Other frameworks
CRA: Cyber Resilience Act for products with digital elements
The Cyber Resilience Act (Regulation (EU) 2024/2847) sets essential cybersecurity requirements for manufacturers of products with digital elements sold in the EU, covering secure-by-default design, a documented vulnerability-handling process (including a software bill of materials), coordinated disclosure, and mandatory incident/vulnerability reporting. Two of its five tracked obligations are platform-managed today, both backed by real, continuous scans: secure-by-default cloud configuration, and software bill of materials generation. Both are explicitly partial checks, not full coverage of their article.
Transcript
The Cyber Resilience Act covers real product cybersecurity for hardware and software with digital elements, not just AI systems.
Enabling it adds five obligations to your list. Two are platform managed today: a clean cloud configuration scan, and automatic software bill of materials generation from a code scan.
The CRA Technical File pulls your real software bill of materials and vulnerability data straight from your own scans, not placeholder text.
Article six is checked against a clean cloud configuration scan, and your software bill of materials generates automatically from a code scan under article thirteen. The rest of article thirteen, article fourteen, and article thirty one still need your action: risk assessment, vulnerability reporting, and the technical documentation itself.
Generating the file is not the same as finishing article thirty one. You still need to review it and keep it updated for as long as you support the product.
Why this is required
Article 6 requires that products with digital elements meet the essential cybersecurity requirements in Annex I Part I only where properly installed, maintained and used as intended with necessary security updates, and that the manufacturer's own processes meet Annex I Part II.
Article 13 requires manufacturers to conduct and document a cybersecurity risk assessment, exercise due diligence on third-party and open-source components, and maintain a vulnerability-handling process including a software bill of materials for at least a 5-year support period.
Article 14 requires notifying any actively exploited vulnerability and any severe incident to the CSIRT designated as coordinator and ENISA within strict deadlines: 24-hour early warning, 72-hour notification, and a final report within 14 days (vulnerability) or one month (incident).
Article 31 requires technical documentation containing the elements set out in Annex VII, drawn up before the product is placed on the market and kept continuously updated during the support period.
What EuroCompliant does
Enabling CRA adds five obligations to your Obligations page. Article 6 (secure-by-default configuration) is platform-managed, evidenced by a clean CSPM scan of your cloud infrastructure, but that's a genuinely partial proxy: it covers cloud configuration only, not on-device or hardware security, or the full breadth of Annex I Part I. Article 13's software bill of materials requirement is also platform-managed, evidenced by a completed SBOM scan, again partial, since it confirms the SBOM exists but not the rest of Article 13's vulnerability-handling policy or coordinated disclosure process. The remaining obligations (the rest of Article 13, Article 14, Article 31) are tenant actions with specific, article-grounded guidance, not generic placeholders.
A CRA Technical File document type is available from the Documents section. It's generated on demand and pulls real per-company data: your software bill of materials from the Syft SBOM scan engine, and open/resolved vulnerability counts from Trivy scan findings. It's genuinely useful evidence to review and attach to your Article 31 documentation, but generating it doesn't automatically mark Article 31 complete, since the platform can't yet verify you actually reviewed and finalised it.
There's no automated check for Article 13's vulnerability-handling policy, coordinated disclosure process, or Article 14's reporting process today; all three need a real, documented process on your side.
Walking through it
Enable CRA
Adds all five obligations, including the two platform-managed checks.
Open /settings/profile?tab=frameworks →Generate and review the CRA Technical File
Pulls your real SBOM (Syft) and vulnerability (Trivy) scan data into one document, structured against Annex VII.
Open /compliance-docs →Document your vulnerability-handling and reporting process
Articles 13 and 14 need a real process on record: a support-period commitment, coordinated disclosure, and the 24h/72h/14-day reporting chain to your CSIRT and ENISA. Your SBOM is generated automatically once you run a code scan.
Open /obligations →The law
Requirements for products with digital elements
Products may only be made available where they meet Annex I Part I (properly installed, maintained and used as intended) and the manufacturer's processes meet Annex I Part II.
Obligations of manufacturers
Conduct and document a cybersecurity risk assessment, exercise due diligence on third-party/open-source components, and maintain vulnerability handling including an SBOM for at least a 5-year support period.
Reporting obligations of manufacturers
Notify actively exploited vulnerabilities and severe incidents to the CSIRT coordinator and ENISA: 24h early warning, 72h notification, 14-day/1-month final report.
Technical documentation
Technical documentation containing the elements in Annex VII, drawn up before market placement and kept continuously updated during the support period.
Penalties for non-compliance
Non-compliance with the essential cybersecurity requirements in Annex I or with Articles 13 and 14 carries fines of up to €15 million or 2.5% of total worldwide annual turnover, whichever is higher (Article 64(2)). A separate, lower tier of up to €10 million or 2% covers a longer list of other articles, and supplying incorrect or misleading information to authorities carries up to €5 million or 1% (Article 64(3)-(4)).
Frequently asked
Are we in scope for CRA?
If you develop, manufacture, or have manufactured products with digital elements (hardware or software, including remote data-processing components) that you place on the EU market and that have a data connection to a device or network, generally yes. Notable carve-outs exist for medical devices, vehicles, aviation-certified products, maritime equipment, and products developed exclusively for national security or defence.
How is this different from the EU AI Act's cybersecurity requirement (Article 15)?
They can both apply at once. Article 15 of the AI Act is one requirement among many for high-risk AI systems specifically. CRA is a dedicated, much more detailed cybersecurity regime covering essentially any connected product with digital elements, AI or not, including SBOM, coordinated vulnerability disclosure, and its own incident-reporting timeline separate from the AI Act's.
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