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Research: referenced in the ENISA SME CRA Survey 2026.

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Regulation (EU) 2024/2847

Cyber Resilience Act

The CRA is the first European regulation that establishes mandatory cybersecurity requirements for all products with digital elements (PDE) placed on the EU internal market — from smart home devices to industrial control systems.

Entry into force

Dec 2024

Full obligation

Dec 2027

Max. fine

€15M / 2.5%

Min. support

5 years

What is the CRA?

Scope

Applies to all manufacturers, importers, and distributors who place products with digital elements (hardware or software) on the EU market — regardless of where the company is headquartered worldwide.

Legal basis

Regulation (EU) 2024/2847. Unlike directives, a regulation applies directly and uniformly in all EU member states — no national transposition required.

Product definition (PDE)

Products with digital elements include all hardware and software with a network-capable component or data interface. From industrial SCADA systems to consumer apps.

Exceptions

Exemptions include medical devices (MDR/IVDR), vehicles (UNECE R155), aviation (EASA), and open-source software without commercial activity.

Implementation Timeline

✓ DoneAll actors
11 Dec 2024

Entry into force

Regulation (EU) 2024/2847 enters into force. The phased application clock starts.

✓ DoneNotified bodies
11 Jun 2026

Conformity assessment bodies (Chapter IV)

The rules on notifying authorities and notified bodies start to apply. This sets up who may certify products — it places no new obligation on manufacturers themselves.

✓ DoneManufacturers
11 Sep 2026

Article 14 reporting obligations

Manufacturers must report actively exploited vulnerabilities and severe incidents : early warning within 24h, notification within 72h, final report 14 days after a fix (vulnerabilities) or one month after the notification (incidents). This is the only manufacturer obligation that lands on this date — and it applies to all products already on the market, including legacy products.

○ PlannedManufacturers
11 Dec 2027

Full application

Everything else applies: Annex I essential requirements, conformity assessment, technical documentation, CE marking and the Declaration of Conformity. Non-compliant products may no longer be placed on the EU market.

Common misconception: On 11 September 2026, only the reporting obligation under Art. 14 becomes mandatory — and it applies to existing products already on the market. The remaining obligations (Annex I, conformity assessment, CE marking) only apply from 11 December 2027.

11 Sep 2026 — SRP reporting is live. The 24 h / 72 h / final-report filing cadence applies to every product with digital elements already on the EU market.

Regulation Chapter Structure

Art. 2Scope

Applies to all products with digital elements (PDE) placed on the EU market.

Art. 3Definitions

Manufacturers, importers, distributors, PDE, vulnerability, security update, support period.

Art. 6Classification

Divided into Default, Important Products (Class I & II) and Critical Products.

Art. 13Manufacturer obligations

Conformity assessment, technical documentation, EU Declaration of Conformity, CE marking, support period (min. 5 years).

Art. 14Reporting obligations

Actively exploited vulnerabilities and serious incidents must be reported to ENISA and CSIRT within 24h.

Art. 15Importer obligations

Importers ensure that only compliant products are placed on the market.

Art. 16Distributor obligations

Distributors verify CE marking and cooperate on corrective measures.

Art. 27Presumption of conformity

Products complying with harmonised standards are presumed to conform.

Art. 32Conformity assessment

Default: Self-assessment. Class I: Notified Body or harmonised standard. Class II: Notified Body mandatory.

Art. 37EU Declaration of Conformity

Formal document per Annex V confirming conformity with the CRA.

Art. 40CE marking

Must be clearly visible, legible and permanently affixed (Annex VI).

Art. 41Market surveillance authorities

Member states designate competent authorities with inspection and intervention powers.

Art. 64Penalties

Fines up to €15 million or 2.5% of worldwide annual turnover — whichever is higher.

Annex I: Technical Requirements

ANNEX I.1.1No known vulnerabilities

Products must not have exploitable security vulnerabilities when placed on the market. Evidence through vulnerability scan before release.

ANNEX I.1.2Secure by Default

Shipped with secure default configurations. No default passwords. Unnecessary services and ports disabled.

ANNEX I.1.3Access control

Authentication and authorisation mechanisms. MFA where appropriate. Session management. Protection against unauthorised access.

ANNEX I.1.4Data confidentiality

Protection of sensitive data in transit (TLS 1.2+) and at rest (AES-256). No unnecessary data storage.

ANNEX I.1.5Data integrity

Protection of data and command integrity. Input validation, checksums, digital signatures.

ANNEX I.1.6Data minimisation

Processing only data necessary for the intended purpose. GDPR data minimisation principle.

ANNEX I.1.7Availability / DoS protection

Limiting the impact of denial-of-service attacks. Rate limiting, resource quotas, graceful degradation.

ANNEX I.1.8Minimise attack surface

Limiting external interfaces to what is necessary. Least-privilege principle. Removal of unused components.

ANNEX I.1.9Limit incident impact

Design for resilience: logging, alerting, isolation mechanisms. Fail-safe behaviour during security incidents.

ANNEX I.1.10Security update mechanism

Secure mechanism for software updates (e.g. signed OTA updates). Documented update channels. Rollback capability.

ANNEX I.1.11Secure communication

Use of secure, current communication protocols. Prohibition of deprecated protocols (TLS 1.0/1.1, SSLv3).

ANNEX I.1.12Software integrity

Verification of software component integrity. Software signing, verification at startup. SBOM for all components.

ANNEX I.2.1Vulnerability identification

Recording and documentation of all vulnerabilities and components. Current SBOM. CVE feed monitoring for all third-party dependencies.

ANNEX I.2.2CVD policy

Publicly accessible Coordinated Vulnerability Disclosure policy. security.txt on website. ENISA registration if required.

ANNEX I.2.3Timely remediation

SLAs for patches: Critical (24–72h), High (7 days), Medium (30 days). Documented and communicated process.

ANNEX I.2.4Regular security testing

Periodic SAST, DAST and penetration tests. Documented results and remediation actions.

ANNEX I.2.5SBOM availability

Machine-readable SBOM (CycloneDX or SPDX) available to authorities on request. Updated with every release.

The CRA Requirement Library in this system contains all 28 requirements with guidance and compliance status. Go to requirement library →

Product Classification

DefaultAssessment

Self-assessment

Examples

Smart home devices, simple IoT sensors, consumer software

Requirements

  • All Annex I requirements
  • Technical documentation (Annex VII)
  • EU Declaration of Conformity
  • CE marking
Class IAssessment

Third-party assessment or harmonised standard

Examples

Browsers, password managers, SIEM systems, firewalls, VPN software

Requirements

  • All Default requirements
  • Notified Body OR harmonised standard
  • Extended technical documentation
Class IIAssessment

Mandatory: Notified Body

Examples

Industrial control systems (SCADA), operating systems, chips with security function, industrial routers

Requirements

  • All Class I requirements
  • Notified Body mandatory
  • Full quality management system (ISO 9001)

Complete Annex Overview

AnnexTitle
Annex IEssential Cybersecurity Requirements
Annex IIUser Information
Annex IIIImportant Products (Class I & II)
Annex IVCritical Products
Annex VEU Declaration of Conformity
Annex VICE Marking
Annex VIITechnical Documentation
Annex VIIIAssessment procedures

Annex VII — Technical Documentation in Detail

ANNEX VII.1General product description

Purpose, main functions, target audience, intended operating environment.

ANNEX VII.2Design & development

Architecture diagrams, security-relevant design decisions, threat models.

ANNEX VII.3Security risk analysis

Full cybersecurity risk analysis (e.g. STRIDE, PASTA) for the product.

ANNEX VII.4Test results

Test plans, scan results (SAST/DAST/pen test), remediation evidence.

Next Steps for Manufacturers

01

Determine product class

Check for each product whether it qualifies as Default, Class I or Class II. Annex III and IV of the CRA provide the categories.

Manage products
02

Perform gap analysis

Assess the status of all 28 CRA requirements for each product. Identify gaps in documentation, processes and technology.

Go to requirement library
03

Create org-level policies

SDL, CVD policy, incident response process — these requirements are fulfilled once at company level and inherited by all products.

Go to policy library
04

Technical documentation

Create per product: general description, architecture, risk analysis (STRIDE), SBOM and test results per Annex VII.

Open dossiers
05

Set up reporting process

Mandatory from Sep 2026: process for 24h reporting of actively exploited vulnerabilities to ENISA and national CSIRT.

Incident response policy
06

EOL planning & support

CRA requires at least 5 years of support. Plan EOL dates for all products and ensure security updates can be provided.

Lifecycle management

Other regimes that run alongside the CRA

The CRA regulates products with digital elements and their manufacturers. NIS2 (Directive (EU) 2022/2555) and DORA (Regulation (EU) 2022/2554) are parallel regimes for the organisations that operate such products: NIS2 for essential and important entities, DORA for financial entities. They do not replace your CRA obligations, but customers in those sectors may ask for your CRA evidence to support their own supply-chain risk management.

Official Regulation

Regulation (EU) 2024/2847 in the EU Official Journal

Open EUR-Lex

© 2026 CRA Compliance Studio. Not legal advice. Always consult qualified counsel.