Cybersecurity by Design: Preparing for the Cyber Resilience Act
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Cybersecurity by Design: Preparing for the Cyber Resilience Act
The European Union’s Cyber Resilience Act (CRA) is a landmark piece of legislation set to redefine cybersecurity standards for products with digital elements. Adopted in March 2024, the CRA establishes a new baseline for security, requiring companies to embed cybersecurity practices throughout the entire product lifecycle. For product developers, this means shifting from a reactive stance to a proactive “secure by design” philosophy. Understanding the CRA’s requirements is the first step toward compliance and avoiding significant penalties.
This blog post will guide you through the key aspects of the CRA, including its core requirements, the costs of non-compliance, and how you can leverage powerful tools to streamline your journey to compliance.
What is the EU Cyber Resilience Act?
The CRA is the first horizontal EU legislation that mandates cybersecurity for any product with digital components sold within its market. This includes everything from industrial machinery and robotics platforms to smart home devices and consumer electronics. The legislation aims to protect consumers and businesses by ensuring that products are secure from the moment they are designed until the end of their support lifecycle.
Key timelines to remember:
- Reporting Obligations: Mandatory reporting of identified vulnerabilities and severe incidents become legally enforceable in September 2026.
- General Obligations: Requirements around secure-by-design, full documentation, and conformity assessments, and more are planned to go into effect by December 2027.
The CRA also categorizes products into four risk classes (Class I to III, plus Critical Products). This classification determines the level of scrutiny and evidence required to prove compliance, ranging from basic documentation to a full third-party conformity assessment.
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Key CRA Requirements for Product Developers
The CRA is not a simple checklist; it demands a comprehensive, lifecycle-based approach to security. Product developers must integrate several key practices into their workflows to meet the new standards.
Conduct Cybersecurity Risk Assessments
You must systematically identify and evaluate potential cybersecurity threats, intended uses, and foreseeable misuse of your product. This forms the foundation of your security strategy.
Define and Document Security Requirements
Based on your risk assessment, you need to define and document specific security requirements. These requirements must be traced to design controls, verification activities, and even source code to demonstrate how you are mitigating identified risks.
Maintain a Software Bill of Materials (SBOM)
An SBOM is a detailed inventory of all software components, libraries, and modules within your product. This list is crucial for tracking components and managing their associated vulnerabilities effectively.
Implement Secure Development and Vulnerability Handling
The CRA requires you to establish and maintain secure development processes. This includes having a structured process for identifying, managing, and patching vulnerabilities discovered after the product is on the market.
Prepare Technical Documentation
You must compile a comprehensive Technical Documentation Package that can be presented to regulators on demand. This package serves as the complete record of your product’s security posture and compliance efforts. It should include:
- The cybersecurity risk assessment.
- Documented and traceable security requirements, design controls, and test results.
- Traceability to implementation tasks and code
- Evidence of your secure design and development process.
- The SBOM.
- Details of your vulnerability handling workflow.
- A lifecycle maintenance plan.
The High Cost of Non-Compliance
Ignoring the CRA is not an option. The penalties for failing to meet its obligations are severe and can have a lasting impact on your business. These include:
- Fines of up to €15 million or 2.5% of your company’s global annual turnover.
- The authority for EU regulators to withdraw or recall non-compliant products from the market.
- Mandatory reporting of incidents and vulnerabilities.
- Increased liability for damages caused by insecure products.
Beyond the direct financial penalties, the reputational damage and loss of market access can be devastating.
Navigating Compliance with Standards and Traceability
While the CRA is principles-based and doesn’t mandate one specific cybersecurity standard, it aligns with several established international frameworks. Adopting one of these can provide a structured path to compliance. Relevant standards include:
- ISO/IEC 62443 for industrial automation and control systems.
- ETSI EN 303 645 for consumer Internet of Things (IoT) devices.
- ISO/IEC 27001 for security controls and information security management.
- ISO/IEC 81001-1 for health software security.
Regardless of the standard you follow, the core principle is demonstrating traceability. Regulators will want to see a clear, auditable link from an identified threat to a risk assessment, through to the security requirement, its implementation as a control, and the verification test that proves it works.
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How Jama Connect® helps to achieve CRA Compliance
This is where a dedicated requirements management platform like Jama Connect becomes a strategic asset. It provides the structure and capabilities needed to build a compliant and traceable development process. Each step of the CRA’s required workflow—from threat identification to documentation—can be mapped directly into Jama Connect as item types within a traceability model.
This means that when a regulator asks, “Show me how you mitigated this vulnerability,” you can instantly generate a report that traces the entire lifecycle of the mitigation. You can show the risk, the requirement it generated, the control that was implemented, the test case that validated it, and all the associated evidence.
Jama Connect offers new and upcoming solutions specifically designed to help you prepare for the CRA:
- Consolidated Frameworks: Pre-configured project templates for consumer electronics and industrial machinery are available. These include the necessary item types and traceability models to align with CRA requirements and standards like SAFe.
- CVSS Templates: To support advanced threat analysis, templates for Common Vulnerability Scoring System (CVSS) versions 2.0, 3.1, and 4.0 are available. These integrate with Excel functions to automate score calculations directly within the platform.
Get Ready for the Cyber Resilience Act
The clock is ticking on the Cyber Resilience Act. While the deadlines may seem distant, building a compliant, secure-by-design development process takes time. The key is to start now. By updating your information models and leveraging tools like Jama Connect, you can build the traceability and documentation needed to meet CRA obligations confidently. Incorporating these practices not only ensures compliance but also results in more secure, resilient, and trustworthy products for your customers.
Note: This article was drafted with the aid of AI. Additional content, edits for accuracy, and industry expertise by Patrick Garman and Mario Maldari.
Manager, Solutions & Consulting at Jama Software
I take great joy in exploring how technology can be applied to business problems in new and unexpected ways to create fluid experiences for customers.
I hold a B.A. from Sewanee: The University of the South and an MBA from Goizueta Business School at Emory University. My professional experience includes project management, new product development, customer insights, and marketing strategy and spans the health, hospitality, transportation and logistics, public, and retail sectors.
I am based in Birmingham, Alabama, with my partner Ian and enjoy live music, cooking, coffee roasting, and spending time with our dogs Toby and Jude and our cat Isabella Rossellini.
I can be reached at garmapq@gmail.com.
I hold a B.A. from Sewanee: The University of the South and an MBA from Goizueta Business School at Emory University. My professional experience includes project management, new product development, customer insights, and marketing strategy and spans the health, hospitality, transportation and logistics, public, and retail sectors.
I am based in Birmingham, Alabama, with my partner Ian and enjoy live music, cooking, coffee roasting, and spending time with our dogs Toby and Jude and our cat Isabella Rossellini.
I can be reached at garmapq@gmail.com.
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