What is the EU Cyber Resilience Act (CRA)?

The EU Cyber Resilience Act (CRA), officially EU Regulation 2024/2847, is a comprehensive EU regulation that establishes mandatory cybersecurity requirements for products with digital elements sold in the European Union. It applies to hardware and software products that can connect to networks or process data. The CRA aims to ensure that manufacturers, importers, and distributors maintain security throughout a product's lifecycle, including vulnerability management, security updates, and transparent communication with users. Full enforcement begins December 11, 2027.

Does the CRA apply to SaaS (Software as a Service) products?

Yes, the CRA applies to most SaaS products. The regulation covers 'products with digital elements' which includes software that processes data or connects to networks. Cloud-based SaaS applications fall under this definition if they are sold or made available to EU customers. However, not all 22 CRA requirements apply to every SaaS product—typically 8-12 requirements apply to cloud-only B2B SaaS, while IoT products may need to comply with all 22. Use the free CRA Compliance Toolkit at cra-toolkit.com to determine which specific requirements apply to your product.

What are the main CRA requirements for software products?

The main CRA requirements for software products include: 1) Secure by Design (Article 10.1) - integrating security throughout development, 2) Secure by Default (Article 10.2) - shipping with secure default configurations, 3) Software Bill of Materials/SBOM (Article 10.5) - maintaining a list of all software components, 4) Vulnerability Handling (Article 13) - having a process to receive and address security vulnerabilities, 5) Security Updates (Article 10.4) - providing security updates for at least 5 years or the product's expected lifetime. Additional requirements may apply based on your specific product type and classification.

When does CRA enforcement begin and what are the key deadlines?

The CRA enforcement happens in phases: 1) December 10, 2024 - CRA enters into force, 2) September 11, 2026 - Conformity assessment bodies must be designated, 3) September 11, 2026 - Vulnerability and incident reporting obligations begin, 4) December 11, 2027 - Full enforcement of all requirements. Organizations selling products with digital elements in the EU should begin compliance preparations now to meet these deadlines.

What is an SBOM and why does CRA require it?

An SBOM (Software Bill of Materials) is a comprehensive list of all software components, libraries, and dependencies used in a product—like an ingredients list for software. CRA Article 10.5 requires manufacturers to maintain SBOMs because: 1) It enables rapid identification of affected products when vulnerabilities are discovered (e.g., Log4j), 2) It provides transparency about third-party components and their security status, 3) It supports vulnerability management and incident response. Free tools like CycloneDX, Syft, and Trivy can generate SBOMs automatically from your codebase.

How much does CRA compliance cost?

CRA compliance costs vary significantly: Hiring consultants typically costs €8,000-€15,000 for initial assessment and €20,000-€50,000+ for full implementation support. However, DIY compliance is possible at minimal cost using free, open-source tools: CycloneDX for SBOM generation, OWASP Dependency-Track for vulnerability monitoring, Trivy for container scanning, and Semgrep for static analysis. The free CRA Compliance Toolkit at cra-toolkit.com helps identify which requirements apply to your product, potentially saving thousands in unnecessary consultant fees. Additionally, EU SMEs can apply for up to €30,000 in grants through the SECURE/Secure4sme program (50% co-financing).

Is my US-based company affected by the CRA?

Yes, if your US-based company sells products with digital elements to customers in the European Union, the CRA applies to you. The CRA has extraterritorial reach—it applies based on where products are sold, not where the company is based. If you place products on the EU market (even through distributors or resellers), you must comply with CRA requirements. This is similar to how GDPR applies to non-EU companies that process EU residents' data.

What products are exempt from CRA?

Several categories are exempt from CRA: 1) Internal tools not placed on the market, 2) Custom software developed for a single client, 3) Products already regulated under other EU frameworks (medical devices, vehicles, aviation), 4) National security and military products, 5) Open-source software developed non-commercially by individuals or non-profit foundations (though commercial entities using open-source remain liable). SaaS products serving only internal company use would not be in scope, but any product offered to external EU customers likely falls under CRA.

What is the difference between CRA and NIS2?

CRA and NIS2 are complementary EU regulations with different focuses: CRA (Cyber Resilience Act) focuses on PRODUCT security—ensuring hardware and software products sold in the EU are secure by design. NIS2 (Network and Information Security Directive 2) focuses on ORGANIZATIONAL security—requiring essential and important entities to implement cybersecurity measures and report incidents. A company might need to comply with both: NIS2 for their organizational security practices, and CRA for any products they manufacture and sell. CRA has specific technical requirements (SBOM, vulnerability handling), while NIS2 focuses on governance, risk management, and incident reporting.

How do I check if CRA applies to my product?

To check if CRA applies to your product, ask these questions: 1) Do you sell or make your product available in the EU market? 2) Is your product software or hardware that processes data or connects to networks? 3) Are you the manufacturer (creator/seller) of the product? If you answered YES to all three, CRA likely applies. The free CRA Compliance Toolkit at cra-toolkit.com provides a 5-minute assessment that determines exactly which of the 22 CRA requirements apply to your specific product type, saving you hours of research through the 200+ page regulation.

What are the CRA penalties for non-compliance?

CRA penalties can be severe: up to €15 million or 2.5% of global annual turnover (whichever is higher) for violations of essential cybersecurity requirements. For less severe infringements, fines can reach €10 million or 2% of turnover. Providing misleading information to authorities can result in fines up to €5 million or 1% of turnover. Additionally, non-compliant products can be withdrawn from the EU market entirely, resulting in significant revenue loss beyond the fine itself.

What is a Software Bill of Materials (SBOM) and how do I create one for CRA?

A Software Bill of Materials (SBOM) is a comprehensive inventory of all software components, libraries, and dependencies in your product — like an ingredients list for software. CRA Article 10.5 requires manufacturers to create and maintain SBOMs. You can generate one for free using tools like CycloneDX CLI, Syft, or Trivy. The SBOM should include component names, versions, suppliers, and known vulnerabilities. Integrate SBOM generation into your CI/CD pipeline for automatic updates. The free CRA Compliance Toolkit at cra-toolkit.com/cra-sbom-requirements provides detailed guidance.

Does the CRA apply to open-source software?

It depends. Non-commercial open-source software developed by individuals or non-profit foundations is generally exempt from CRA. However, commercial entities that use, integrate, or distribute open-source software in their products remain fully liable under CRA for those products. Additionally, the CRA introduces a new category called open-source software stewards (Article 24) — organizations that systematically support open-source projects used commercially. Stewards have reduced obligations focused on cybersecurity policies and cooperation with authorities, but they are not exempt entirely. Learn more at cra-toolkit.com/cra-for-stewards.

How does CRA affect companies outside the EU?

The CRA has extraterritorial reach, similar to GDPR. If your company — regardless of where it is headquartered (US, UK, India, etc.) — sells or makes available products with digital elements to customers in the EU market, you must comply with CRA requirements. This applies whether you sell directly or through distributors, resellers, or app stores. Companies outside the EU should designate an authorized representative within the EU and begin compliance preparations well before the December 2027 full enforcement deadline. Use the free assessment at cra-toolkit.com/does-cra-apply-to-me to check your obligations.

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CRA Requirements: Complete List Explained in Plain English

All 22 essential cybersecurity requirements from the Cyber Resilience Act Annex I, broken down into actionable engineering tasks.

Free CRA Readiness Assessment

Last updated: September 5, 2026

Understanding CRA Requirements (Annex I)

The CRA requirements are defined in Annex I of the Cyber Resilience Act and are divided into two parts:

Part I: Security Requirements

14 requirements covering how your product must be designed and built to be secure.

Secure by default
Access control
Data protection
Minimal attack surface

Part II: Vulnerability Handling

8 requirements covering how you must manage security vulnerabilities throughout the product lifecycle.

Vulnerability identification
Disclosure process
Patching and updates
SBOM maintenance

Want to explore each requirement in detail with implementation guidance?

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Part I: Security Requirements (Product Design)

These requirements apply to how your product is designed, developed, and configured:

Risk-Based Security Design

Products with digital elements shall be designed, developed, and produced to ensure an appropriate level of cybersecurity based on the risks (Annex I Part I, point 1).

Example: Threat modeling during design, documented cybersecurity risk assessment driving security decisions.

No Known Exploitable Vulnerabilities

Products must be made available on the market without known exploitable vulnerabilities.

Example: CVE/vulnerability scanning and remediation before release.

Secure by Default

Products must be designed and manufactured with appropriate security by default, not requiring user configuration to be secure.

Example: No universal default passwords. Minimal open ports. Encryption enabled by default.

Protection Against Unauthorized Access

Products must protect against unauthorized access through appropriate mechanisms like authentication and access control.

Example: Multi-factor authentication, role-based access control, session management.

Data Confidentiality

Products must protect the confidentiality of stored, transmitted, and processed data using encryption or other appropriate means.

Example: TLS for data in transit, AES encryption for data at rest.

Data Integrity

Products must protect the integrity of data against unauthorized manipulation or alteration.

Example: Digital signatures, checksums, tamper detection mechanisms.

Data Minimization

Products must only process data that is adequate and relevant for the intended purpose.

Example: Collect only necessary user data, implement data retention limits.

Availability Protection

Products must ensure essential functions remain available, including resilience against DoS attacks.

Example: Rate limiting, graceful degradation, offline capability.

Minimize Negative Impact

Products must be designed to minimize negative impact on other devices and networks.

Example: Network isolation, controlled resource usage, no unwanted network scanning.

Reduce Attack Surfaces

Products must reduce attack surfaces including external interfaces to a minimum.

Example: Disable unused features, minimize open ports, remove debug interfaces.

Incident Impact Mitigation

Products must include mechanisms to reduce the impact of security incidents.

Example: Sandboxing, process isolation, automatic recovery.

Security Information Recording

Products must record/log security-relevant events and make information accessible to users.

Example: Audit logs, login attempts, configuration changes.

Secure Updates

Products must support secure update mechanisms to address vulnerabilities in a timely manner.

Example: Signed updates, automatic update checks, rollback capability.

Secure Data Removal

Products must let users securely and permanently remove all data and settings, and any data transferred to another product or system must be transferred securely.

Example: Secure/permanent wipe on factory reset, secure export when migrating data to another product.

Part II: Vulnerability Handling Requirements

These requirements govern how manufacturers must handle security vulnerabilities:

Identify and Document Vulnerabilities

Manufacturers must identify and document vulnerabilities in their products, including through third-party components.

Address Vulnerabilities Without Delay

Once identified, vulnerabilities must be addressed and remediated promptly.

Apply Effective Testing

Regular security testing must be performed throughout the product lifecycle.

Disclose Patch Information

Information about fixed vulnerabilities must be publicly disclosed after the update is available.

Implement Coordinated Disclosure Policy

A vulnerability disclosure policy must be in place for receiving reports from security researchers.

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Share Vulnerability Information

Share information about vulnerabilities to help other operators and ENISA.

Distribute Security Updates

Security updates must be made available free of charge and distributed securely.

Provide SBOM

A machine-readable Software Bill of Materials must be compiled and maintained.

SBOM Guide →

Which Requirements Apply to Your Product?

The toolkit evaluates all 22 CRA requirements, but applicability and implementation rigor vary based on your product classification:

Standard

Basic implementation. Self-assessment allowed. Most consumer electronics and general software.

Important I

Enhanced requirements. Third-party assessment required — no harmonised CRA standards as of 2026 (Article 32). Identity management, VPNs, etc.

Important II

Stricter oversight. Third-party assessment required. Hypervisors, firewalls, secure elements.

Critical

Highest assurance. EU cybersecurity certification mandatory. Smart cards, HSMs.

Explore Requirements in Detail

Use our interactive Requirements Explorer to see implementation guidance, evidence needed, and track your compliance progress for each requirement.

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