Hello everyone,


Kindly let me introduce myself. This is the first – and potentially, last – 
message on this mailing list. I am Marco, the CISO of EQS Group. Kindly allow 
me to address some of the statements expressed publicly here.



About the Convercent application



Convercent was acquired by OneTrust in 2021, and in turn, EQS has acquired it 
from OneTrust at the end of 2024. Before being acquired by EQS, the Convercent 
application has not received much love in the latest years, and EQS has since 
then proceeded to migrate its customers to the EQS Compliance COCKPIT, which is 
a modern, supported, and secure SaaS. The Convercent application is sunset and 
will be finally switched off by mid of 2026.



Currently, Convercent is supported by EQS on a best-effort basis; despite that, 
EQS Group has committed to fix all critical vulnerabilities until the last 
customer is fully migrated. We want our customers to migrate to our best 
service because it is better – not rush them in our new product because what we 
inherited from an acquisition is insecure.





The vulnerabilities



The two issues disclosed are either minor in nature or do not constitute 
vulnerabilities. One was a lack of certain HTTP headers (some of the reported 
ones where wrong, but regardless, still hardly something CVE-worthy), and the 
second was about an “exposed” API; however, it is public by design as this is 
how the application works: it is a page where customers – who have explicitly 
agreed and signed off to be present – are added to a drop-down list, fed from 
this public API. The web page exposes the list of customers by design.



While we may reasonably question whether this page reflects current 
secure-by-design standards, this brings zero added risk to any of the EQS 
customers and Convercent users.



I strongly disagree with the ideas that those “vulnerabilities” could become 
CVEs – regardless of the status of the SaaS security and how CVEs are handled. 
Therefore, we proceeded to ask for their removal from the CVSS database, so not 
to alarm our customers with false positives. The responsible CNA agreed 
immediately to remove them (thank you very much, VulnCheck!).





Communication with our customers



EQS Group communicates with its customers through established and appropriate 
channels – notably, our Trust Center – and not via anonymous mailing lists. 
Customers have received and will continue to receive all the notifications they 
have contractually required to obtain, and where relevant, additional context 
beyond those obligations.



Customers have received a briefing about the activity happening on this mailing 
list via our Trust Center.





The status of SaaS Security



As EQS Group is a CNA candidate, we participate and closely follow discussions 
between MITRE, CISA, and the German BSI, about vulnerability reporting for 
SaaS. While we have not heard any news on this front since the last two years, 
EQS Group remains committed to aligning with applicable best practices as they 
evolve.


We believe that meaningful progress in SaaS security is best achieved through 
structured, collaborative forums with clear governance, rather than responding 
to ad-hoc reports of unvetted findings. EQS Group already participates to 
proper, professional working groups on SaaS security, for instance through the 
Cloud Security Alliance. If other working groups will emerge through any of the 
official organisms already mentioned, we will certainly participate.


In general, as a principle, CVEs have been created many years ago, at a time 
where “the Cloud” did not exist in its current form. They were conceived so 
that users who procured a software from a development company and installed it 
on their system, could be notified when the software they have installed, 
manifested a security issue. In that way, they could procure the patch and fix 
it before a misuse could happen.


Now, except for very particular and edge cases, this is largely inapplicable to 
SaaS, where there is very little users can do and solely rely on the Cloud 
Service Provider to fix any vulnerability. There is almost never any real 
ground for a SaaS provider to notify a customer – unless of course a breach has 
been detected, but in that case we are way beyond a CVE and we are on a 
different territory. For a SaaS, even knowing that the application had a bug, 
does not help the user in any way. This is why typically CVEs as a concept are 
not the proper tool to address SaaS vulnerabilities, and in general, rushing to 
disclose them only damages the users; a disclosure does not help them in any 
way.




Response to the “Responsible" Disclosure



About the “responsible" disclosure: EQS Group receives a significant volume of 
“vulnerability notifications” like that one. Almost all of them are low or 
irrelevant issues from anonymous users looking to make a buck; they are 
typically about a missing HTTP headers or lack of optional DNS records. Given 
the scale of our environment, it can happen that some record is not updated, 
but this has little relevance to the security of our platforms. We also cannot 
always reply to all those messages, and most of them seem AI or automatically 
generated.



The notification from “Yuffie Kisaragi” was sent to us on the 4th of December 
and went to Junk due to the low reputation of the email used. The author then 
rushed to obtain two CVE IDs less than two weeks later and subsequently lost no 
time posting them on this list.



EQS Group is certainly not perfect, but if these would have been real 
vulnerabilities, I argue that this would have not qualified as a “responsible” 
disclosure by any reasonable standard.



Further communications


EQS Group’s vulnerability handling policy is listed 
here<https://www.eqs.com/report-a-vulnerability/#handle> –  
https://www.eqs.com/report-a-vulnerability/ – and we strongly suggest anyone to 
read it before they issue a report.



In this regard, we would like to point out the followings:

  1.  For several reasons – legal, commercial, policy, and ethical – EQS Group 
is unable to respond to requests for payment of bounties outside of an official 
bug bounty program.
  2.  EQS Group does nor remunerate bugs that were already discovered 
internally and were already in resolution.
  3.  EQS Group strongly discourages non-approved, un-vetted testing on EQS 
Group’s infrastructure. They can and will be perceived as hostile activity. 
Testing is encouraged only within officially approved bug bounty programs, in 
respect to the established rules of engagement.
  4.  Kindly avoid pointless reports on MTA-STS records, DMARC, quantum 
ciphers, and other junk like that. It makes our life easier.



Thank you for your attention.

Best regards / mit freundlichen Grüßen / Cordiali saluti

Dr Marco Ermini (He/Him)
Chief Information Security Officer (CISO)

[email protected]<mailto:[email protected];>

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From: Wade Sparks <[email protected]>
Date: Wednesday, 21. January 2026 at 17:29
To: Yuffie Kisaragi <[email protected]>
Cc: Security Vulnerability <[email protected]>, 
[email protected] <[email protected]>
Subject: Re: Multiple Security Misconfigurations and Customer Enumeration 
Exposure in Convercent Whistleblowing Platform (EQS Group)


EXTERNAL EMAIL WARNING: Please check the sender of the message

Hello Yuffie,

Upon further investigation, the VulnCheck CNA determined that these 
vulnerabilities were not suitable for CVE assignment. The vulnerabilities exist 
within a SaaS product and are mitigated at the CSP-level which in this case, 
would be the vendor, EQS Group. Rather than contribute unactionable CVE 
records, the VulnCheck CNA used its discretionary prowess to move forward with 
rejecting these records. This policy aligns with a 2022 blog from 
MITRE<https://www.cve.org/Media/News/item/blog/2022/09/13/Dispelling-the-Myth-CVE-ID>.
 It should be noted that the vendor informed us that they have published 
advisories for the respective vulnerabilities in their "Trust Center" customer 
portal.

These actions should not be a deterrent for you to pursue CVE assignment 
through MITRE or another research CNA.

Best regards,

[https://lh7-us.googleusercontent.com/-9dCGnQIZaW0ehyK1B0bqLmef7d7ZWuSmmmWUYJGhzNgtzRhqFPZrtO3AnQt8PETFHiv6_YST3DacZVgrxPdAYXErAMnJrF6Isn27caszruLjby7jLRuuU__5emkqFjU8hczQ307--yVVMpVSiK7Qg]<https://www.vulncheck.com/>

Wade Sparks III

VulnCheck
Senior Vulnerability Analyst


On Tue, Jan 20, 2026 at 12:13 PM Yuffie Kisaragi 
<[email protected]<mailto:[email protected]>> wrote:


Dear Art,


Thank you for sharing your detailed evaluation and for pointing out the 
relevant sections of the CNA Rules.


Your argument is well reasoned, particularly with respect to the current 
guidance on SaaS and exclusively hosted services.


I have forwarded your evaluation to the CNA for further consideration. It will 
also be important to understand the vendor’s perspective in light of the points 
you raised, especially regarding the applicability of the 
“exclusively-hosted-service” tag and the removal of prior restrictions.

We look forward to receive transparent feedback from the CNA and/or the vendor.

To date, the vendor has remained silent with regard to informing their users 
about the reported issues. As far as we can determine, no public advisory or 
user-facing communication has been issued via their vulnerability reporting 
channel (https://www.eqs.com/report-a-vulnerability/) or elsewhere.

Best regards,

Yuffie

On Tue, Jan 20, 2026 at 7:26 PM 
<[email protected]<mailto:[email protected]>> wrote:

Hi,

> the vulnerabilities are no longer considered eligible for CVE tracking, 
> despite being real, independently discovered, responsibly disclosed, and 
> acknowledged by the vendor.
CVE IDs *can* be assigned for SaaS or similarly "cloud only" software. For a 
period of time, there was a restriction that only the provider could make or 
request such an assignment. But the current CVE rules remove this restriction:

4.2.3 CNAs MUST NOT consider the type of technology (e.g., cloud, on-premises, 
artificial intelligence, machine learning) as the sole basis for determining 
assignment.

It would have been acceptable (even preferred) to leave CVE-2025-34411 and 
CVE-2025-34412 published and identify them as affecting an 
"exclusively-hosted-service:"

5.1.11.1 (A CVE Record) MUST use the “exclusively-hosted-service” tag when all 
known Products listed in the CVE Record exist only as fully hosted services. If 
the Vulnerability affects both hosted services and on-premises Products, then 
this tag MUST NOT be used.

Rules: https://www.cve.org/resourcessupport/allresources/cnarules

Regards,

- Art

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