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One article interpretation: Core requirements of the European Union's Cyberresilience Act CRA
Author.
LCS
Source:
Post time:
2025-12-12
1、 Background of the Act
With the rapid popularization of "smart" devices, IoT terminals, embedded software, and remote data processing systems, ordinary household devices such as smart cameras, refrigerators, toys, wearable devices, and even industrial control systems may become attack targets through network connections and data exchange. Therefore, the formulation of the Cyber Resilience Act (CRA) is based on the extreme popularity of digital products, the sharp rise in security risks, insufficient coverage of existing regulations, and the EU's desire to enhance consumer and business trust through unified market rules.
2、 Basic requirements for network security
Firstly, what is a 'product containing digital elements'?
A software or hardware product, as well as a remote data processing solution related to it; Including software or hardware components that are separately launched on the market. Simply put, as long as the product contains software, firmware, chips, or requires connection to the backend system to process data, it is considered a digital product. Even communication modules and software components sold separately are considered.
The safety requirements of the product itself
CRA requires all products with digital elements to be 'default safe' throughout the entire process from design, development to production. When the product is launched, it must not contain known vulnerabilities, and the factory configuration must be a secure configuration; Data transmission and storage need to be encrypted and tamper proof; To prevent unauthorized access, reduce the attack surface, and ensure the sustainable operation of core functions in the event of an attack. At the same time, the product needs to have secure logging capabilities, as well as support for thorough and secure data deletion and migration.
Manufacturer's Vulnerability Management Responsibility
Manufacturers must establish a comprehensive vulnerability management system, including creating a Software Bill of Materials (SBOM), continuously conducting security testing, timely releasing patches, and ensuring that security updates can be automatically pushed; And provide publicly transparent vulnerability information after fixing the vulnerability (which can be delayed if necessary); Establish vulnerability disclosure policies and reporting channels to ensure that users can receive patches quickly and securely. The overall goal is to ensure that the product remains consistently safe throughout its entire lifecycle.
3、 Scope of application
As long as the purpose of the product is to connect data with devices or networks. Almost all are applicable to CRA.
Specifically, it can be divided into important products and key products
Important products: network management systems, standalone/embedded browsers, password managers, network management systems, boot managers, operating systems, various software products, security related microprocessors/controllers, routers, switches, firewalls, intrusion detection and defense systems, etc.
Key products: Hardware devices with security boxes, smart meter gateways, smart cards or similar devices, security elements, other devices used for advanced security purposes, including devices used for secure encryption processing.
4、 Punishment
According to the Cybersecurity Resilience Act, for violating companies, a maximum penalty of 2.5% of the global annual revenue for the previous fiscal year or an administrative fine of 15 million euros can be imposed. Providing incorrect, incomplete, or misleading information to notified bodies and market supervision agencies may result in a maximum penalty of 1% of the global annual revenue for the previous fiscal year, or an administrative fine of 5 million euros.
5、 Effective time
The notification obligation of qualified assessment institutions will take effect from June 11, 2026.
The manufacturer's obligation to report security incidents will be implemented from September 11, 2026: the obligation for manufacturers to report when they discover vulnerabilities or serious security incidents in their products that have been actively exploited. Manufacturers are required to report vulnerabilities or security incidents to CSIRT and ENISA within specific time periods (such as 24 hours, 72 hours, 14 days, etc.) and provide detailed event information, impact assessments, remediation measures, etc.
All other regulations will come into effect from December 11, 2027.
6、 The difference between the Network Resilience Act (CRA) and the EN 18031 standard:
CRA: For all products with digital elements, including hardware, software, embedded systems, IoT devices, etc. Its purpose is to ensure the network security of these products from design to lifecycle management, requiring manufacturers to consider network security in product design and production processes, and provide remediation measures for known vulnerabilities.
EN 18031: It is a European standard for specific fields, mainly focusing on developing network security requirements for networked wireless devices (such as smart home devices, wireless communication devices, etc.).
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