Cyber Resilience Act: EU obligations for digital product security

Why the Cyber Resilience Act matters

The Cyber Resilience Act (CRA) is the first European regulation introducing legal cybersecurity obligations for digital products, including both hardware and software. Its goal is to make cybersecurity an integrated feature from the design phase and to ensure it throughout the product lifecycle.

Approved in October 2024 and entered into force in December 2024, the regulation will be fully applicable starting December 2027. It marks the shift from voluntary standards to binding requirements for placing products on the EU market.

What the CRA requires

According to the CRA, manufacturers must integrate cybersecurity measures during product development and maintain them during use. This includes vulnerability management, releasing security updates, and protecting user data.

For high-risk products, third-party conformity assessment may be required, while most other products will follow a self-assessment route. All manufacturers must provide technical documentation and clear user instructions.

Non-commercial open-source software is generally excluded, but all commercial products (smart devices, routers, business software, banking apps…) must comply.

Which products are covered

The CRA applies to any product with digital elements that can connect directly or indirectly to a network or another device. Examples include smart home devices, wearables, embedded software, and banking or health apps.

Products already regulated by specific EU sectoral legislation (such as medical devices, automotive, aerospace) are excluded to avoid regulatory overlap.

Risks of non-compliance

After the transition period, non-compliant products cannot be sold in the European Union. Fines may reach up to €15 million or 2.5% of global annual turnover, whichever is higher.

In addition to fines, there are risks related to reputational damage, mandatory recalls, or legal liability in the event of security incidents.

How to prepare

Preparing for the CRA requires a clear strategy. Companies should conduct cybersecurity audits on their digital products, apply security by design principles, and establish vulnerability management and secure update policies.

It is essential to prepare and maintain updated technical documentation, including items like the SBOM (Software Bill of Materials). Preparing in advance reduces costs and minimizes the risk of market disruptions.

How Abinsula can help

Abinsula is the ideal partner to guide your company through the process of complying with the Cyber Resilience Act. With our experience in software engineering, IoT, and embedded systems, we help businesses understand the regulation and define a tailored path toward compliance.

We offer personalized consulting that starts with an initial analysis and adapts to the specific needs of each client. Our approach is practical and result-driven, aiming to help companies meet CRA requirements effectively and sustainably.

Whether you need to evaluate an existing product or assess regulatory impacts on a new one, Abinsula stands by your side throughout the process, providing expertise and strategic vision.

The Cyber Resilience Act is a game-changer for anyone developing or selling connected digital products in Europe. It introduces new responsibilities, but also creates opportunities to stand out through security, reliability, and trust.

Contact us today for a free assessment and discover how we can help you comply with the Cyber Resilience Act.