The EU Cyber Resilience Act (CRA), adopted by the European Parliament in 2024, marks a major milestone in European cybersecurity legislation. As the first EU-wide law focused on the cybersecurity of digital products, it establishes mandatory requirements for manufacturers, importers, and distributors of Products with Digital Elements (PDEs). Its primary goal is to minimize vulnerabilities in both hardware and software and enhance security across the entire product lifecycle.

Organizations operating in the EU—or selling into the EU market—must now meet rigorous cybersecurity obligations, including post-market surveillance and third-party compliance oversight.

Key Highlights of the EU Cyber Resilience Act

Definitions

Product with Digital Elements (PDE): Any hardware or software product capable of processing data directly or indirectly.

Manufacturer: The entity responsible for designing or producing PDEs, even if production is outsourced.

Critical (Class I) & Non-Critical (Class II) Products: PDEs are classified under Annex III due to their importance to essential services or security.

Class I: Includes OSs, routers, VPNs, password managers

Class II: Includes firewalls, hypervisors, tamper-resistant chips

Scope and Applicability

The CRA applies to all PDEs placed on the EU market, regardless of where they originate. It encompasses:

  • Manufacturers (including software developers), importers, and distributors
  • Enterprises using third-party ICT products, who must ensure vendor compliance
  • Excludes open-source software developed outside of commercial activities

Principles and Obligations

Secure-by-design and default: PDEs must be designed to minimize vulnerabilities from inception.
Lifecycle cybersecurity: Organizations must address risks from development to end-of-life, including updates and patches.
Vulnerability reporting: Organizations must report exploited vulnerabilities and severe security incidents within 24–72 hours to ENISA.
Transparency obligations: Manufacturers must provide clear instructions for secure use and disclose known vulnerabilities to users.

Enforcement and Penalties

CRA compliance will be enforced by national market surveillance authorities across the EU. Non- compliance comes with significant consequences, including:

  • Fines of up to €15 million or 2.5% of global annual turnover, whichever is higher.
  • Potential withdrawal of non-compliant products from the EU market.

Exemptions include, micro and small enterprises are not fined for late vulnerability notifications and open-source stewards are exempt from financial penalties.

Key Enforcement Dates:

  • June 2026: Notification obligations for severe incidents and exploited vulnerabilities begin.
  • December 2027: Full compliance and enforcement deadline.

How Does CRA Compare to Other EU Regulations?

The EU Cyber Resilience Act (CRA) complements other regulatory frameworks such as NIS2, GDPR, and the EU AI Act by addressing product-level cybersecurity. In contrast, the others focus on operational security (NIS2), personal data protection (GDPR), and AI-specific risk management (EU AI Act).

While some overlap exists—particularly in incident reporting—the CRA uniquely addresses cybersecurity at the product level, closing regulatory gaps and working in tandem with sector-specific laws.

The CRA introduces both compliance obligations and market access challenges. It elevates the importance of supply chain transparency, robust vulnerability management, and security throughout the product lifecycle.

So, how can your organization get ahead of the core business functions most impacted by the CRA? Start with these seven practical tips.

7 Key Steps to Prepare for EU Cyber Resilience Act Compliance

Preparing for the EU Cyber Resilience Act doesn’t have to be overwhelming. By following these seven practical steps, your organization can take proactive and structured action toward achieving full compliance.

1. Review Your Product Portfolio

Start by identifying which of your products fall under the category of Products with Digital Elements (PDEs). Once you have a clear list, determine whether any are classified as “critical products” under the CRA. These products will require stricter controls and additional obligations, so it’s essential to flag them early.

2. Adopt Secure Development Practices

Build security into every stage of your product development lifecycle. Incorporate threat modeling, follow secure coding standards, and ensure thorough security testing. It’s also wise to align your processes with recognized frameworks such as ISO 27001 and NIST CSF to meet international best practices.

3. Improve Vulnerability Management Processes

Develop a comprehensive and well-documented process for identifying, disclosing, and mitigating vulnerabilities. Require your teams to follow Coordinated Vulnerability Disclosure (CVD) protocols. Prepare for rapid response by setting up internal escalation paths and ensuring your incident response plans allow you to notify regulators within 24 hours if needed.

Make it routine to document:

  • Root cause analysis
  • Remediation steps
  • Any impact on customers

Additionally, monitor your critical vendors to ensure their vulnerability handling meets your expectations.

4. Create and Maintain Detailed Technical Documentation

Documentation plays a central role in CRA compliance. Ensure that documentation outlines risk assessments, security measures, test results, and update processes. For each regulated product, keep clear records of:

  • Product descriptions, use instructions, software versioning
  • Cybersecurity risk assessments and vulnerability handling procedures
  • Evidence of conformity assessments
  • Software Bill of Materials (SBOMs)
  • Declaration of Conformity and CE marking

Be ready to share this information with authorities upon request. Keep these records on file for at least 10 years.

5. Conduct CRA Conformity Assessments

Determine whether your product requires a self-assessment or an independent third-party evaluation. Based on the outcome, apply the appropriate CE marking and complete the EU Declaration of Conformity to demonstrate your product meets CRA standards.

6. Strengthen Third-Party Risk Oversight

Evaluate the CRA compliance maturity of all your suppliers. Introduce CRA-specific checkpoints into your vendor onboarding and contract renewal processes. Update procurement contracts to include requirements for:

  • Security responsibilities
  • Disclosure obligations
  • Submission of SBOMs

Maintain visibility into your vendors’ product dependencies and assess potential business continuity risks if a vendor fails to comply with CRA.

7. Train and Educate Internal Teams

Make sure your teams understand what the CRA means for their roles. Provide targeted training to compliance, engineering, and procurement staff. Incorporate CRA awareness into product development, vendor onboarding, and incident response planning. Consider hosting cross-functional workshops to practice how your teams would respond to a security incident under CRA requirements.

Why the EU Cyber Resilience Act Demands Early Action

The Cyber Resilience Act represents a paradigm shift in how the EU approaches digital product security, embedding cybersecurity obligations at every stage—from product design to end-user deployment. It reinforces a shared responsibility model across the digital supply chain and empowers consumers with greater trust and control over the security of connected products.

Even if CRA compliance is not yet mandatory for your business, early alignment offers clear benefits:

  • Demonstrates a commitment to customer safety
  • Mitigates product liability risks
  • Enhances competitiveness in the EU
  • Boosts resilience against cyber threats

By embedding CRA-aligned security into product development and third-party risk programs, organizations can reduce exposure, enhance customer trust, and ensure uninterrupted access to EU markets.

Next Steps: Strengthen CRA Compliance with Mitratech

With steep penalties and stringent obligations, the EU Cyber Resilience Act is not a regulation you want to drag your feet on. As you prepare to comply with the EU Cyber Resilience Act (CRA), the right tools can simplify and accelerate your readiness journey.

Mitratech’s suite of GRC and risk management solutions support CRA-aligned operations by helping you:

  • Centralize and automate technical documentation management for audit readiness.
  • Implement consistent and repeatable vulnerability and incident response workflows.
  • Evaluate and monitor third-party risk using robust TPRM tools.
  • Conduct risk assessments and manage secure development with policy and control frameworks.
  • Deliver organization-wide training with integrated compliance awareness and tracking modules.

Ready to see how Mitratech can support your CRA compliance? Request a demo today and speak with a solutions expert.

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