This work presents a methodology for evaluating the uncontrolled external leakage probability of a subsea well during the production phase. Based on a barrier diagram, an algorithm for possible leak path identification is proposed, considering different operation modes: gas lift operation, free-flowing, or well closed at the subsea Christmas tree. Considering the equivalency between these paths and the minimum cut sets from a fault tree modeling, the uncontrolled external leakage probability is calculated using the upper bound approximation. The effect of common cause failures is considered for the failure mode fail-to-close-valve. The instantaneous availability function of each component is considered. Non-repairable, repairable, and periodically tested items are used. Probability distribution parameters are estimated in order to make a case study. The failure rate functions determined are used as input for the proposed model, regarding the following failure modes: fail-to-close, external-leakage, and internal-leakage at the closed position. Finally, failure probability results and sensitivity analysis are demonstrated for a base case study. Parameters like time between tests, inspections, and component reliability are varied in order to identify the impact on the uncontrolled external leakage probability. The main objective of the proposed methodology is to support decision-making on the well integrity management system during the production phase of a subsea well. To this end, actual and reliable input data should be considered.