EU Cyber Resilience Act (CRA)
The CRA mandates security-by-design, continuous vulnerability management, and SBOM transparency for any “Product with Digital Elements” including embedded software, device firmware, and companion apps. CRA compliance is now tied to CE-marking and required for EU market access.
Key Impacts on Manufacturers
- Maintain machine-readable, updated SBOMs for every release
- Continuously track vulnerabilities in all OSS/third-party components
- Operate a vulnerability disclosure process and report severe issues to ENISA
- Provide secure update mechanisms (separate from feature updates)
- Maintain security documentation for up to 10 years
Timeline
- Sep 2026 : Mandatory reporting to ENISA
- Dec 11, 2027 : Full enforcement (SBOMs, secure updates, conformity evidence)
Penalties
Up to €15M or 2.5% of global turnover, plus potential loss of EU market access.
What you can do now?
- Automate SBOM generation & lifecycle management
- Strengthen vulnerability/dependency management
- Modernize secure development processes (shift-left checks, CI/CD controls, formal disclosure workflows)
Read – How Black Duck Simplifies CRA Compliance!
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