Does the Cyber Resilience Act Apply to Operating Systems?
Learn if the EU CRA applies to Operating Systems, what the core compliance requirements are, and how to start preparing your engineering teams automatically.
Core Definition
Yes. The EU Cyber Resilience Act applies directly to Operating Systems as they fall under the definition of "products with digital elements." An OS vendor needs a coordinated vulnerability disclosure process spanning the kernel and every bundled first-party application, not just the kernel team. This means your software must meet mandatory cybersecurity requirements to be distributed in the EU market.
Key Compliance Steps for Operating Systems
- Determine Classification: Check if your Operating Systems falls under the default category or Class I/Class II, which dictate stricter conformity assessment paths.
- Perform Risk Assessment: Map out the attack surface for your software and document the mitigations for the "secure by design" requirement.
- Implement Vulnerability Reporting: Provide a 24-hour reporting mechanism to ENISA for actively exploited vulnerabilities.
- Generate an SBOM: Ensure all dependencies used in your Operating Systems are documented in a machine-readable Software Bill of Materials.
- Avoid the Common Pitfall: Long-term support commitments get made informally in blog posts instead of the documented support-period disclosure CRA expects.
How This Plays Out in Practice
An OS vendor needs a coordinated vulnerability disclosure process spanning the kernel and every bundled first-party application, not just the kernel team.
What to Watch For
Long-term support commitments get made informally in blog posts instead of the documented support-period disclosure CRA expects.
Assess Your CRA Readiness
Evaluate your product's Cyber Resilience Act readiness using our interactive tool. Find exactly which of the 22 security requirements apply directly to Operating Systems.