EU Cyber Resilience Act (CRA): Requirements, Deadlines and Five-Year Update Rules

The EU’s Cyber Resilience Regulation has been in effect since December 2024. It requires manufacturers of connected products to meet clear security standards, follow reporting obligations, and provide regular updates. Requirements vary by product category, and manufacturers must adjust and document their processes accordingly.

Many manufacturers and users are asking what the Cyber Resilience Act means for them. The Cyber Resilience Act (CRA) came into force on December 10, 2024. Its provisions will be implemented in stages: initial reporting obligations for manufacturers begin September 11, 2026, and full enforcement will take effect December 11, 2027. From late 2027 onward, non-compliant products will no longer be permitted on the EU market, and affected companies will face new responsibilities. These include stronger security requirements, risk assessments, detailed documentation, and expanded reporting. However, the exact obligations depend on the product category and specific criteria. 

Security requirements: Regulation Applies to All Connected Devices

The Federal Office for Information Security (BSI) aims for the regulation to establish a “minimum level of cybersecurity” for all connected products. This represents a significant shift: any product with digital components sold in the EU must now comply with specific security standards. This covers manufacturers offering hardware or software that is either directly or indirectly connected. 

The scope is broad and covers:

  • Consumer devices (smartwatches, connected toys, video games)
  • Business solutions (microprocessors, cloud services, firewalls, VPNs)
  • Software applications and infrastructure components

Open-source software is exempt only if it is not used for commercial purposes.

Product Categories: VPNs Classified as Critical Category I

The regulation classifies connected products into several categories based on their risk level. Basic “products with digital elements” include items like smartphones, tax software, robotic vacuum cleaners, and Airtags. More sensitive products fall into two “important” classes, Class I and Class II, with an additional “critical products” category.

In brief, the categories are:

  • General products
  • Important products – Class I
  • Important products – Class II
  • Critical products 

Examples include:

  • Class I: Web browsers, password managers, SIEM tools, VPN software and hardware, operating systems, routers, and switches
  • Class II: Hypervisors and container platforms
  • Critical products: Smart cards and hardware security modules

These categories determine the level of obligation. Class II products face stricter requirements than Class I, which in turn are more regulated than general products. The Cyber Resilience Act offers several compliance modules, from internal controls (Module A) to EU type examinations (Modules B and C), and comprehensive quality assurance (Module H). Certification is also an option.

Security Patches: Five-Year Update Requirement Begins in 2027 

Until now, there was no legal mandate for security updates, but the Cyber Resilience Act changes this. Providers must deliver security updates and vulnerability fixes for a minimum of five years. Shorter update periods are allowed only if the product’s expected lifespan is less than five years.

Manufacturers must supply these security updates promptly and free of charge. An exception exists for customized products, where companies may arrange paid updates through contracts. 

Risk Analysis: Essential Steps for CRA Compliance 

To ensure CRA compliance, manufacturers must:

  • Identify affected products
  • Determine the applicable product category
  • Conduct structured cybersecurity risk assessments
  • Implement appropriate technical and organizational safeguards
  • Maintain comprehensive compliance documentation

The regulation applies to companies of all sizes.

Non-compliance may result in fines of up to:

  • 15 million euros
  • or 2.5% of global annual turnover

Support is available from the Federal Office for Information Security (BSI), which has published a technical guideline detailing manufacturer and product requirements. The BSI also offers downloadable information brochures to help companies get started. 

Conclusion: Preparing for CRA Compliance Before 2027 

The EU Cyber Resilience Act represents a fundamental shift in product cybersecurity regulation. Manufacturers must integrate security-by-design principles, long-term update strategies, and structured risk management processes into their development lifecycle.

Organizations that begin preparing early will reduce regulatory risk and avoid last-minute compliance challenges before the 2027 enforcement deadline.

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