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Start by establishing whether the CRA applies
The CRA is Regulation (EU) 2024/2847, which sets cybersecurity requirements for products with digital elements made available on the EU market. Do not assume that every software service or connected system is automatically covered. Define the product boundary, intended purpose, connectivity and the economic operator’s role, then assess the full scope and exclusions in the regulation, especially Article 2.
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The regulation excludes specified areas, including certain medical devices, motor vehicles, aviation products and marine equipment, as well as products exclusively developed or modified for national security or defence purposes. Other EU product legislation can also affect the analysis. Record why the product is in scope or why a particular exclusion applies; do not base that decision on the broad label “software product.”
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Classify the product before choosing a conformity route
If the product is in scope, determine whether its core functionality places it in an important or critical product category under the CRA annexes. That classification affects the conformity-assessment procedure. A generic description of the product is not enough to establish its category or route.
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Check the product’s security properties and component controls
Article 6 opens: “Products with digital elements shall be made available on the market only where:”. It then ties market access to two conditions: the product meets the essential cybersecurity requirements in Annex I, Part I, and the manufacturer’s processes meet the requirements in Annex I, Part II. In other words, security features in a release do not substitute for the manufacturer’s ongoing vulnerability-handling processes.
Risk assessment and secure design
Maintain a cybersecurity risk assessment and use it to set an appropriate security level for the product. Assess the applicable Annex I properties, including protection against known exploitable vulnerabilities, secure-by-default configuration, access control, and protection of data and integrity. The relevant controls depend on the product and its risks; a checklist that is detached from the product’s intended use is not a substitute for the assessment.
Component inventory and SBOM
Identify and document the components in the product, along with vulnerabilities. The CRA 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. Establish risk-appropriate due diligence for third-party components and a process to report and remediate vulnerabilities found in integrated components, including open-source components.
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An SBOM is one part of the evidence, not proof by itself that the product is secure or compliant. Its value depends on whether it reflects the product you actually ship and supports vulnerability assessment and remediation.
Make vulnerability handling and updates operational
Vulnerability handling has to work throughout the product’s support period. Verify that the team can receive reports, assess issues, make fixes and deliver them to users—not merely that a policy exists on paper.
- Maintain a coordinated vulnerability disclosure policy and a reachable contact for vulnerability reports.
- Test and review product security regularly.
- Remediate vulnerabilities without delay.
- Distribute security updates securely and without delay. Where technically feasible, separate security updates from functionality updates.
For readiness, map each step from intake to release: who triages a report, how severity and impact are assessed, who approves a fix, how affected versions are identified, and how users receive the update. Keep records that demonstrate the process is being followed.
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Set a support period users can understand
Set the support period to reflect the product’s expected use and reasonable user expectations. It must be at least five years unless the product is expected to be used for a shorter time; in that case, the support period corresponds to that shorter expected use time. Document the rationale and make the support end date clear to users.
Connect that commitment to the people and processes needed to provide support and security updates for the stated period. A published end date is not enough if the organisation cannot maintain the vulnerability-handling and update capability behind it.
Prepare user information, technical documentation and conformity evidence
Give users clear instructions for secure installation, operation, updates and decommissioning, together with the required manufacturer and vulnerability-reporting contact information. Maintain technical documentation that includes the cybersecurity risk assessment and the rationale for the support period.
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Determine the conformity procedure from the product’s category and applicable rules. Where required, prepare the EU declaration of conformity and affix the CE marking. Keep production and change-management processes able to maintain conformity as the product changes and applicable standards evolve. The precise procedure cannot be determined without the product’s classification and circumstances.
Meet the reporting obligations already in force
Since 11 September 2026, the CRA’s Article 14 reporting obligations concerning actively exploited vulnerabilities and severe incidents apply. Your readiness plan should therefore include an escalation path to assess whether an event is reportable, collect the information needed, and carry out the reporting process. Check the current operational guidance and reporting-platform details, which can evolve; the obligation’s start date is not a reason to wait for the general application date.
Know which CRA dates matter
| 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 obligations for actively exploited vulnerabilities and severe incidents applied. |
| 11 December 2027 | The CRA’s main application date. |
The dates are set out in Regulation (EU) 2024/2847 and the EUR-Lex CRA summary. As of 13 October 2026, the Article 14 reporting obligations are already applicable; the general application date is still ahead.
Turn the checks into a readiness decision
Use a product-specific evidence review rather than an unsupported yes-or-no declaration. For each applicable obligation, record the accountable owner, evidence, unresolved gap and next action. Treat an unverified or missing item as an open gap, not as evidence of compliance.
- Define scope and role. Record the product boundary, intended purpose, EU-market availability, connectivity, economic-operator role, and any applicable exclusion or interaction with other EU product legislation.
- Record classification and route. Document the analysis of the product’s core functionality, its category under the CRA annexes, and the resulting conformity procedure.
- Review the engineering evidence. Check the risk assessment, applicable security properties, component inventory, SBOM and third-party-component vulnerability process against the product actually shipped.
- Exercise the lifecycle workflows. Verify that vulnerability intake, security review, remediation and secure update distribution have owners and can be carried out in practice.
- Check the user and compliance record. Review the support-period rationale and end date, user instructions, technical documentation, and the required conformity evidence for the product’s route.
- Test reporting escalation. Confirm that the relevant teams can identify and assess potentially reportable events and follow the current Article 14 reporting process.
A useful readiness record distinguishes obligations that are not applicable, obligations supported by current evidence, and unresolved gaps with an owner and completion plan. Do not mark the product ready until the scope and conformity decisions are documented and the applicable product and lifecycle obligations have supporting evidence.
What a product-specific verdict still depends on
A defensible assessment needs more than the product name. It depends on intended purpose, market and connectivity, the manufacturer/importer/distributor roles, core functionality and category, architecture and dependency inventory, risk assessment, vulnerability and update processes, support commitment, and existing conformity evidence. The regulation is binding, but implementation materials may develop as harmonised standards and Commission guidance evolve; recheck the applicable materials when making or updating a conformity decision.
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