Last verified: 2026-07-03

• references/essential-requirements.md

  — Annex I essential requirements, product categories, support period, SBOM, vulnerability handling, reporting obligations

• references/conformity-assessment.md

  — conformity assessment routes by product class, CE marking process, DoC, notified bodies, market surveillance, penalties

• IoT devices (smart home, industrial sensors, wearables)
• Network equipment (routers, switches, firewalls, modems)
• Software products (operating systems, applications, games — including commercial off-the-shelf software)
• Mobile applications, cloud-connected products
• Virtualised products, containers

1. Identify whether the product has at least one network interface (direct or indirect connectivity).
2. Check exclusions (medical devices, aviation, automotive, military, etc.).
3. Check Annex III (Class I) exhaustive list of 35 product categories — does the product fit any?
4. Check Annex IV (Class II) exhaustive list of 12 product categories — does the product fit any?
5. If neither Annex applies, the product is Default class.
6. Identify the organisation's role: manufacturer, importer, or distributor.
7. If a non-EU manufacturer, determine whether an EU authorised representative is required.

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1. No known exploitable vulnerabilities at time of placing on market
2. Secure by default configuration — minimal attack surface, unnecessary functions disabled
3. Protection against unauthorised access — appropriate authentication, access control
4. Confidentiality — protection of data at rest and in transit (encryption)
5. Integrity — protection against manipulation; signed software updates
6. Minimal data processing — data minimisation and privacy by design
7. Protection of availability — resilience against denial of service
8. Limited negative impact on other devices/networks
9. Exploit mitigation mechanisms
10. Security-relevant information disclosed to users

1. Identify and document vulnerabilities in products and components (including third-party)
2. Address vulnerabilities without delay — free security updates
3. Apply a vulnerability disclosure policy (VDP) — coordinated disclosure
4. Publish a point of contact for vulnerability reporting
5. Share information with CERT/CSIRT networks
6. Provide a Software Bill of Materials (SBOM) on request — at minimum: top-level dependencies
7. Maintain free-of-charge security updates for the support period
8. Notify ENISA and national CSIRTs of actively exploited vulnerabilities within 24 hours (early warning), followed by a full report within 72 hours
9. Notify users promptly of security issues and remediation measures

1. Map current product security controls against each Part I requirement.
2. Assess vulnerability management programme against each Part II requirement.
3. Confirm existence of VDP and public point of contact.
4. Confirm SBOM capability (at minimum, top-level open-source components).
5. Determine support period commitment.
6. Identify gaps, assign risk ratings, and propose remediation timeline.

references/conformity-assessment.md

1. Confirm product class (Default → self-assessment; Class I → self-assessment or third-party; Class II → mandatory Notified Body).
2. Prepare technical documentation (TD) — required elements per Annex VII.
3. Conduct conformity assessment against Annex I requirements.
4. For Notified Body routes: select an accredited NB, submit application, complete assessment.
5. Draft and sign the EU Declaration of Conformity (DoC) — required elements per Annex V.
6. Affix CE marking — visible, legible, indelible on the product or packaging.
7. Retain TD and DoC for 10 years after placing on market.

• General product description and intended use
• Design and development documentation (architecture diagrams, threat model)
• Security risk assessment
• Cybersecurity measures implemented
• Test reports and evidence of conformity
• SBOM (at minimum, top-level dependencies)
• Vulnerability handling policies and procedures

1. Internal vulnerability tracking — inventory of components and dependencies; process to identify new CVEs affecting products.
2. Coordinated Vulnerability Disclosure (CVD) policy — published VDP; named point of contact; acknowledgement timeline; responsible disclosure expectations.
3. Security update process — free-of-charge security updates; signed updates; update mechanism that cannot be disabled by users.
4. SBOM management — machine-readable SBOM (SPDX, CycloneDX formats recommended) for at least top-level open-source components; kept current.
5. ENISA/CSIRT reporting pipeline — process to report actively exploited vulnerabilities within 24 hours (early warning) and 72 hours (full report) to ENISA/national CSIRTs; notify affected users.
6. Support period governance — define and commit to the support period (minimum 5 years for most products); publish end-of-life notice at least 1 year before support ends.
7. Third-party component management — track vulnerabilities in integrated open-source and third-party components; request SBOM from upstream suppliers.

• Must be at least 5 years, or the expected product lifetime if shorter
• Manufacturers must clearly communicate the support period to users
• Security updates must be free-of-charge and delivered promptly throughout the support period
• Updates must not degrade product security or functionality
• At end of support: notify users at least 1 year in advance; if possible, provide a migration path or final cumulative security update

• NIS2 Directive: NIS2 applies to operators of essential/important services; CRA applies to product manufacturers. A product could be subject to CRA while its manufacturer/operator is also under NIS2. No conflict — they are complementary.
• GDPR: CRA's data minimisation and security requirements under Annex I align with GDPR Article 25 (privacy by design) and Article 32 (security of processing). Products must implement both.
• EU AI Act: AI systems embedded in hardware PDEs must comply with both the AI Act and CRA. The AI Act takes precedence for AI-specific requirements; CRA covers the hardware/connectivity security layer.
• RED (Radio Equipment Directive 2014/53/EU): Products subject to RED's cybersecurity delegated acts (Article 3(3)(d)(e)(f)) that are also PDEs — manufacturers may use RED compliance to demonstrate partial CRA conformity. ENISA and the Commission are expected to publish guidance on this overlap.
• MDR/IVDR: Medical devices are excluded from CRA. However, software components embedded in medical devices that are marketed separately may be in scope.

This skill provides general compliance information, not legal advice. Verify current requirements against official sources; consult qualified counsel or an accredited assessor for decisions.