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Cyber Resilience Act Compliance Services for EU Market | CRA Guide
- Feb 4
- 7 min read
Now The EU Cyber Resilience Act (CRA) is a law, with mandatory compliance starting in 2027. From that date on, any product with digital components entering the EU market must meet CRA standards.
Certification practices are already familiar to compliance professionals: preparing for regulatory requirements, adapting products technically, and undergoing conformity assessment procedures is a lengthy and resource-intensive process.
Delaying preparation significantly increases financial costs, regulatory risks, and the risk of losing access to the EU market. So, as IT providers with CRA consulting service, we created this article to help companies assess their level of readiness for the CRA, identify their target compliance state in time, and begin implementing the necessary security and compliance measures.
Non-compliance with the standard can result in:
removal products from the EU market,
loss of contracts with EU clients and partners,
fines of up to €15 million or 2.5% of global annual turnover
These risks can be reduced to zero with a reliable partner. With over 10 years of experience in cybersecurity and regulatory compliance, we offer a comprehensive range of services to support CRA certification — from audits and assessments to technical implementation and staff training.
We’ve also developed our own compliance checklist for manufacturers, developers, importers, and distributors, so you can evaluate your readiness for the CRA
👉 Grab your compliance checklist by writing to our e-mail management@mutekigroup.com
What is the EU Cyber Resilience Act (CRA)
The CRA sets enforceable cybersecurity rules for any product entering the EU market ensuring digital goods are secure from design to delivery. It covers obligations related to:
secure product design,
vulnerability management,
incident reporting,
technical documentation,
security updates after the product is released.
Who does the CRA apply to? The CRA applies to both EU-based and non-EU companies if they:
sell products directly to customers in the EU
supply products through distributors, resellers, or OEM partners in Europe.
Products Covered by the EU CRA The CRA applies to nearly all products with digital components, including
software (both commercial and embedded),
hardware devices with software components,
Internet of Things (IoT) products,
networking equipment,
connected industrial and consumer products.
In practice, if a product processes, stores, or transmits data, it is very likely to fall under the CRA. A key requirement is integrating security from the earliest stages of product design.
CRA Requirements for Manufacturers
Before placing a product with digital components on the EU market, manufacturers must comply with the full set of requirements under the Cyber Resilience Act to ensure cybersecurity throughout the product’s entire lifecycle.
Under Article 13 of the CRA, manufacturers must conduct a cybersecurity risk assessment that takes into account the product’s intended use, expected operating conditions, and life cycle. The findings of this assessment should inform every stage—from planning and design to development, production, supply and ongoing maintenance—to reduce risks and prevent incidents.
Manufacturers are also responsible for securely integrating all components, including open-source software and third-party modules, applying proper due diligence during acquisition and use. Additionally, they must establish clear policies and procedures for managing and mitigating vulnerabilities, including coordinated disclosure when necessary.
Maintaining technical documentation is mandatory. This documentation should cover cybersecurity measures, risk assessments, known vulnerabilities, updates and the preparation of EU Declaration of Conformity. CE marking must be applied after completing the relevant conformity assessment procedure.
Additionally, manufacturers must ensure proper product identification (type, batch or serial number) and provide their name, contact details, and website on the product packaging or accompanying documentation. They must also guarantee product support for at least five years, or for the product’s expected lifespan if shorter.
Security updates released during the support period must remain available for at least ten years or until the end of the support period, whichever is longer.
The CRA also places particular emphasis on reporting obligations. Manufacturers must notify the relevant CSIRTs within 24 hours of discovering security vulnerabilities or incidents. They must notify market authorities and end users and provide vulnerability details to the developers of any integrated components. These reporting duties only become mandatory in 2027, once the transition period ends.
CRA and Software Developers
The Cyber Resilience Act (CRA) primarily targets companies that develop and commercialize software products for the European Union market. This mainly concerns non-embedded software sold or distributed alongside products with digital components.
Free open-source software and pure SaaS solutions are generally not the direct focus of the CRA, except when such software is used to remotely process data generated by hardware products sold in the EU. The CRA also takes into account existing sector-specific regulations. If software is already subject to other EU legislation, such as medical devices or civil aviation, the CRA requirements apply only to aspects not covered by the specialized legislation, avoiding duplication.
For software companies falling under the CRA, the regulation sets a clear objective: to improve the cybersecurity resilience of software products throughout their entire lifecycle.
This means implementing a risk-based approach to development, secure default settings, reducing attack surfaces, timely vulnerability remediation, and regular security updates. Special attention is given to access control, protection of privacy and data integrity, and ensuring that products can maintain the availability of key functions even after incidents. Beyond technical measures, the CRA requires developers to maintain proper documentation, including cybersecurity technical documentation, risk assessments, and, where applicable, a Software Bill of Materials (SBOM). Manufacturers must also make available an EU Declaration of Conformity explaining how the product complies with the CRA requirements and what security support users will receive. All relevant information must be retained for an extended period after the product is placed on the market.
Finally, the Cyber Resilience Act imposes duties to interact with market surveillance authorities and report incidents, but these obligations won’t be mandatory until the transition period ends in 2027. This provides software companies with time to prepare processes, adapt development, and integrate CRA requirements into their product and security strategies.
Importers, Distributors, and Third Parties
Importers play a critical role in ensuring that Internet of Things (IoT) devices entering the EU market comply with the Cyber Resilience Act (CRA). Before placing a product on the market, they must verify that the manufacturer has met all the baseline cybersecurity requirements set out in Annex I of the CRA.
Specifically, importers need to check whether the manufacturer has completed the conformity assessment, prepared technical documentation, and applied CE marking. It is also important to ensure that the product is accompanied by contact information, clear instructions, and safety-related information. The CRA places particular emphasis on documentation. For importing IoT devices into the EU, importers must have access to technical documentation, the EU Declaration of Conformity, CE marking, and complete information for both users and authorities. All of this documentation must be retained for at least 10 years.
If an importer discovers that a product does not meet essential CRA requirements or poses cybersecurity risks, they are obliged to refrain from placing it on the market, inform the manufacturer, and notify market surveillance authorities. In the event of vulnerabilities, the importer must immediately notify the manufacturer, and if the manufacturer cannot fulfill their obligations, the importer must also inform the competent authorities and end users.
Distributors: Compliance Control at the Point of Sale
Distributors are tasked with making sure that products with digital components entering the EU meet CRA requirements. They must act with due diligence, verify CE marking, and confirm that both the manufacturer and importer have met their regulatory duties.
To achieve this, distributors need to keep essential documentation on hand—such as proof of conformity, records of non-compliance, vulnerability reports, and details of corrective actions and communications with market authorities.
If a distributor spots cybersecurity risks or any CRA non-compliance, they must immediately halt distribution, notify the manufacturer and relevant authorities, and help resolve the issues. Should the manufacturer go out of business, distributors are also required to inform authorities and, when possible, end users.
Third Parties: When Modifications Trigger Manufacturer Responsibility
The CRA also applies to third parties who are not manufacturers, importers or distributors but make significant modifications to products with digital components and place them on the market. In such cases, these economic operators are considered manufacturers and must comply with all applicable CRA requirements.
However, this responsibility does not extend to routine security patches that do not change the product’s intended purpose, nor to products developed or modified exclusively for use by government administrations.
Achieving CRA Compliance
Compliance with the CRA is a structured, ongoing process rather than a one-time audit. A typical compliance path includes:
analyzing the product and assessing CRA applicability;
evaluating gaps in security and compliance;
developing a compliance roadmap;
implementing technical measures and remediations;
training teams;
conducting a final assessment and preparing documentation
Download the CRA Compliance Checklist by writing to our e-mail management@mutekigroup.com
Common Cyber Resilience Act Compliance Mistakes
For companies outside the EU, CRA certification is often underestimated.
The most common mistake is misunderstanding CRA applicability. Even if a company is not based in or does not have a physical office in Europe, it is still subject to the CRA and bears all associated risks if compliance is not achieved.
Incomplete technical documentation is another frequent issue. Security controls may exist, but if they are not properly documented, demonstrating compliance becomes impossible.
Lack of a structured vulnerability disclosure process is also a common pitfall. The CRA requires formal procedures for handling and reporting vulnerabilities—ad hoc fixes are not sufficient.
👉 Avoid CRA compliance risks — consult with our expert by using the contact form or us at management@mutekigroup.com
Muteki Group — CRA Consulting Service
We help companies achieve CRA compliance without disrupting business or losing access to the EU market.
Our services include:
auditing and assessing CRA applicability;
analyzing gaps in security and documentation;
developing a practical compliance roadmap;
supporting secure development and technical implementations;
training engineering, product, and management teams.
We offer both CRA certification and standalone services.
Our strengths lie in a track record of successful projects, a diverse team of experts, and constant tracking of EU regulatory updates. We fluently speak both the language of regulators and engineers — and know how to connect these perspectives smoothly, without extra bureaucracy or delays.
Don’t wait until the last minute to prepare for CRA.
Start taking action today—confidently with Muteki Group!
Contact us for a CRA consultation
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