unverified. In the same way that transparency in finance and food safety improved those industries, security transparency via public threat models can drive accountability and higher baseline security across the software ecosystem. This document outlines the rationale, historical analogies, a maturity roadmap, stakeholder impacts, technical enablers, and practical steps toward making threat model disclosures a norm in corporate practice. It blends visionary foresight with concrete next steps for the threat modeling community and policymakers.

Historical Parallels: From Opaque Risk to Mandatory Transparency

Financial Reporting: In the early 20th century, financial markets were rife with hidden risks and corporate misdeeds. The 1929 stock market crash and ensuing Great Depression exposed how lack of transparency enabled fraud and shattered public confidence. The regulatory response – including the Securities Act of 1933 and the Securities Exchange Act of 1934 – fundamentally changed the game by mandating truthful financial disclosures. Companies selling securities were now required by law to provide audited financial statements and reveal material risks, so that investors could make informed decisions. For example, the 1933 Act “required registration of most securities sales” and insisted that “investors must receive truthful financial data about public securities” being offered. Over subsequent decades, financial transparency became routine: quarterly reports, annual audits, and standardized accounting rules (GAAP/IFRS) turned corporate finance from a black box into a well-lit storefront. This didn’t eliminate all fraud or failure, but it raised the overall trust and stability of markets by exposing lemons and rewarding sound management. Today, no serious company could imagine raising capital without publishing its financial health – it’s simply an expected duty of market participation.

Food and Product Labeling: A similar evolution occurred in food safety and consumer products. In the past, buyers had little insight into what they were ingesting – harmful ingredients, poor hygiene, and false claims were common. Public outcry and health scandals eventually led to regulations forcing transparency in labeling and standards. A landmark in the United States was the Nutrition Labeling and Education Act of 1990, which “required standardization of the health and nutritional information food manufacturers provide to consumers on food packages”, giving birth to the now-familiar Nutrition Facts label. Suddenly, companies had to openly disclose calories, ingredients, and daily values, subject to uniform definitions. This empowered consumers to compare products and made nutrition a competitive factor, incentivizing improvements. Analogous mandates exist for product safety (e.g. appliance energy ratings, car safety crash ratings, etc.), all based on the principle that transparency drives quality. What used to be proprietary or inconsistent information became a common baseline of disclosure. The food industry did not crumble under these requirements; rather, it adapted and innovated, and consumers rewarded those who delivered healthier, safer products. The progression from an opaque “buyer beware” market to one of labeled, accountable goods is a powerful precedent for cybersecurity.

Cybersecurity Today: By comparison, the digital products industry is still in a Wild West stage regarding transparency. When a software vendor claims to be “secure” or “enterprise-grade,” buyers largely have to take it on faith. Aside from basic compliance checkboxes or penetration test certificates (which are often private), there is no widely mandated disclosure of how a product was secured or what threats were considered. As a result, the software market exhibits the same failures once seen in finance and food: security quality is largely unverifiable, so bad practices hide behind marketing rhetoric. Studies and experts have noted that cybersecurity markets suffer from serious information asymmetry – buyers can’t verify claims, so weaker products often prevail on cost or features. Just as the best cars were driven out of the used-car market before transparency, the most secure software can be undervalued if nobody knows the difference. The absence of a “security label” or public threat model keeps everyone in the dark. The next sections lay out a vision for moving cybersecurity onto a path already tread by finance and food: from opacity to transparency, from voluntary best-effort to regulated disclosure of security posture, with threat models as the centerpiece of that transparency.

Roadmap to Regulatory Norm: From Ad-Hoc to Mandatory Threat Models

Achieving mandatory threat model disclosures will be a journey. We can chart the evolution of this practice in maturity stages (borrowing Wardley Mapping’s concepts of Genesis, Custom-Built, Product, and Commodity). Below is a roadmap from the current state to a future state where publishing threat models is an established regulatory norm:

Transitioning through these stages will require effort and advocacy. Early in the roadmap, voluntary action and industry collaboration are key – developing standards, proving feasibility, and demonstrating the benefits. Later, top-down pressure from regulators will likely cement the practice (just as financial disclosure was eventually enforced by law). Wardley Mapping this journey helps to anticipate the tipping points: for example, moving from Custom to Product stage might coincide with the release of a widely used threat modeling platform or an open standard that gains broad support. Moving from Product to Commodity will likely require regulatory intervention or a major paradigm shift (perhaps a scandal that prompts legislation, akin to financial crashes or food safety incidents). The trajectory is clear: to make security a visible, comparable attribute of products, we must evolve threat modeling from today’s niche art into tomorrow’s mandatory business practice.

Stakeholder Perspectives: Benefits and Trade-offs

Adopting mandatory threat model disclosures would impact various stakeholders in different ways. We outline the key benefits and potential trade-offs for four primary groups:

Technical Enablers for Security Transparency

Turning the vision of mandatory threat model disclosure into reality will require significant technical groundwork. Several enablers must be in place to support standardization, automation, and safe sharing of threat models. Here we outline the key technical components and initiatives needed:

Partial Disclosure and Safe Transparency

A frequent concern is that publishing a threat model could hand attackers a “map” to exploit the system. It’s a valid point to address – how do we enable transparency while maintaining security? The answer lies in partial disclosure and careful anonymization, which allow organizations to share the essence of their security posture without revealing sensitive details that could aid an attacker. This approach is similar to how companies disclose financial risks: enough detail to inform investors, but not the exact combination to the safe.

The Role of Partial/Anonymized Threat Models: In practice, companies can maintain multiple versions of a threat model for different audiences. The most detailed model, including granular system specifics, remains internal for engineering use. From that, organizations can derive a sanitized version for public disclosure. This sanitized threat model would focus on threats, impacts, and mitigations in general terms, omitting specific technical information like IP addresses, exact software versions, or other data that might facilitate an attack. As the Designing Secure Software initiative suggests, you might tag sections of the master threat model by audience, then compile a high-level overview for executives and customers, and a more technical (but still scrubbed) version for integrators or regulators. Key to this approach is that the threats and mitigations themselves are not secret – indeed, they shouldn’t be. If your product relies on “security by obscurity” (keeping the very existence of a vulnerability secret), that’s a fragile strategy. Instead, openly acknowledging a threat (e.g. “Threat: data exfiltration by insider”) and stating that you have a mitigation (without necessarily detailing the exact monitoring rules) does not weaken your security – it strengthens trust. It’s akin to a bank saying “We’re threatened by robbers, so we have armed guards and vaults”; that doesn’t tell the robber how to rob the bank, it just assures customers their money is protected.

Analogy to Open Source and Vulnerability Disclosure: There is an instructive analogy in the world of open source software and vulnerability disclosure. Releasing source code could, in theory, help attackers find flaws; yet it also enables a vast community to inspect and strengthen the code. Similarly, disclosing a vulnerability publicly could alert attackers, but it’s accepted (with coordinated disclosure) because it leads to fixes and awareness. Publishing threat models sits somewhere in between – it’s a proactive disclosure of potential issues and defenses. Yes, attackers could read it, but they likely learn little that they wouldn’t already assume. Attackers usually know that, say, a web application might have XSS or SQL injection; a threat model confirming “we considered SQL injection and have input validation” doesn’t give away a zero-day, it just tells the world the developers are mindful of that class of attack. As one commentary put it, “open threat modeling should never be divulging any crown jewels, it’s more like a ‘spec sheet’ for security considerations.”. A spec sheet for a car lists the safety features (airbags, ABS, etc.) – useful to the buyer, and not particularly useful to a thief. Likewise, a security spec sheet (threat model) lists security features and risk assumptions. By carefully stripping out implementation specifics, companies can avoid providing a roadmap for attackers while still demonstrating due diligence.

Building Secure Transparency Practices: To implement partial disclosure effectively, organizations will develop guidelines and perhaps automated tools as mentioned. For example, a guideline might state: “Include threat categories, attacker types, potential impacts, and mitigations. Omit exact configurations, detection thresholds, or anything that would significantly aid in bypassing a control.” In cases where a mitigation is sensitive (maybe a proprietary anomaly detection algorithm), the public model can state “anomaly detection in place” without detailing how. The assumption is that attackers, if sophisticated, will assume you have some detection anyway – saying so doesn’t increase their chances. Meanwhile, honest stakeholders get confidence that you have considered the issue. Companies can also explicitly call out what is not addressed in the public model. For instance, “Out-of-scope: this product is not designed to resist hardware tampering” – such a statement can be important for user awareness (just as a food label might say “contains peanuts”). It’s better to be transparent about exclusions than for users to find out the hard way. Indeed, a public threat model might include an “accepted risks” section for threats that remain (this can actually spur useful market discussion: perhaps a competitor will advertise that they do mitigate that risk, pushing others to improve).

The notion of having internal vs external threat models is already advocated by experts. Internal models can be fine-grained and even include “attack playbooks” or red-team findings – things you’d never publish. External models focus on broad strokes. We can also leverage legal frameworks: for example, maybe only a summary is public, and regulators get to see a fuller version under confidentiality. Over time, as comfort grows, the line between what’s public and private may shift (likely towards more public, as we realize it doesn’t harm security). Companies may even decide to open up more once they see the benefits – similar to how open-source software went from fringe to mainstream as the benefits outweighed the perceived risks.

Addressing Legal and Competitive Fears: Partial disclosure helps with concerns beyond just security – it also addresses intellectual property and liability worries. By removing specifics, companies aren’t giving competitors a blueprint of their system; they’re merely sharing principles and measures that any competent firm should have. In terms of liability, one might worry “if we publish a threat model and later a breach happens via something not in it, are we exposed to lawsuits?” This is where careful wording and perhaps regulatory safe harbors will help: the threat model can include disclaimers that it’s not exhaustive or is as of a certain date. Regulators could provide that a good-faith threat model disclosure won’t be used to penalize a company unless there was gross negligence or deception. In fact, transparency can be protection against negligence claims: it shows you exercised due diligence in thinking about security. If anything, it’s companies that hide their practices that suffer worse in court of public opinion after an incident (“what did they know and when? why didn’t they at least warn users of this risk?”). With open threat modeling, the dialogue changes to a more collaborative tone – customers and third-party experts might even help improve your security by reviewing your threat model and providing feedback or spotting omissions (much like open source contributions).

In summary, secure transparency is achievable. By publishing threat models in a controlled, anonymized way, organizations can reap the benefits of market trust and informed stakeholders without materially increasing their attack surface. The process is akin to walking a path that other industries have walked: find the right level of abstraction where useful information is shared but sensitive details remain confidential. As the “Flaunt your Threat Models” article encapsulates, if done properly, sharing threat models “amounts to security by transparency, not by obscurity – a stronger posture where you’re not betting on secrecy to save you”. Instead of hoping attackers never figure out your weak points, you’re proactively shoring them up and confident enough to show your work. That cultural shift, from secrecy to openness, is at the heart of the vision for mandatory threat model disclosures.

Conclusion: From Vision to Reality – Next Steps

Mandating threat model disclosures as a norm will not happen overnight, but the path is becoming clear. This vision is both ambitious and practical: ambitious in that it foresees a world with radically higher security accountability, yet practical because it builds on patterns seen in other domains and incremental progress already underway. To transform this foresight into reality, a blend of community effort, industry initiatives, and regulatory action will be needed.

Industry and Community Initiatives: The threat modeling community can start by promoting voluntary transparency as a competitive advantage. Security-conscious companies should consider publishing (even partial) threat models for flagship products as a pilot, demonstrating the concept and learning the best practices of sanitization and presentation. Early movers can publicly “flaunt” their threat models to show leadership, much as some companies today publish transparency reports or open-source security tools for goodwill. Industry groups (like the OWASP Threat Modeling community, the Threat Modeling Connect conferences, etc.) can collaborate on developing the open standards discussed – finalizing a common threat model schema, perhaps through a consortium or an open project. Tool vendors should align on export/import formats (the work by IriusRisk on an Open Threat Model standard is a good example). Additionally, creating reference libraries of threat models for common systems (analogous to design patterns or the OWASP Top Ten but for threat models) can help newcomers and provide templates to reduce the burden. Efforts by individuals like Dinis Cruz in pushing graph-based knowledge-sharing, and projects like OWASP OdTM, should be supported and extended – they are building the infrastructure on which this transparency will run. The community should also engage in educational outreach: training developers and security staff not just how to threat model, but how to communicate threat models to different stakeholders. This is a new literacy we must develop, akin to how the financial world had to develop investor relations communications.

Policymaker and Regulator Actions: Regulators and governments can start laying groundwork by incorporating threat modeling into existing frameworks. For example, the SEC’s recent cybersecurity risk disclosure rules could be expanded in the future – today they require describing processes and incidents, but tomorrow they could encourage or mandate including a summary of the organization’s threat assessment and mitigations (essentially a high-level threat model) in annual reports. Sector-specific regulators (energy grid, aviation, healthcare) might begin by asking companies to produce threat models internally as part of compliance, and eventually for critical areas consider public executive summaries of those models. Governments can also fund or endorse the development of standards (NIST, for instance, could publish guidelines on threat model disclosure and maybe pilot a “cyber nutrition label” program). The idea of security labels is already gaining traction, especially for consumer IoT devices – threat model disclosure is a logical extension/upscale of that concept for more complex software and services. Lawmakers should explore liability protections to encourage transparency – analogous to how the SAFETY Act in the US provides some liability limits for approved security measures, we might provide safe harbor for those who do transparent threat modeling in good faith. Furthermore, regulators can convene industry panels to hammer out what a reasonable disclosure looks like in different contexts (the needs of a cloud service vs. a medical device will differ). Finally, an eye should be kept on international harmonization: cybersecurity is global, so aligning standards across major markets (e.g., US, EU, UK, Asia) will prevent fragmentation and reduce the burden on multinational firms.

Visionary but Incremental: The long-term vision painted here is one of a safer digital ecosystem where security is not a hidden attribute but a visible, comparable aspect of products. It draws on lessons from the past – when transparency took hold in finance and food, both industries saw improved outcomes and greater trust. Achieving the same for cybersecurity will require overcoming cultural inertia (“we’ve always kept security info secret”) and addressing real challenges (standardization, not giving attackers undue info). But the benefits are compelling: an end to the lemons market in security, empowered consumers, and a race to the top for product security quality. The trajectory will likely be incremental: from a few companies voluntarily publishing threat models, to industry standards emerging, to partial regulatory adoption (perhaps in critical sectors or for large public companies first), and eventually broad regulation that solidifies the practice for all. Along this path, the threat modeling community has a critical role to play in advocating, prototyping, and refining the approach.

In conclusion, mandatory threat model disclosure represents a paradigm shift in how we think about cybersecurity accountability. It moves us toward a future where security due diligence is transparent and continuously improving through feedback loops. Much like a food nutrition label doesn’t guarantee health but empowers choices, a security threat model label would empower stakeholders to choose and demand better security. The journey to get there will entail developing new standards and habits, but each step – whether it’s adopting a common threat language, using graphs and ontologies for knowledge sharing, or simply deciding to publish a threat summary for your next software release – is a step toward correcting the imbalance of today’s market. It is a future where the norm is to share, not to hide, our understanding of threats. In that future, attackers will face a more united and informed defense, and the market will reward those who do security right. The message to the industry is clear: let’s start treating threat models not as private memos, but as public contracts of trust. The sooner we begin, the sooner the “market for lemons” in software can become a market of safety and assurance.

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