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Well - here we are talking about ice, so it’s comparatively easy to penetrate, by drilling or melting. Methods are already worked out for Europa. Brian Wilcox is working on a 100% sterile probe to descend into the Europan ocean. It would have vacuum insulation like a thermos flask, a blade that cuts ice chips that the body then melts and analysed. It would be sterilized first by heated to over 900 °F (500 °C) during its cruise to Europa which would not only kills microbes but also decomposes organics that would confuse the results.
Vacuum insulated probe for Europa (screenshot from this YouTube video) - it doesn't heat the ice directly. Instead a blade at the tip cuts the ice into chips which the probe then melts and analyses. The probe would be heated to over 900 °F (500 °C) throughout the cruise out to Europa. It uses plutonium 238 for the melting - and so, presumably for its power source too, so there is no problem with batteries vulnerable to heating.
He describes it in a paper here (abstract, the paper itself is behind a paywall).
In his abstract he says
"A central thesis of this work is that we must start by addressing the Planetary Protection constraints, and not to try to add them on at the end. Specifically, all hardware in the probe would be designed to survive heat sterilization at 500 °C for extended periods, as required to meet the COSPAR 1-in-10,000 probability per mission of biological contamination of the ocean"
The NASA summary says
"To ensure no Earth microbes hitched a ride, the probe would heat itself to over 900 degrees Fahrenheit (482 degrees Celsius) during its cruise on a spacecraft. That would kill any residual organisms and decompose complex organic molecules that could affect science results."
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