Does the Cyber Resilience Act Apply to Payment Gateways?
Learn if the EU CRA applies to Payment Gateways, 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 Payment Gateways as they fall under the definition of "products with digital elements." A payment gateway is squarely 'important' or 'critical' tier under CRA given its role in financial infrastructure, meaning third-party conformity assessment is very likely required. This means your software must meet mandatory cybersecurity requirements to be distributed in the EU market.
Key Compliance Steps for Payment Gateways
- Determine Classification: Check if your Payment Gateways 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 Payment Gateways are documented in a machine-readable Software Bill of Materials.
- Avoid the Common Pitfall: Relying entirely on PCI-DSS certification as a substitute for the CRA's own conformity assessment process — the two are not interchangeable.
How This Plays Out in Practice
A payment gateway is squarely 'important' or 'critical' tier under CRA given its role in financial infrastructure, meaning third-party conformity assessment is very likely required.
What to Watch For
Relying entirely on PCI-DSS certification as a substitute for the CRA's own conformity assessment process — the two are not interchangeable.
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 Payment Gateways.