Implementing EU Cyber Resilience Act compliance

CRA Consulting: Cyber Resilience Act

The EU Cyber Resilience Act (Regulation (EU) 2024/2847) imposes binding cybersecurity standards on all manufacturers, importers, and distributors of products with digital elements.

  • 01Early compliance with CRA requirements ahead of the 2026/2027 deadlines
  • 02Secure-by-Design integration into your product development
  • 03Development of a complete Software Bill of Materials (SBOM)
  • 04Competitive advantage through demonstrable product security
11+Years of experience
120+Employees
540+Projects
ISO 27001certified

What the Cyber Resilience Act means for your organisation

The Cyber Resilience Act affects all products with digital elements on the EU market, from IoT sensors and smart home devices to firewalls and operating systems, through to mobile apps and SaaS platforms. The regulation distinguishes four product classes with different conformity requirements: standard products (self-assessment by the manufacturer is sufficient), important products Class I (e.g. password managers, VPN software, network management, self-assessment or third-party review against a harmonised standard), important products Class II (e.g. firewalls, hypervisors, IDS/IPS systems, mandatory third-party review by a notified body), and critical products (e.g. smart meter gateways, hardware security modules, EU certification required).

Our expert consultants provide comprehensive cra consulting services tailored to your organization's specific needs. We combine deep regulatory expertise with practical implementation experience to deliver measurable results.

6 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

CRA Gap Analysis & Product Classification

Systematic assessment of your product portfolio against all requirements of CRA Annexes I and II. We classify each product into the correct category (Standard, Important Class I/II, Critical), identify the applicable conformity assessment procedures, and deliver a prioritised measures roadmap with concrete work packages, responsibilities, and a timeline through to December 2027. Deliverable: gap report with product classification matrix and compliance roadmap.

02

SBOM Implementation & Vulnerability Management

Development of a comprehensive Software Bill of Materials (SBOM) in machine-readable formats such as CycloneDX or SPDX. We integrate SBOM generation into your CI/CD pipeline, establish automated vulnerability matching against CVE databases, and implement the vulnerability handling process required by the CRA throughout the entire support period (typically 5 years). This means that in the next Log4Shell-type situation, you can identify which products are affected within minutes. Deliverable: SBOM toolchain, vulnerability management process, policy for free security updates.

03

Secure-by-Design & Secure-by-Default Consulting

Integration of cybersecurity from the concept phase of your product development, not as a retrospective add-on. We establish threat modelling (STRIDE/PASTA), define security requirements for your architecture, implement secure default configurations (no weak default passwords, automatic security updates, minimal attack surface), and embed security gates into your development process. Deliverable: Secure Development Lifecycle (SDL) framework, threat modelling documentation, security requirements catalogue.

04

Reporting Obligations & Incident Response (from September 2026)

From 11 September 2026, manufacturers must report actively exploited vulnerabilities to the competent CSIRT authority and ENISA within 24 hours, with a follow-up report within 72 hours and a final report within 14 days. We build your reporting process, define escalation paths, create report templates for the ENISA platform, and train your team through tabletop exercises. This ensures you are operationally ready by the deadline. Deliverable: incident response playbook, report templates, escalation matrix, training delivery.

05

Conformity Assessment & CE Marking

Preparation and support throughout the entire conformity assessment procedure, from self-assessment for standard products, to assessment against harmonised standards (EN 303 645, IEC 62443) for Class I products, through to collaboration with notified bodies for Class II and critical products. We prepare the technical documentation, the EU declaration of conformity, and support the CE marking process. Deliverable: technical documentation in accordance with Annex VII, EU declaration of conformity, CE marking approval.

06

CRA Training & Management Briefings

Tailored workshops for management, product management, development, and procurement. Content: CRA requirements in detail, product classification based on your specific product range, obligations by role (manufacturer, importer, distributor), penalty risks (up to €15 million / 2.5% of turnover), distinction from NIS2 and the EU AI Act, and concrete next steps. For SMEs, we offer compact formats that address the relief measures provided for small companies under the CRA. Deliverable: workshop delivery, management summary, individual action plan.

6 phases

Our Approach to CRA Implementation

We guide you in a structured manner from the current-state analysis to demonstrable conformity, tailored to your product landscape and maturity level.

  1. Scoping & Product Classification

    Identification of all products with digital elements in your portfolio and classification into CRA categories (Standard, Important Class I/II, Critical). Identification of the applicable conformity assessment procedures, self-assessment, assessment against harmonised standards, or third-party assessment by a notified body.

  2. Gap Analysis & Maturity Assessment

    Systematic comparison of your existing processes (development, vulnerability management, documentation, incident response) against the requirements of CRA Annexes I and II.

    prioritised gap list with effort estimates and quick wins.

  3. Compliance Roadmap

    Development of a binding implementation plan with milestones for September 2026 (reporting obligations) and December 2027 (full conformity). Definition of work packages, responsibilities, and budget framework, aligned with your product development cycle.

  4. Implementation

    Execution of identified measures, SBOM toolchain in the CI/CD pipeline, Secure Development Lifecycle, Vulnerability Disclosure Policy, reporting processes to ENISA/CSIRT, secure default configurations. Parallel creation of technical documentation in accordance with Annex VII.

  5. Internal Auditing & Conformity Assessment

    Conducting an internal pre-audit against all CRA requirements, remediation of identified findings, and support throughout the formal conformity assessment, as a self-assessment for standard products, and in collaboration with notified bodies for Class II and critical products.

  6. Ongoing Operations & Monitoring

    Establishment of continuous vulnerability management throughout the entire support period (standard: 5 years), regular SBOM updates, monitoring of new harmonised standards and CRA implementing acts, training of new staff. This ensures your CRA compliance remains secured even after initial conformity.

Sarah Richter

Your contact

Sarah Richter

Head of Information Security, Cyber Security

10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security

Why Choose ADVISORI?

  • 01Deep regulatory and industry expertise
  • 02Proven track record with leading organizations
  • 03Practical, implementation-focused approach
  • 04End-to-end support from assessment to implementation

Expert Consultation Available

Contact our specialists today for a personalized assessment of your requirements.

3 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about CRA Consulting: Cyber Resilience Act

Which products fall under the Cyber Resilience Act?

The CRA covers all products with digital elements placed on the EU market, hardware with network functions (smartphones, laptops, IoT sensors, smartwatches, connected toys, smart home devices, firewalls, smart meter gateways) and pure software products (operating systems, accounting software, mobile apps, computer games). The decisive factor is a direct or indirect network connection. Excluded are products already regulated elsewhere, such as medical devices (Medical Device Regulation), type-approved vehicles (UN ECE R155), defence products, and non-commercial open-source software. The CRA is product-based, not sector-based, traditional industrial companies or automotive suppliers may also be affected if they manufacture connected products or software components.

What product classes exist and what do they mean?

The CRA distinguishes four categories: Standard products (the large majority) require a self-assessment by the manufacturer. Important products Class I (e.g. password managers, VPN software, network management systems, browsers, SIEM systems) can be assessed via self-assessment against harmonised standards or through third-party review. Important products Class II (e.g. firewalls, IDS/IPS, hypervisors, operating systems, industrial control systems) mandatorily require assessment by a notified conformity assessment body. Critical products (e.g. smart meter gateways, hardware security modules, smart cards) require EU certification. The classification directly determines the effort and cost of the conformity assessment.

What deadlines apply under the CRA?

The CRA entered into force on 10 December 2024 (20 days after publication in the EU Official Journal on 20 November 2024). Implementation is phased: From 11 June 2026, conformity assessment bodies must be notified. From 11 September 2026, reporting obligations apply, manufacturers must report actively exploited vulnerabilities and significant security incidents to ENISA within 24 hours. From 11 December 2027, all products newly placed on the market must fully comply with all CRA requirements, including conformity assessment, technical documentation, SBOM, and CE marking. Products already on the market before this date are grandfathered, but only at the level of individual product units, not entire product lines.

Certificates, partners and more

ISO 9001 CertifiedISO 27001 CertifiedISO 14001 CertifiedBeyondTrust PartnerBVMW Bundesverband MitgliedMitigant PartnerGoogle PartnerTop 100 InnovatorMicrosoft AzureAmazon Web Services

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