Cyber Resilience Act: Critical Cybersecurity Requirements

The EU Cyber Resilience Act (CRA) entered into force on December 10, 2024, introducing mandatory cybersecurity requirements for manufacturers and retailers of products containing digital elements. For embedded developers, this regulation represents a fundamental shift in how connected devices must be designed, developed, and maintained throughout their lifecycle.

What is the Cyber Resilience Act?

The CRA aims to safeguard consumers and businesses buying software or hardware products with a digital component, addressing inadequate cybersecurity levels and lack of timely security updates in many products. The regulation applies to hardware and software products that are connected, directly or indirectly, to another device or network, including IoT devices, smart home products and embedded systems.

Timeline and Urgency

Critical Dates:

• December 11, 2027: Main obligations take effect (36 months after entry into force)
• September 11, 2026: Incident reporting requirements begin (21 months after entry into force)

The clock is ticking. Product manufacturers have less than three years to ensure their products comply with comprehensive cybersecurity requirements. Companies in scope are advised to begin preparing for the far-reaching legislative changes sooner rather than later.

Key Requirements for Embedded Products

Essential Cybersecurity Standards

Products must be designed to be free of known vulnerabilities, have secure settings and access controls, protect data confidentiality, integrity and availability, limit data processing and attack surfaces, mitigate exploitation risks, and provide security logs.

Mandatory Risk Assessment

Prior to placing products on the EU market, manufacturers must conduct a comprehensive cybersecurity risk assessment identifying and reducing risks, preventing security incidents, and protecting user health and safety throughout the product's lifecycle.

Vulnerability Reporting

Manufacturers must report any actively exploited vulnerability to ENISA within 24 hours of detection and inform affected users as soon as possible.

Long-term Support Commitment

Manufacturers must provide ongoing support and security updates for at least five years, with updates remaining available for download for at least 10 years.

Product Classification Impact

The CRA categorizes products into three risk levels:

Default Products (90% of devices): Smart toys, TVs, fridges, and similar consumer devices can self-assess compliance.

Important Products (Class I): Browsers, password managers, antiviruses, firewalls, VPNs must adhere to harmonized standards or undergo third-party assessment.

Critical Products and Important Products (Class II): General-purpose microprocessors and certain firewalls require mandatory third-party assessment before market placement.

Compliance Requirements

Documentation and Certification

Products meeting regulatory conformity assessment must affix a CE marking, with clear technical documentation and user instructions including security features and safe use guidelines.

Supply Chain Security

Manufacturers must ensure that components and software from third-party suppliers meet the CRA's cybersecurity requirements, including conducting due diligence and ongoing monitoring.

Data Retention

Companies must retain data inventory and documentation for 10 years after being put on market or the support period, whichever is longer

Penalties and Enforcement

Non-compliance may result in fines of up to €15 million or 2.5% of global annual turnover, whichever is higher. These penalties underscore the regulation's serious impact on embedded device manufacturers.

Immediate Actions for Embedded Developers

1. Assess Product Portfolio: Determine which products fall under CRA scope and their risk classification
2. Review Development Processes: Integrate security-by-design principles into your development lifecycle
3. Implement Vulnerability Management: Establish processes for rapid vulnerability detection and reporting
4. Plan Long-term Support: Budget for extended security update commitments
5. Evaluate Supply Chain: Audit third-party components and suppliers for CRA compliance
6. Document Security Measures: Prepare comprehensive technical documentation and risk assessments

Logic Technology's Support

The CRA represents both a challenge and an opportunity for embedded developers to build more secure, resilient products. At Logic Technology, we understand the complexity of implementing comprehensive cybersecurity measures while maintaining product performance and development efficiency.

Our embedded development tools and expertise help you navigate CRA requirements by:

• Integrating security testing into your development workflow
• Providing static analysis and vulnerability detection capabilities
• Supporting secure coding practices and standards compliance
• Enabling comprehensive documentation and traceability

Don't wait until 2027. Start preparing your embedded products for CRA compliance today. The regulation's comprehensive requirements demand immediate attention to avoid costly redesigns and potential market delays.

Ready to ensure CRA compliance? Contact Logic Technology to learn how our embedded development solutions can help you build secure, compliant products that meet the EU's new cybersecurity standards.