CRA: Your product, your file, everything in one place
The Cyber Resilience Act sets requirements for products with digital elements across the whole life cycle. Complass guides you product by product from applicability to CE marking.
Compliance management in 20 secondsProject, next step, checklist, Statement of Applicability, audit package. Beispieldaten der Demo-Firma.
What is CRA?
The Cyber Resilience Act (CRA) is EU Regulation (EU) 2024/2847 on horizontal cybersecurity requirements for products with digital elements. It requires security by design, vulnerability handling throughout the support period, reporting of actively exploited vulnerabilities and a conformity assessment with CE marking.
Content as of:
Does it apply to me?
The CRA applies to products with digital elements made available on the EU market, i.e. hardware and software with a data connection such as controllers, devices and applications. Obligations mainly affect manufacturers, as well as importers and distributors. Exceptions apply, among others, to products already covered by certain other EU rules.
The reporting obligations under Art. 14 have applied since 11 September 2026, including for products placed on the market before that date.
This overview does not replace legal advice. The legal or normative text is authoritative; in Complass you check applicability with guidance based on the references.
Legal basis
Art. 2 CRAArticle 2 Cyber Resilience ActScope1. This Regulation applies to products with digital elements made available on the market, the intended purpose or reasonably foreseeable use of which includes a direct or indirect logical or physical data connection to a device or network. 2. This Regulation does not apply to products with digital elements to which the following Union legal acts apply: - (a) Regulation (EU) 2017/745; - (b) Regulation (EU) 2017/746; …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗Scope
Art. 3 CRAArticle 3 Cyber Resilience ActDefinitionsFor the purposes of this Regulation, the following definitions apply: (1) ‘product with digital elements’ means a software or hardware product and its remote data processing solutions, including software or hardware components being placed on the market separately; (2) ‘remote data processing’ means data processing at a distance for which the software is designed and developed by the manufacturer, or under the …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗Definitions
Art. 7 CRAArticle 7 Cyber Resilience ActImportant products with digital elements1. Products with digital elements which have the core functionality of a product category set out in Annex III shall be considered to be important products with digital elements and shall be subject to the conformity assessment procedures referred to in Article 32(2) and (3). The integration of a product with digital elements which has the core functionality of a product category set out in Annex III shall not in …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗Important products with digital elements
Art. 13 CRAArticle 13 Cyber Resilience ActObligations of manufacturers1. When placing a product with digital elements on the market, manufacturers shall ensure that it has been designed, developed and produced in accordance with the essential cybersecurity requirements set out in Part I of Annex I. 2. For the purpose of complying with paragraph 1, manufacturers shall undertake an assessment of the cybersecurity risks associated with a product with digital elements and take the outcome …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗Obligations of manufacturers
Key dates
Entry into force of the Regulation
Art. 71(1)Article 71 Cyber Resilience ActEntry into force and application1. This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. 2. This Regulation shall apply from 11 December 2027. However, Article 14 shall apply from 11 September 2026 and Chapter IV (Articles 35 to 51) shall apply from 11 June 2026.As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
Chapter IV (notified bodies, Art. 35–51) applies
Art. 71(2)Article 71 Cyber Resilience ActEntry into force and application1. This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. 2. This Regulation shall apply from 11 December 2027. However, Article 14 shall apply from 11 September 2026 and Chapter IV (Articles 35 to 51) shall apply from 11 June 2026.As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
Reporting obligations under Art. 14 apply – including for existing products
Art. 71(2)Article 71 Cyber Resilience ActEntry into force and application1. This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. 2. This Regulation shall apply from 11 December 2027. However, Article 14 shall apply from 11 September 2026 and Chapter IV (Articles 35 to 51) shall apply from 11 June 2026.As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
24 hours / 72 hours / 14 days
Early warning, notification and final report for actively exploited vulnerabilities (final report 14 days after a fix is available)
Art. 14 CRAArticle 14 Cyber Resilience ActReporting obligations of manufacturers1. A manufacturer shall notify any actively exploited vulnerability contained in the product with digital elements that it becomes aware of simultaneously to the CSIRT designated as coordinator, in accordance with paragraph 7 of this Article, and to ENISA. The manufacturer shall notify that actively exploited vulnerability via the single reporting platform established pursuant to Article 16. 2. For the purposes of …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
Ten phases from applicability and role through classification and risk assessment to the declaration of conformity, post-market obligations and product liability.
Catalogue for Annex I
Essential cybersecurity requirements and vulnerability handling with status and evidence, linkable with IEC 62443-3-3 and the Machinery Regulation.
Vulnerabilities in your own product
Import the SBOM, continuously match components against public vulnerability data and create the Art. 14 incident pre-filled in case of active exploitation.
Technical documentation
Templates for, among others, risk assessment, SBOM concept, vulnerability handling process, disclosure policy, user information per Annex II and EU declaration of conformity.
The CRA and the Machinery Regulation in one file per product and version: requirements, SBOM, vulnerabilities, support period. Complass drafts the technical documentation and the EU declaration of conformity.
What you need at a minimum as a manufacturer
If you are a manufacturer under the CRA, this selection covers the obligations in Complass. The free applicability check shows whether it does.
minimum selection manufacturer
Start package, size S, with Vulnerabilities and attack techniques
Vulnerabilities and attack techniques (incl. SBOM, CRA product file, MITRE ATT&CK): Handle vulnerabilities and send an early warning on actively exploited vulnerabilities within 24 hours. (Art. 14, Annex I Part II CRA (opens in a new tab))+ €149
Incident management
GDPR, AI Act and Whistleblower protection (HinSchG) (baseline protection)
If you are only an importer or distributor (Art. 19, 20 CRA), the CRA framework without the vulnerability module is enough in Complass: Start, €199 net/month. Anyone who sells products under their own name or substantially modifies them counts as a manufacturer (Art. 21, 22 CRA). View selection: minimum selection importer or distributor
Recommended
Business
€739net per month
More impact with Asset management and zones, Supplier Management and Business continuity management (BCM), room for 10 users and 2 frameworks.