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CHEN
02 · CYBER RESILIENCE ACT

EU CRA
Compliance and Testing

Build a compliance evidence chain around horizontal standards, product-specific vertical drafts, vulnerability reporting and secure development across the full product lifecycle.

ARTICLE 14 · APPLICATION DATEFrom 11 September 2026

The CRA vulnerability and serious incident reporting obligations start to apply. Manufacturers need a timed internal workflow for identification, triage, evidence collection, external reporting and user notification.

Key obligation

Vulnerability reporting is a timed process, not just an email

Reports mainly concern actively exploited vulnerabilities and serious incidents affecting product security, users or network services.

01Within 24 hours after awareness

Early warning

Submit basic facts, affected products or versions, known exploitation and initial mitigation.

02Within 72 hours after awareness

Detailed notification

Add vulnerability nature, severity, impact scope, indicators, measures taken and remediation plan.

03Within 14 days after fix availability

Final vulnerability report

Explain root cause, impact, exploitation, corrective measures, security update and user communication.

04Within one month after 72h notice

Final incident report

Provide investigation conclusion, handling process, impact assessment and measures to prevent recurrence.

READINESS CHECKLIST

Finish a tabletop exercise before 2026-09-11

  • 7×24 vulnerability and incident intake channel
  • PSIRT, R&D, legal, management and external contacts
  • Rules for active exploitation and serious incident triage
  • 24h, 72h and final report templates
  • Fast lookup for product, version, SBOM and customer impact
  • At least one tabletop and one practical response drill
Get Reporting Workflow Plan
Horizontal standards

prEN 40000 series: common compliance baseline

Horizontal standards help manufacturers build reusable requirement libraries, development processes and evidence templates for products with digital elements.

prEN 40000-1-1Concepts

Definitions and terminology

Unifies terms such as product, component, asset, vulnerability, risk, support period, security update and supply-chain role.

  • Clarify product boundary, data flow and responsibility matrix.
  • Map legal clauses to product functions and evidence.
  • Align vulnerability, incident, fix and mitigation definitions.
prEN 40000-1-2Principles

Cyber resilience principles

Translates risk-oriented, secure-by-design and secure-by-default principles into lifecycle practices.

  • Perform risk analysis based on intended and foreseeable use.
  • Embed least privilege, defense in depth and secure defaults.
  • Plan monitoring, update and end-of-support arrangements.
prEN 40000-1-3Vulnerability

Vulnerability handling requirements

Defines intake, validation, severity rating, fixing, coordinated disclosure and records as a basis for PSIRT and CRA reporting.

  • Set a unified vulnerability contact, SLA and owner.
  • Keep affected version, risk decision, patch and communication evidence.
  • Connect 24h, 72h and final CRA reporting milestones.
prEN 40000-1-4Controls

Common product security controls

Converts CRA Annex I requirements into testable controls around identity, access, confidentiality, integrity, logging, updates and resilience.

  • Decide applicability and non-applicability rationale for each control.
  • Define evidence for configuration, interfaces, updates and recovery.
  • Add product-specific scenarios through vertical standards.

Status note: Final references, clauses and harmonized status should always be locked to the latest official publications before project delivery.

Vertical standard drafts

EN 304 xxx: product-specific risk and evidence

Vertical drafts refine verification priorities for browsers, operating systems, routers, smart home products, wearables and other concrete categories.

Software and security toolsExamples
EN 304 617

Browsers

Web isolation, certificate validation, download protection, extension permissions, privacy data and automatic update.

EN 304 618

Password managers

Master key protection, credential encryption, autofill boundaries, synchronization, recovery and leakage risks.

EN 304 619

Anti-virus software

Engine integrity, signature updates, quarantine handling, trusted update and privileged execution risks.

EN 304 620

VPN software

Tunnel protocol, key management, authentication, traffic leakage, default configuration and client updates.

Platforms and network infrastructureExamples
EN 304 625

Network interfaces

Exposed services, protocol implementation, interface authorization, input handling and attack surface minimization.

EN 304 626

Operating systems

Privilege separation, secure boot, patching, logging, credential protection and secure defaults.

EN 304 627

Routers and switches

Management interface, segmentation, firmware update, initial credential, configuration backup and exposure risks.

EN 304 636

Firewalls

Default policy, rule integrity, administrator privileges, audit logging, updates and secure failure behavior.

Smart home and consumer productsExamples
EN 304 631

Smart home assistants

Voice and account data, wake-up control, third-party skills, linkage authorization and cloud communication.

EN 304 632

Smart home security products

Cameras, locks and alarms with remote access, account sharing, privacy protection and alert reliability.

EN 304 633

Connected toys and child-care devices

Children's data, guardian authorization, audio/video functions, location data, defaults and remote control.

EN 304 634

Wearables

Health and location data, mobile pairing, wireless interfaces, account security, cloud sync and loss scenarios.

Secure development lifecycle

Embed CRA requirements into product SDLC

Compliance should not be a last-minute document task. Each development stage should produce traceable security inputs, review gates and evidence.

01

Scope and roles

Identify product boundary, digital components, target markets, supply-chain roles and support period.

Output: applicability list and responsibility matrix
02

Risk and threat modeling

Map assets, data flow, trust boundaries, attacker capability, foreseeable misuse and lifecycle risks.

Output: threat model and risk treatment plan
03

Security requirements

Turn authentication, authorization, encryption, logging, updates and interface protection into verifiable requirements.

Output: requirements and architecture review
04

Secure coding and supply chain

Apply coding rules, code review, secret handling, dependency governance, supplier evidence and SBOM maintenance.

Output: code review, SBOM and supplier evidence
05

Security verification

Combine SAST, DAST, dependency scanning, fuzzing, interface testing, penetration testing and remediation retest.

Output: test plan, findings and retest report
06

Release evidence

Complete risk acceptance, secure-default check, technical documentation, user guidance and release approval.

Output: technical file and release sign-off
07

Monitoring and PSIRT

Collect vulnerability intelligence and feedback, complete triage, fixes, disclosure, reporting and user notification.

Output: reporting and communication records
08

Updates and support

Provide security updates during the support period and communicate end-of-support and secure retirement.

Output: update records and EOL plan

Need to turn CRA clauses into product tasks?

Share product type, architecture, software components, target markets and development stage for a tailored roadmap.

Get CRA Compliance Plan
Hotline400-661-8031