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You can’t determine whether a software product is ready for the Cyber Resilience Act (CRA) without first assessing the product’s scope, intended purpose, and category. Readiness means being able to demonstrate the applicable security properties, vulnerability-handling processes, documentation, support commitments, reporting capability, and conformity steps—not simply planning to add a CE mark before the main application date. The CRA is Regulation (EU) 2024/2847, and its reporting duties for actively exploited vulnerabilities and severe incidents already apply.
Start with scope and product classification
The CRA establishes cybersecurity requirements for products with digital elements made available on the EU market. A product described only as “software” cannot be classified from that label alone. Assess the product’s intended purpose, connectivity, product boundary, and the economic operator’s role; then check the regulation’s Article 2 for exclusions and interactions with other EU product legislation. The regulation excludes specified areas, including certain medical devices, motor vehicles, aviation products, marine equipment, and products exclusively developed or modified for national security or defence purposes. These exclusions are specific, so do not assume they apply merely because a product is used in one of those sectors. Read Regulation (EU) 2024/2847.
Next, determine whether the product’s core functionality falls into an important or critical category listed in the CRA annexes. Category can affect the conformity-assessment route. The regulation’s requirements and assessment process must be considered for the particular product; a generic readiness checklist cannot establish that a specific product is in scope or compliant.
What does the Cyber Resilience Act require from software manufacturers?
The CRA combines product-security requirements with processes manufacturers must maintain while the product is supported. A useful readiness review tests both: whether the product is designed and configured securely, and whether the organization can identify, assess, communicate, and remediate vulnerabilities over time.
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Assess risk and design for security
Maintain a cybersecurity risk assessment for the product and use it to determine appropriate security measures. Check the product against the security properties in Annex I, including protection against known exploitable vulnerabilities, secure-by-default configuration, access control, and protection of data and integrity. Record how the assessment informs design decisions and how relevant risks are addressed.
Inventory components and maintain an SBOM
Identify and document the product’s components and vulnerabilities. Annex I calls for a software bill of materials (SBOM) in a commonly used, machine-readable format that covers at least the product’s top-level dependencies. A component inventory should be usable in the vulnerability process: establish how the team evaluates third-party components, including open-source components, and how it reports and remediates vulnerabilities found in components integrated into the product.
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Operate a vulnerability-handling process
Establish a coordinated vulnerability disclosure policy and a reachable contact for reporting vulnerabilities. The process should support regular security testing and review, prompt remediation, and secure distribution of security updates without delay. Where technically feasible, security updates should be separate from functionality updates. Keep evidence of the process and its operation, rather than treating a policy document alone as proof that vulnerabilities can be handled effectively.
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Set and communicate the support period
Set a support period that reflects the product’s expected use and reasonable user expectations. The period is generally at least five years; if the product is expected to be used for less time, the support period corresponds to that shorter expected use time. Document the rationale, make the support end date clear to users, and plan the resources and processes needed to provide required support and updates through that period.
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Prepare user information and technical documentation
Prepare clear instructions for secure installation, operation, updating, and decommissioning. Include the required manufacturer information and a way to contact the manufacturer about vulnerabilities. Maintain the technical documentation required by the regulation, including the cybersecurity risk assessment and the rationale for the support period. The documentation should reflect the product actually placed on the market and its maintained processes.
Determine the conformity route and maintain compliance
Identify the conformity-assessment procedure that applies to the product, taking its category and applicable rules into account. Where required, prepare an EU declaration of conformity and affix CE marking. Readiness also depends on production and change-management processes that can preserve conformity as the product changes and relevant standards or guidance develop. A CE-marking task at release cannot replace that ongoing capability.
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Reporting duties are already in effect
Since 11 September 2026, Article 14 reporting obligations concerning actively exploited vulnerabilities and severe incidents apply. Manufacturers should have an operational escalation path to assess whether an event is reportable, gather the required information, and carry out the reporting process. Check current Commission guidance and platform details as they evolve; do not assume that a future general application date postpones these reporting duties. EUR-Lex’s CRA summary also sets out the phased application timeline.
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Key Cyber Resilience Act dates
| Date | What applies |
|---|---|
| 20 November 2024 | Regulation (EU) 2024/2847 was published in the Official Journal. |
| 11 June 2026 | Provisions on notification of conformity-assessment bodies applied. |
| 11 September 2026 | Reporting duties concerning actively exploited vulnerabilities and severe incidents applied. |
| 11 December 2027 | The CRA’s main application date. |
These dates reflect the regulation’s phased application as of 13 October 2026. The main application date is not a reason to defer work on reporting duties that are already applicable.
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A practical readiness review
Use these checks to identify evidence gaps for a specific product. A “yes” should point to an owner, process, or record that can be demonstrated—not just an intention to address the item later.
- Scope: Is the product boundary, intended purpose, EU-market status, connectivity, operator role, and any possible exclusion documented?
- Category and route: Has the product’s core functionality been assessed against the CRA categories, and has the applicable conformity procedure been identified?
- Risk and design: Is there a current cybersecurity risk assessment linked to the product’s security properties and configuration?
- Components: Can the team identify components and vulnerabilities, produce a machine-readable SBOM covering at least top-level dependencies, and act on findings?
- Vulnerability response: Is there a disclosure policy and reachable contact, plus a practiced path for review, remediation, and secure update distribution?
- Support and information: Is the support-period rationale recorded, the end date communicated, and the user information prepared?
- Evidence and reporting: Are technical documentation, conformity evidence, change controls, and an escalation path for reportable events available to the responsible teams?
If an answer is no or cannot be evidenced, treat it as a readiness gap to assign and resolve. A product-specific conclusion requires details such as intended purpose, architecture and dependencies, category, risk assessment, update and vulnerability processes, support commitment, and existing conformity evidence.
What a readiness decision can—and cannot—tell you
A completed review can show whether the manufacturer has identified applicable obligations and can demonstrate the corresponding product and lifecycle controls. It cannot yield a reliable pass/fail conclusion from the words “software product” alone. Scope, category, conformity route, and evidence depend on the product and the manufacturer’s role. Recheck the regulation and applicable implementation materials as harmonized standards and Commission guidance develop.
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