Introduction:

The European Union Cyber Resilience Act (CRA) is a landmark regulation designed to enhance cybersecurity across hardware and software with digital elements that are offered for sale within the EU. As cyber threats continue to evolve, the CRA introduces mandatory security requirements for manufacturers to ensure that products placed on the EU market are resilient to cyberattacks.

This blog explores the key objectives, scope, and implications of the CRA, helping businesses and stakeholders understand what they need to do to comply with this important legislation.

Why the EU Introduced the CRA

Cybersecurity incidents are on the rise, affecting businesses, governments, and individuals. Many products on the market today lack basic security measures, exposing users to significant risks. The EU CRA aims to address these gaps by:

• Strengthening cybersecurity standards across products with digital elements.
• Protecting consumers and businesses from vulnerabilities and cyber threats.
• Enhancing supply chain security to prevent systemic risks.
• Creating a unified cybersecurity framework that aligns with existing EU regulations, such as the NIS2 Directive and the Digital Operational Resilience Act (DORA).

Key Elements of the EU Cyber Resilience Act

The CRA introduces a set of mandatory security requirements for hardware and software products with digital elements. These requirements apply throughout the entire product lifecycle, from design to disposal.

1. Scope: Which Products Are Affected?

The CRA applies to any product with digital elements - essentially any hardware or software that can connect to a network or another device, or has data processing capabilities. It includes finished products (like fitness trackers), but also individual components or software that are integrated into other systems.

Examples include:

• IoT devices (smart home appliances, wearables, industrial IoT solutions).
• Software applications (operating systems, cloud services, and AI-driven software).
• Cybersecurity solutions (firewalls, VPNs, and authentication systems).
• Critical infrastructure components (ICS/OT systems, SCADA solutions, and networking equipment).

Certain high-risk products may require additional security assessments and certification before entering the EU market.

Medical devices, motor vehicles, aeronautical products, and marine equipment are excluded from the CRA’s scope as they are governed by their own individual regulation.

2. Security by Default 

Manufacturers and software developers must implement secure-by-design principles, ensuring that products:

• Have secure-by-default configurations.
• Are resilient against known cyber threats.
• Minimize vulnerabilities during development and throughout their lifecycle.

3. Vulnerability Management and Security Updates

Under the CRA, organizations must:

• Establish a vulnerability monitoring and disclosure process.
• Provide timely security updates and patches to address emerging threats.
• Maintain transparent communication with regulators and users regarding security risks.

4. Supply Chain Security Requirements

Manufacturers must ensure their third-party suppliers and components meet CRA security standards. This includes maintaining a Software Bill of Materials (SBOM) to track dependencies and identify vulnerabilities.

5. Compliance and Enforcement

The CRA is currently slated to go into effect in December 2027.  Non-compliance with the CRA can result in:

• Fines of up to €15 million or 2.5% of global annual revenue, whichever is higher.
• Market restrictions, preventing non-compliant products from being sold in the EU.
• Increased scrutiny from regulators and potential legal liabilities.

How Businesses Can Prepare for CRA Compliance

With the CRA set to reshape cybersecurity requirements, businesses should take proactive steps to ensure compliance:

1. Conduct a cybersecurity risk assessment to identify gaps in product security.
2. Implement secure software development lifecycle (SDL) practices.
3. Establish a vulnerability management program to track and respond to threats.
4. Enhance supply chain security by requiring CRA compliance from third-party vendors.
5. Align with existing cybersecurity frameworks such as ISO 27001, NIST, and IEC 62443 to streamline compliance efforts.

Conclusion

The EU Cyber Resilience Act marks a significant step toward a more secure digital ecosystem by setting strict cybersecurity requirements for digital products. Organizations that take early action to align with CRA mandates will not only ensure compliance but also gain a competitive edge by delivering more secure and resilient products to the market.

As the CRA moves closer to implementation, businesses must stay informed, assess their cybersecurity practices, and work towards compliance to avoid regulatory penalties and security risks.

References

Cyber Resilience Act (CRA) | Updates, Compliance:  https://www.european-cyber-resilience-act.com/

EU Cyber Resilience Act: https://www.simmons-simmons.com/en/publications/cm6gcjsf707b0tr0kozughngv/the-eu-cyber-resilience-act