If you ship software into the EU, EU Cyber Resilience Act compliance is about to feel less like paperwork and more like product work. The CRA pushes security into daily engineering, from design reviews to patch releases and incident reporting.
In February 2026, the key point is timing. Full CRA product compliance comes later, but incident and vulnerability reporting obligations start earlier. Teams that wait for 2027 will end up scrambling, because evidence and tooling take time to build.
Disclaimer: This article shares engineering-focused implementation guidance, not legal advice. Confirm scope and obligations for your products with qualified counsel and your conformity assessment plan.
What the CRA changes in 2026 (and why software teams should care now)
The CRA covers “products with digital elements”, which includes many types of software and software-enabled devices placed on the EU market. If your product connects to networks, processes data, or relies on third-party components, expect the CRA to touch your SDLC.
Two dates matter for planning:
- 11 September 2026: reporting kicks in for actively exploited vulnerabilities and certain serious incidents, with tight timelines (an early alert within 24 hours, a fuller report within 72 hours, and a follow-up within 14 days, as described in current CRA reporting summaries available as of February 2026).
- 11 December 2027: full CRA requirements apply for products placed on the EU market, including conformity assessment and CE marking expectations.
Even if you mainly sell SaaS, don’t assume you’re out. Pure cloud services are often treated differently, but many “SaaS” offerings ship agents, desktop clients, mobile apps, gateways, plug-ins, containers, or embedded components. Those deliverables can pull you into CRA scope.
A helpful mental model is a nutrition label. The CRA expects you to know what’s inside your product (SBOM), how it can fail (risk assessment and threat model), and how you’ll fix it (secure update mechanism and vulnerability handling).
If you can’t answer “what version is deployed where, and what CVEs affect it?” within minutes, you’ll struggle with CRA reporting and patch expectations.
Plan for governance too. Your product may fall into different assurance paths (self-assessment for many products, third-party involvement for higher-risk categories). Either way, evidence wins. You’ll need repeatable documentation, not heroics during an audit.
EU Cyber Resilience Act compliance checklist (obligations, owners, evidence)
Start by turning the CRA into work items with clear ownership. The table below maps common CRA-style obligations to actions your team can execute and prove.
| Obligation area | What to implement (practical actions) | Typical owner | Evidence to retain |
|---|---|---|---|
| Product scope and classification | Decide which deliverables are in scope (apps, agents, firmware), define support period, map target EU markets | Product + Security | Scope memo, product inventory, support lifecycle statement |
| Secure-by-design requirements | Secure defaults, least privilege, hardening guides, secure configuration baselines | Engineering + Security | Secure design notes, configuration baseline, security requirements in backlog |
| Risk assessment and threat modeling | Maintain a threat model per major feature, track risks and mitigations | Security + Engineering | Threat model, risk register, architecture diagrams |
| Vulnerability management | Intake, triage, fix, verify, and communicate, set SLAs tied to severity and exploit status | Security + DevSecOps | Vulnerability workflow, ticket history, patch timelines, verification results |
| SBOM and component control | Generate SBOM per release, track direct and transitive deps, monitor for new CVEs | DevSecOps | SBOM files, dependency manifests, CVE monitoring logs |
| Security testing | Add security test planning, run SAST/DAST where relevant, fuzzing for parsers, review auth flows | QA + Security | Security test plan, scan reports, pen test summaries (as applicable) |
| Secure update mechanism | Signed updates, rollback protection, update transparency, clear user guidance | Platform/Release | Update design doc, signing key management, release notes templates |
| Incident reporting readiness | Define what counts as reportable, build an on-call path, rehearse reporting timelines | Security + SRE | Incident runbook, report templates, exercise records |
| Supplier and open-source risk | Assess critical suppliers, set security requirements, monitor supplier advisories | Procurement + Security | Supplier questionnaires, contract clauses summary, supplier risk register |
| Technical documentation and audit readiness | Keep docs current per release, tie evidence to versions and SKUs | Compliance/QA + Eng | Documentation index, versioned evidence packs, change logs |
A “minimal but real” artifact set that works well for audits and for engineers:
- SBOM per build or per release, plus a way to map it to deployments.
- Threat model for core workflows (auth, updates, remote access, data handling).
- Risk assessment with severity, owner, and due dates.
- Security test plan tied to release gates.
- Secure update mechanism description (signing, rollout, rollback, comms).
- Incident reporting runbook with timelines aligned to September 2026 reporting.
Keep these versioned. Evidence that floats around in wikis without release tags won’t help when someone asks, “Was this true for v3.9.2?”
Engineering implementation tips for CI/CD and post-market monitoring
Most teams meet CRA expectations by treating security like quality. Put checks where mistakes happen, then keep receipts.
CI/CD controls that reduce CRA risk
You don’t need a complex pipeline to make progress, but you do need consistency.
- SAST and secrets scanning on every pull request, with developer-friendly feedback.
- Dependency scanning (SCA) tied to the SBOM, with alerts when new CVEs land.
- DAST for web apps and APIs in a staging environment, plus basic auth and session checks.
- Build signing and release signing, with protected keys and auditable access.
- Provenance and traceability, so you can show what source produced what artifact.
- Release gates that block shipment when high-severity issues are open, unless there’s a documented exception.
A simple pattern works: fail fast on new critical issues, warn on lower ones, and require explicit sign-off for exceptions. That sign-off becomes part of your CRA evidence trail.
For secure development practices, many teams map controls to recognized standards, then tailor them. Common references include ISO/IEC 27001 (security management), ISO/IEC 27034 (application security), IEC 62443 (industrial and embedded security), and ETSI EN 303 645 (consumer IoT baseline). Use them as checklists and vocabulary, then document what you adopted.
Post-market monitoring, disclosure, and reporting readiness
CRA doesn’t stop at release day. You need a way to detect issues, accept reports, and ship fixes.
Operationally, focus on three flows:
- Telemetry and logs that support detection (crash spikes, auth anomalies, update failures), while respecting privacy rules and your own data minimization goals.
- Vulnerability intake (email alias or portal), triage SLAs, and a coordinated disclosure process.
- Patch delivery with safe rollout (canary, staged deployment), plus rollback plans.
The policy layer below keeps those flows predictable.
| Recommended policy | What it should cover | Owner | Evidence |
|---|---|---|---|
| Vulnerability disclosure (CVD) | Intake channel, triage steps, researcher comms, disclosure timelines | Security | Public policy page, internal SOP, triage logs |
| Patching and security updates | Severity-based SLAs, exploit handling, backport rules, EoL approach | Engineering + Product | Patch SLA doc, release notes, support lifecycle |
| Secure coding standard | Approved patterns, banned functions, auth and crypto rules, code review expectations | Engineering | Coding standard, training records, review checklists |
| Supplier risk policy | Supplier tiers, required attestations, SBOM requests, ongoing monitoring | Procurement + Security | Supplier register, assessments, contract requirements summary |
By September 2026, teams should be able to answer two questions quickly: “Is it exploited?” and “Who do we notify, and when?” That readiness usually takes a few rehearsal drills, not just a document.
Conclusion
EU Cyber Resilience Act compliance is easiest when it looks like normal engineering: clear owners, repeatable checks, and versioned evidence. Start in 2026 by tightening vulnerability intake and incident reporting timelines, because those arrive before full enforcement. Then use CI/CD gates, SBOMs, and secure update design to make compliance part of every release. The best time to build your evidence pack is when the work happens, not when someone asks for it.
