Cyber Resilience Act: what you must do if you make software.

Who it applies to

The regulation says «products with digital elements», which is broader than it sounds. If you sell in Europe, it most likely covers you.

• Software sold as a product, licensed or subscribed, whether it runs in the cloud or on customer premises.
• Firmware and embedded software: if the product has a microcontroller and a connection, it is in scope.
• Software components sold to other manufacturers who integrate them.
• Importers and distributors carry their own obligations, not just the original manufacturer.
• Sectors already covered by their own regulations — medical devices, automotive, aviation — stay outside.

The dates that matter

Two distinct deadlines, and the first one catches out anyone who only looked at the last.

What you must actually produce

The regulation does not ask for good intentions: it asks for documents and processes someone can come and read.

Cybersecurity risk assessment

Documented, product-specific, and maintained across the support period. It belongs in the technical documentation.

Software bill of materials (SBOM)

Your dependencies, at least top level, in machine-readable form. It is also how you know whether a new vulnerability concerns you.

Vulnerability handling

A process that finds, triages and fixes without undue delay, and a channel through which anyone can report to you.

Security updates

Free and timely for the whole declared support period, which must be declared and cannot be shorter than the product’s expected life.

Technical documentation

The file that demonstrates conformity with the essential requirements, kept current and retained for ten years.

EU declaration of conformity and CE marking

Yes, CE marking applies to software too. This is the step that surprises almost everyone.

Reporting within 24 hours

For an actively exploited vulnerability or severe incident: first notification within 24 hours to the relevant CSIRT and ENISA. This is the obligation that starts first.

Four beliefs that cost money

We meet them regularly, and they all come from a partial reading of the regulation.

Where to start

If you have done nothing yet, this order reduces risk fastest.

1. Establish which of your products are in scope, and who the manufacturer is for each under the regulation.
2. Generate the SBOM for those products. Without it, every later step is guesswork.
3. Open a public vulnerability reporting channel and write the internal procedure behind it.
4. Declare the support period per product and check you can honour it.
5. Start collecting evidence in technical-documentation format from the next release onwards.