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CRA's first obligation takes effect

Regulation (EU) 2024/2847

Cyber Resilience Act the new European standard for IoT

The CRA is the first horizontal EU regulation mandating that all products with digital elements meet cybersecurity requirements from design to post-sale lifecycle. It entered into force on December 10, 2024; reporting obligations begin September 11, 2026, and full compliance is required by December 11, 2027.

September 11, 2026 — Article 14 Reporting

GÜN
——SAAT
——DK
——SN

Full Compliance

11.12.2027

Max Penalty

€15M / 2.5%

Standard

EN 18031

Authority

ENISA

Article 14

Three-tier mandatory reporting cycle

Active exploitation detection triggers a three-phase notification process starting with a 24-hour early warning to the ENISA Single Reporting Platform and extending up to 14 days.

Phase 01T+0

Vulnerability Detected

TegmenSoft telemetry engine detects active in-the-wild exploitation and scores severity.

Phase 02T+≤ 24h

Early Warning

An early warning notification including affected member states is automatically sent to ENISA SRP.

Phase 03T+≤ 72h

Full Notification

A full report including exploitation details, affected product lines, and mitigation steps is submitted.

Phase 04T+≤ 14d

Final Report

After corrective measures are published, vulnerability disclosure, CVSS and security update details are reported.

Obligations

Five core competencies every manufacturer must have

The CRA forces manufacturers to restructure not just in reporting, but also in design, documentation, and lifecycle management.

Secure by Design

Products must meet security requirements from the design phase. Default settings must be secure with unpredictable passwords.

CE Marking

CRA-scoped products can only bear the CE mark and be placed on the EU market after conformity assessment is completed.

SBOM Obligation

Manufacturers must document all software components (SPDX/CycloneDX) used in the product and present them upon request.

Support Period

Products' support period must be clearly declared, and security updates must be provided free of charge during this period.

Market Surveillance

Member state authorities have the power to withdraw non-compliant products from the market, impose bans, and issue penalties.

Timeline

CRA enforcement process and critical milestones

The official Cyber Resilience Act timeline and what each phase means for manufacturers.

December 10, 2024

Entry into Force

Cyber Resilience Act (Regulation (EU) 2024/2847) published in the EU Official Journal and entered into force.

January 2025

Standardization Request

European Commission submitted a formal request to CEN-CENELEC for the development of harmonized standards.

September 11, 2026

Reporting Obligation Begins

24-hour ENISA SRP notification requirement for actively exploited vulnerabilities becomes legally binding.

November 2026

Harmonized Standards

EN 18031 family and other harmonized standards are published; compliance path clarifies for manufacturers.

December 11, 2027

Full Compliance

CRA requirements and CE marking obligations become fully mandatory for all products with digital elements.

Breaking Point: 11.09.2026 from this date, reporting actively exploited vulnerabilities to ENISA SRP within 24 hours becomes a legal prerequisite. Manual processes cannot meet this threshold — automation is mandatory.

Risk Classification

Same SDK for every risk class, different audit depth

The CRA divides products into four risk classes. While audit intensity varies, SBOM, vulnerability reporting, and secure OTA are common technical requirements across all classes.

DEFAULT

Default

Example

Smart home devices, consumer IoT, smart toys

Audit

Self-assessment (Module A) sufficient

IMPORTANT

Important — Class I

Example

Authentication systems, VPNs, network management tools

Audit

Notified Body involvement may be required

IMPORTANT

Important — Class II

Example

Industrial firewalls, operating systems, microprocessors

Audit

Third-party examination (Type Examination) mandatory

CRITICAL

Critical

Example

Smart meters, HSM modules, smart cards, health hardware

Audit

Full authorized audit under EUCC

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CRA Compliance — Cyber Resilience Act · TegmenSoft