CRA Deep Dive: Obligations, gaps, plan.

The reporting obligation already applies. From December 2027, your device only gets the CE mark with CRA proof. In one day you will know where your product and your organization stand.

Format

CRA Deep Dive, one day

Price

Fixed price

Result

Gap list, separated into organization and device

Deadlines

Reporting obligation since 11 Sep 2026 · Full application from 11 Dec 2027

Basics

What is the CRA and who is affected?

The Cyber Resilience Act (CRA, Regulation (EU) 2024/2847) regulates the cybersecurity of products with digital elements. It applies to manufacturers, importers and distributors of devices with software and a data connection, whether wireless or wired.

Standard products

Self-assessment is enough.

Important products (Class I and II)

For Class I without a harmonized standard, effectively a notified body.

Critical products

Strictest level with its own testing obligations.

CRA reporting obligation: applies since 11 Sep 2026

24 h early warning, 72 h notification, 14-day final report, also for devices in the field. More from the BSI and ENISA.

The situation

Three deadlines set your schedule.

As an EU regulation, the CRA has applied directly in all member states since 10 Dec 2024. The obligations apply in stages, and the first one is already running.

In our project experience, implementation in a company takes 18 to 24 months. That is an empirical value, not a legal requirement.

10 Dec 2024

The CRA enters into force

11 Sep 2026 · already applies

Reporting obligation for actively exploited vulnerabilities

It also applies to devices already in the field. The deadlines are in the Basics section.

11 Dec 2027

CE mark only with CRA proof

Then the remaining obligations apply, including Annex I, conformity assessment and at least five years of security updates. They apply to products placed on the market from this day.

Wireless or wired

CRA for embedded and IoT: Your starting point determines how far along you already are.

With wireless

You already have a foundation

Since August 2025, radio devices must meet cyber requirements from the Radio Equipment Directive, tested to EN 18031. From 11 Dec 2027 the CRA replaces this obligation.

Good EN 18031 work carries over: Many pieces of evidence can be mapped to the CRA's technical security requirements for your device.

Wired only

You start without groundwork

For purely wired devices there was no comparable cyber obligation in the CE procedure so far. The CRA applies anyway, including with an indirect connection, for example via a gateway.

Hybrid devices carry the radio obligation today and the CRA for the whole device from 2027.

The CRA demands more than EN 18031

It covers all elements of the radio requirements and adds five more.

Software bill of materials (SBOM)

Vulnerability management

Coordinated disclosure

Reporting to ENISA

Support period

The device check

CRA checklist for manufacturers: Four questions for your device.

If you cannot answer one of them with yes, you know where the work begins.

1

Do signed updates arrive remotely?

Security updates, preferably automatic, with protected integrity and separate from feature updates.

2

Is there a software bill of materials per version?

Machine-readable, at least with the top-level dependencies. The modem firmware belongs in it too.

3

Do you report a vulnerability within 24 hours?

Early warning, notification and final report run through the ENISA reporting platform.

4

Can you prove conformity?

Technical documentation with risk assessment, to be kept for ten years.

Division of labor

Whoever sells under their own name is the manufacturer.

This also applies when others develop for you. The contract regulates who delivers what to whom. Responsibility towards the authority stays with you, including due diligence for third-party components.

Evidence is created during development, not at the end. That is why development and regulatory work sit at the same table from the start.

Who does what

Two sides, one proof

IOX implements in the device:

→ Secure boot

→ Remote updates

→ Software bill of materials

→ Key management

→ Radio approval

A consulting partner accompanies the regulatory side:

Classification of the obligations, concept paper and gap list, so your management can decide.

Process

CRA implementation: One day, one list, then the plan.

Step 1 · CRA Deep Dive

CRA Deep Dive

One day at a fixed price. We go through your product and your organization together.

The Deep Dive does not replace legal advice.

Deep Dive key facts

Price: Fixed price that we name in the first call.

Location: Online or on site, at your place or in Cologne.

Participants: The person who makes the final decision and the experts who know your product best.

Documents: Please don't send anything confidential yet. We are happy to sign a non-disclosure agreement before exchanging documents.

Step 2 · Gap list

Gap list

Separated into organization and device, complemented by a concept paper. The result belongs to you.

Step 3 · Implementation in the device

Implementation in the device

We implement what is missing. The evidence is created directly during development.

Are you still at the start of your product development? Then the Accelerator Sprint fits.

Proof

150+

Projects around connected products.

Remote updates in the field

For the sensor and gateway of a car wash manufacturer, in operation.

View project →

CE procedure supported

Two CE products, tested at TÜV Süd and TÜV Nord.

View project →

Radio link designed for CRA obligations

Developed for a pump manufacturer, with the upcoming requirements in mind.

View project →

[Photo]

Who leads the Deep Dive

[Name, role at IOX]

[Two sentences on experience with embedded, radio, cloud and CE procedures]

Frequently asked questions

What manufacturers ask first.

Are we still the manufacturer if others do the development?

Yes, as soon as the product comes to market under your name or brand. The manufacturer is whoever develops a product or has it developed and markets it under their own name or brand.

A development contract only regulates who delivers what to whom. Responsibility towards the authorities stays with the manufacturer, including due diligence for purchased third-party components. If you develop on commission and do not market the product yourself, you should clearly delimit the roles with the client by contract.

Does the CRA also apply to devices that have already been sold?

The design and documentation obligations apply to products that are placed on the market or substantially modified from 11 Dec 2027. The reporting obligations, however, have applied since 11 Sep 2026 to products that are already in the field.

For manufacturers with installed devices this means: The process for vulnerability reports must be in place before the other obligations take effect. You should be able to report an actively exploited vulnerability within 24 hours and know how a security update reaches devices in the field.

Is EN 18031 enough?

EN 18031 covers the requirements of the Radio Equipment Directive that have applied to radio devices since August 2025, and it is a good building block. But it does not automatically replace CRA proof.

The CRA covers all elements of the radio requirements and additionally requires a software bill of materials, vulnerability management, coordinated disclosure, reporting and a support period of at least five years. Your existing evidence can be mapped to Annex I Part I of the CRA. In the Deep Dive we check which gaps remain.

Is ISO 27001 enough?

It helps with the processes in your organization but does not replace evidence on the product.

The CRA requires evidence for the device itself, such as a software bill of materials, security updates and technical documentation. That is why the gap list in the Deep Dive separates organization and device.

What applies to open-source components?

As the manufacturer you carry the due diligence for all third-party components in the product, including open source. They belong in the software bill of materials, because every third-party component brings its own vulnerability risk and its own update path.

The support period of chip manufacturers can also be shorter than the lifetime of your device. Which special rules apply to open-source projects themselves, we classify for your case in the Deep Dive.

Do we need a testing body?

In the standard class, self-assessment is enough: You assess conformity yourself and declare it. For Class I products without a harmonized standard, a notified body effectively becomes necessary.

Which class applies to your product and where standards and notified bodies stand, we clarify in the Deep Dive.

What does the CRA Deep Dive cost?

The Deep Dive has a fixed price that we name in the first call. What the implementation costs depends on the gaps and can be estimated after the Deep Dive.

The effort varies a lot, depending on whether your wireless device already has evidence or is purely wired.

Request

Know where you stand. In one day.

Tell us briefly what you are working on. We will get back to you with a proposed date for the CRA Deep Dive.

The Deep Dive does not replace legal advice. The manufacturer declares conformity themselves.

Discuss my project

1. We will get back to you shortly.

2. Initial call 15 to 30 minutes, no sales pressure.

3. A proposal for the next step, or an honest no.

Please don't send anything confidential. IOX GmbH, Cologne, is responsible for this form. More in the privacy policy.

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