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Regulations

Cyber Resilience Act

Cyber Resilience Act (CRA) is an EU regulation establishing cybersecurity requirements for products with digital elements. CRA requires manufacturers to implement security by design, provide security updates, and report vulnerabilities throughout the product lifecycle.

What is Cyber Resilience Act?

Cyber Resilience Act Definition

Cyber Resilience Act (CRA) is a European Union regulation adopted in 2024 that introduces mandatory cybersecurity requirements for products with digital elements sold on the EU market. CRA aims to ensure that digital products - from smart home devices to business software - are designed and maintained with security in mind.

CRA Scope

Products covered:

  • Software (operating systems, applications)
  • IoT devices (cameras, sensors, smart home)
  • Computer hardware with firmware
  • Network devices (routers, firewalls)
  • Video games and mobile applications

Exclusions:

  • Medical devices (MDR)
  • Vehicles (UN R155)
  • Aviation
  • SaaS services (covered by NIS2)

Key CRA Requirements

Security by Design:

  • Security from the design phase
  • Secure default configurations
  • Attack surface minimization

Vulnerability Handling:

  • Vulnerability management process
  • Incident reporting to ENISA
  • Coordinated vulnerability disclosure

Security Updates:

  • Free updates throughout lifecycle
  • Minimum 5 years (or product lifetime)
  • Automatic or easy to apply

Documentation:

  • Secure usage instructions
  • SBOM (Software Bill of Materials)
  • Supported update information

Product Categories

Class I (lower risk):

  • Most consumer products
  • Self-assessment conformity
  • Example: smart TV, games

Class II (higher risk):

  • Security-critical products
  • Third-party assessment
  • Example: firewalls, ICS systems, HSM

Implementation Timeline

  • 2024: Regulation adoption
  • 2025: Vulnerability reporting obligations entry into force
  • 2027: Full requirements entry into force

CRA vs NIS2

AspectCRANIS2
What it regulatesProductsEntities/operators
Who it applies toManufacturers, importersEssential service providers
FocusProduct securityOrganizational security

CRA and NIS2 are complementary - CRA for products, NIS2 for operators.

Penalties and Enforcement

  • Non-compliance with requirements: Up to €15M or 2.5% of turnover
  • Failure to report vulnerabilities: Up to €10M or 2% of turnover
  • Product withdrawal from market for serious violations

Implications for Manufacturers

  • Processes: Security Development Lifecycle (SDL)
  • Teams: Dedicated PSIRT (Product Security Incident Response Team)
  • Tools: SBOM generation, vulnerability scanning
  • Documentation: Compliance declarations, instructions

Cyber Resilience Act is a groundbreaking regulation that will fundamentally change how digital products are designed and maintained in the EU.

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