The EU Cyber Resilience Act: Building a Secure Internet of Things and Software Ecosystem

Introduction: Europe Responds to the Security Crisis in Connected Devices

Europe is facing a new cybersecurity reality. As billions of devices—from smart thermostats to industrial machinery—connect to the internet, vulnerabilities in software and hardware have become a systemic threat. A single insecure camera, router, or open-source component can compromise entire networks.

Recognizing this, the EU has adopted the Cyber Resilience Act (CRA)—a groundbreaking regulation that establishes mandatory cybersecurity requirements for all products with digital elements sold in the EU. Entering into effect progressively from 2025 onward, the CRA aims to make secure-by-design not just best practice but law.

The CRA represents a major shift: cybersecurity is no longer a voluntary market feature—it is a legal obligation for manufacturers, importers, and distributors.

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1. What Is the Cyber Resilience Act? A New Horizontal Security Law

The CRA is a horizontal regulation covering almost everything that has software:

Consumer IoT devices (smart speakers, toys, wearables),

Industrial control systems and sensors,

Software products, apps, and operating systems,

Hardware with programmable components,

Open-source software in commercial products.

Its purpose is simple but ambitious:

Ensure that every connected product on the EU market meets basic cybersecurity standards throughout its entire lifecycle.

The CRA works alongside:

NIS2 Directive (sector-level cybersecurity),

Product Liability Directive (compensation for damage),

AI Act (high-risk AI systems).

Together, they form a comprehensive digital security regime.

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2. Core Obligations Under the CRA

The CRA introduces obligations across the entire product lifecycle — from design to updates.

A. Cybersecurity-by-Design Requirements

Manufacturers must:

Use secure default configurations,

Implement robust access controls,

Ensure secure software development practices,

Minimize attack surfaces and known vulnerabilities,

Provide strong encryption for sensitive data.

B. Vulnerability Management and Patch Obligations

For the first time in EU law, manufacturers are legally required to:

Maintain a coordinated vulnerability disclosure (CVD) process,

Monitor vulnerabilities continuously,

Issue security patches for at least five years (or expected product lifespan),

Notify ENISA of actively exploited vulnerabilities within 24 hours.

C. Transparency Requirements

Manufacturers must:

Provide users with a Software Bill of Materials (SBOM),

Clearly disclose security support periods,

Include instructions for safe configuration and updates.

D. Mandatory CE Marking for Cybersecurity

Products must undergo:

Self-assessment for low-risk items,

Notified Body assessment for high-risk items (e.g. identity systems, password managers),

Cybersecurity compliance becomes part of the CE marking framework.

This transforms cybersecurity into a market access requirement.

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3. Who Is Affected? Manufacturers, Importers, Distributors — and Open Source

A. Manufacturers

Carry the heaviest obligations: design security, vulnerability handling, compliance documentation.

B. Importers and Distributors

Must verify that products carry proper CE marking and documentation before placing them on the EU market.

C. Software Developers

Standalone software is covered—meaning developers must follow secure coding and update obligations.

D. Open Source Software

Non-commercial open source is exempt, but once incorporated into a commercial product, manufacturers must ensure:

security testing,

vulnerability patching,

SBOM documentation.

This distinction was added after strong pushback from the OSS community.

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4. Enforcement and Penalties

The CRA gives authorities significant enforcement powers:

Market surveillance authorities can require withdrawal or recall of insecure products,

ENISA coordinates vulnerability alerts and systemic risk assessments.

Penalties

Up to €15 million or 2.5% of global annual turnover for the most serious violations (e.g., failing basic cybersecurity requirements),

Up to €10 million or 2% for documentation failures.

This puts cybersecurity on par with GDPR in terms of legal seriousness.

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5. What Companies Must Do Now: A Compliance Roadmap

Step 1: Map All Products and Software

Identify which products fall under CRA scope (almost all digital products).

Step 2: Conduct a Cybersecurity Risk Assessment

Evaluate design vulnerabilities, supply-chain risks, and embedded components.

Step 3: Implement Secure Software Development Lifecycle (SSDLC)

Align with ISO 27001, ENISA guidelines, and OWASP standards.

Step 4: Build a Vulnerability Management System

Establish:

internal response teams,

coordinated disclosure policies,

patch management processes.

Step 5: Prepare Technical Documentation

Required for CE marking and audits:

Security architecture descriptions,

SBOM,

Lifespan support plan,

Test reports.

Step 6: Train Staff and Update Supply Contracts

Cybersecurity obligations cascade through the supply chain.

The CRA will require significant investment, especially for SMEs and hardware manufacturers—but it will also raise security baselines across the entire EU economy.

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6. Broader Impact: How the CRA Reshapes Global Cybersecurity

The CRA is expected to have global ripple effects, much like the GDPR:

Manufacturers worldwide may design products to CRA standards to access the EU market.

U.S. and Asian regulators are watching the model closely.

Cybersecurity will become a competitive differentiator, not just a compliance burden.

Supply-chain security will be elevated through mandatory SBOM disclosures.

The Act also positions the EU as a global leader in securing consumer and industrial technology.

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Conclusion: A New Era of Secure Digital Infrastructure

The Cyber Resilience Act marks a fundamental shift in how digital products are regulated. By combining mandatory cybersecurity, continuous updates, and market oversight, the EU is aiming to eliminate the weakest link problem that plagues the internet ecosystem.

In the coming years, the CRA will:

Raise consumer safety standards,

Strengthen industrial resilience,

Increase trust in IoT and software products,

Align Europe’s digital transformation with strong security principles.

As AI, IoT, and cloud technologies continue to proliferate, the CRA ensures one thing remains constant: security cannot be optional.