Market Outlook
mechanisms to securely distribute updates” indicates that such updates must be automatically distributed, free-of-charge and in a timely manner (so ideally over-the-air) – and the act further specifies that “the support period for which the manufacturer ensures the effective handling of vulnerabilities should be no less than five years”.
“identify and document vulnerabilities and components… by drawing up a software bill of materials (SBOM)”: while it’s possible this may be delayed, as the format is still to be defined by a standards working group, that’s not guaranteed – and you will probably need a SBOM to know where to check for vulnerabilities regardless.
Q: What about open source? A: Open-source software is mentioned many times throughout the CRA – but any protections are more aimed at the open source community rather than, for example, OEMs using Linux. A special working group (‘ADCO: Administrative Cooperation Group’) will be set up to ensure consistent application of the CRA. But I don’t foresee any special exemptions – and it will fall on developers and the open source community to come up with compliance routes. No magic wands are being waved so far.
Q: Seems quite onerous! Surely there’s a ‘grace period’? A: Yes, there is a 36-month grace period, after which it will apply to any product which is then fi rst sold commercially or “substantially modifi ed”. However, the act will also require reporting of incidents and vulnerabilities by the vendor 15 months before that.
Q: Where can I read the full details? A: You can read all about the CRA on the EU’s Digital Strategy website here: https://
digital-strategy.ec.europa.eu/en/policies/ cyber-resilience-act
…or you can read the full text of the Cyber Resilience Act (Regulation (EU) 2024/2847) itself here: https://
eur-lex.europa.eu/legal-content/EN/TXT/ PDF/?uri=OJ:L_202402847 – enjoy!
Q: What does this mean for embedded systems & IoT developers? A: Parts of the Cyber Resilience Act apply to both new and existing products (for
www.cieonline.co.uk
instance, requirements around reporting of incidents and vulnerabilities – or if existing products are “substantially modified” in the future). So, as well as ensuring that your current project complies, there are also question marks around existing products. Clearly, three years isn’t sufficient time to redesign all legacy products, so some OEMs are adopting a “wait and see” approach – while others, mindful of the potential market advantage, are pressing ahead with redesigns.
Many developers are currently working on products which will release within three years, so theoretically, this far-reaching legislation may not apply (unless the product is “substantially modifi ed” in the future). But remember, if your project gets held up or modifi ed, and goes beyond the three-year deadline, then it will have to comply. Since Direct Insight often operates within safety-critical and medical product development fields, we’re already seeing the impact of meticulous consideration of CRA in those projects.
The most critical items to consider are secure boot, and a secure update process (ideally OTA: over-the-air), as these may be difficult features to add retrospectively. We also expect to see a flurry of compliance concerns in more general- purpose embedded markets as projects begin which may not ship by mid-2027. Customers may be encouraged to move to a commercial OS, where some of the compliance work is already done by the vendor. Maybe a compliance route for Linux will emerge – but it’s hard to say right now.
Q: How can I learn more about how to navigate the CRA in our IoT and embedded systems product development? A: Embedded systems developers wanting to learn how to navigate the Cyber Resilience Act (CRA) can watch this online training workshop from Direct Insight. Entitled ‘The EU Cyber Resilience Act: Practical Preparation for Embedded Engineers’, our free training webinar (available on demand at: https://www.
directinsight.co.uk/eu-cyber-resilience-act- free-training-webinar/) will explain how embedded systems engineers can prepare for the CRA and discuss what it means for developers concerned about the move towards compliance.
https://www.directinsight.co.uk/ Components in Electronics December/January 2025 15
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