Feature: Security
the product if shorter, and requires that manufacturers provide a specifi ed end-of- support date upon market release. When an actively exploited vulnerability
is discovered, manufacturers must disclose it to their national Computer Security Incident Response Team (CSIRT) and European Network and Information Security Agency (ENISA), the EU agency for cybersecurity. T is reporting commitment comes into eff ect on September 11, 2026, with the following timeframe requirements: • 24 hours: Early warning reports must be sent to ENISA and the national CSIRT.
• 72 hours: A formal vulnerability notifi cation must be generated that details the exploit and how it aff ects a system.
• 14 days: A fi nal report must be submitted once a security patch is available. Naturally, continuous vulnerability
management requires some level of real- time threat monitoring. Public frameworks like the Common Vulnerabilities and Exposures (CVE) system can help manufacturers spot and patch new threats in third-party soſt ware components, even before they are actively exploited within their own devices. To support this, the CRA also mandates
that manufacturers maintain technical documentation for every update. In particular, a soſt ware bill-of-materials (SBOM) must be provided in a machine- readable format, such as CycloneDX or SPDX, covering all top-level dependencies at a minimum. T is format enables automated tools to scan every soſt ware build against CVE databases, to identify new vulnerabilities as soon as they are reported. DevSecOps teams can then deliver patches that fi x in-house issues without introducing third-party soſt ware.
Figure 2: CRA conformity requires that manufacturers produce comprehensive, up-to-date technical documentation for all products
In addition to SBOMs, CRA conformity
requires extensive documentation that includes a high-level security risk assessment, system architecture diagrams with a description of the development process, and descriptions of the vulnerability handling process; see Figure 2. T ese are used to verify that the system is secure-by-design within CRA guidelines. Logged documentation must be retained throughout a device’s lifecycle and made available to auditors and surveillance authorities, and notify bodies for ten years aſt er market release, or for the duration of a longer support period. Finally, a formal declaration of
conformity (DoC) allows manufacturers
to use the CE marking for EU market access. T e DoC document contains details that include the manufacturer’s name and address, a unique identifi cation for the product, and references to specifi c standards and technical specifi cations used to prove compliance. For certain digital products that come under the CRA’s “Important Class I”, “Important Class II” and “Critical” categories, details of a third-party auditor must also be included to verify compliance. Such devices include industrial control systems, IoT gateways and soſt ware for privileged access, where breaches may cause wider infrastructure damage. By signing a DoC, manufacturers take full
responsibility for CRA compliance. Given the depth of these commitments,
With full regulatory rollout marked for December 11, 2027, and other mandatory requirements coming too, it is essential for engineering teams and product managers to understand the legislation
OTA updates provide the most eff ective way to quickly deliver patches and maintain connected device integrity. Continuous OTA updates, however, require a sophisticated soſt ware architecture that specifi cally caters to CRA-aligned updates.
Designing for regular OTA security Under the CRA, DevSecOps teams face immense time pressure when locating,
www.electronicsworld.co.uk May 2026 31
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