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For years, cybersecurity in connected products was often treated as something to improve after the product reached the market. Devices were designed, firmware was developed, cloud platforms were connected, and security improvements were sometimes postponed until vulnerabilities appeared.
That approach is becoming increasingly difficult to sustain.
The EU Cyber Resilience Act (CRA) introduces mandatory cybersecurity requirements for a broad range of products with digital elements sold in the European Union.
For IoT manufacturers, this represents more than another regulatory obligation. It changes how connected devices must be designed, developed, updated, and supported throughout their lifecycle.
In this article, we explore what the EU Cyber Resilience Act means, which products it affects, and how IoT companies can prepare without unnecessarily rebuilding their existing technology.
The EU Cyber Resilience Act is a European Union regulation establishing cybersecurity requirements for products with digital elements.
Formally known as Regulation (EU) 2024/2847, it aims to improve the cybersecurity of hardware and software products placed on the EU market.
Its central principle is straightforward:
Cybersecurity should be built into digital products from the beginning and maintained throughout their supported lifetime.
Previously, cybersecurity requirements for connected products varied across sectors and product categories.
The CRA introduces a broader regulatory framework that applies to many types of hardware and software.
Connected devices have become part of everyday life and critical business operations.
Smart home devices, industrial gateways, medical technologies, connected vehicles, and enterprise IoT platforms increasingly exchange information across networks.
However, these connected environments introduce security risks.
Common weaknesses include:
A vulnerability in one connected device can sometimes provide an entry point into a larger network.
The CRA addresses these risks by requiring manufacturers to consider cybersecurity throughout product development and maintenance.
The regulation focuses on several outcomes.
1. Secure products by design
Manufacturers must consider cybersecurity during product design and development rather than treating it as an optional feature.
2. Better vulnerability management
Manufacturers must establish processes for identifying, documenting, and addressing vulnerabilities.
3. Security updates throughout the support period
Products must have appropriate mechanisms for distributing security updates.
4. Greater transparency
Manufacturers must provide relevant security information, including details about the support period and how users can report vulnerabilities.
5. More consistent cybersecurity expectations
The CRA establishes a common framework for many digital products entering the EU market.
The practical takeaway is that cybersecurity becomes part of product conformity, alongside other applicable regulatory requirements.
The Cyber Resilience Act entered into force on December 10, 2024, but its obligations apply in stages.
Understanding this timeline is important for manufacturers planning product development and future releases.
December 10, 2024: Regulation enters into force
The CRA became part of EU law.
June 11, 2026: Conformity assessment body provisions
Certain provisions relating to notified conformity assessment bodies began applying.
September 11, 2026: Vulnerability reporting obligations
Manufacturers become subject to specified reporting requirements concerning actively exploited vulnerabilities and severe incidents affecting product security.
December 11, 2027: Main CRA requirements apply
The principal cybersecurity requirements become applicable to products within scope.
These dates are particularly relevant to manufacturers with long hardware development cycles.
A connected product being designed today may still be sold or introduced into the European market after the main requirements become applicable.
IoT products often involve several development layers:
Security improvements across these layers may require architectural changes.
For example, adding secure firmware updates to an existing device can involve changes to the bootloader, flash memory allocation, firmware signing process, and device recovery mechanism.
Such modifications become more expensive once hardware designs are finalized or products are deployed at scale.
The earlier manufacturers assess CRA requirements, the more flexibility they have to address security gaps through normal product development.
If your connected product is approaching commercialization, Infolitz can help assess security considerations across firmware, device connectivity, mobile applications, and cloud infrastructure.
The CRA generally applies to products with digital elements that are made available on the EU market and whose intended or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network.
This includes many connected hardware products and software applications.
Consumer IoT
Industrial IoT
Enterprise Technology
Software Products
The actual applicability depends on the product, how it is made available, and whether specific exclusions or sector-specific rules apply.
Certain regulated product categories are excluded from the CRA because they are subject to other applicable EU regulatory frameworks.
For example, medical devices covered by the EU Medical Device Regulation and in vitro diagnostic medical devices covered by the corresponding EU regulation are excluded.
Manufacturers should therefore evaluate their product classification rather than assuming that every connected product falls under identical CRA requirements.
Yes, potentially.
A manufacturer based in India, the United States, or another non-EU country may need to comply when placing an in-scope product on the EU market.
The regulation is not limited to manufacturers headquartered in Europe.
This matters for global IoT businesses developing devices for international customers.
A product designed and manufactured outside the EU may still need to satisfy CRA requirements before being placed on the European market.
One of the most important implications of the CRA is that cybersecurity cannot be addressed by protecting only one component.
Modern IoT systems consist of interconnected layers.
A typical architecture includes:
IoT Device → Communication Network → Cloud Platform → Mobile or Web Application
Each layer introduces potential vulnerabilities.
A secure cloud platform cannot compensate for a device that accepts unauthorized firmware updates.
Similarly, secure firmware does not eliminate risks caused by poorly protected cloud APIs.
Security begins at the device.
Manufacturers should evaluate:
Secure boot, for example, helps prevent unauthorized firmware from executing by verifying software integrity during startup.
For products with long deployment lifetimes, device-level protections are particularly important.
Firmware controls device behavior and communication.
Security weaknesses at this layer can expose the entire connected system.
Important practices include:
Firmware security should also account for operational conditions.
A device installed in a remote industrial facility may have intermittent connectivity.
Its update mechanism must account for interrupted downloads, power failures, and recovery scenarios.
IoT devices frequently communicate using protocols such as MQTT, HTTPS, BLE, and industrial communication standards.
Security considerations include:
The appropriate security mechanism depends on device capabilities, communication requirements, and deployment conditions.
Cloud platforms often manage thousands of connected devices.
A weakness in backend authorization or device management can affect an entire deployment.
Manufacturers should evaluate:
Mobile and web applications frequently provide user access to connected devices.
Their security must be considered as part of the overall product architecture.
Important controls include:
The key architectural lesson is that IoT cybersecurity must be evaluated across the complete connected product, not just the device firmware.
The CRA establishes essential cybersecurity requirements for products with digital elements.
These requirements address both product characteristics and manufacturers' vulnerability-handling processes.
Products must be designed, developed, and produced with cybersecurity in mind.
They must also be made available with secure default configurations.
For example, a connected gateway should not rely on a universal, publicly known administrator password.
Manufacturers should instead implement appropriate authentication and secure provisioning mechanisms.
Manufacturers must establish processes for identifying and addressing vulnerabilities.
These processes should cover:
Vulnerability management continues after the product reaches customers.
Manufacturers must provide appropriate mechanisms for addressing vulnerabilities through security updates.
For connected devices, this often means implementing secure over-the-air firmware updates.
A robust OTA system should support:
Automatic security updates may be required where applicable, subject to the regulation's conditions and product context.
A Software Bill of Materials (SBOM) is a structured inventory of software components used in a product.
It helps manufacturers identify third-party libraries and dependencies that may contain vulnerabilities.
For example, an IoT gateway might use:
If a vulnerability is discovered in one of these components, the SBOM helps identify affected products.
Under the CRA, manufacturers must identify and document product components and vulnerabilities, including by drawing up an SBOM in a commonly used, machine-readable format covering at least top-level dependencies.
The regulation does not generally require manufacturers to publish their complete SBOM publicly.
Manufacturers must assess cybersecurity risks associated with their products.
This includes considering intended use, reasonably foreseeable use, and the product's operating environment.
For example, a consumer temperature sensor and an industrial gateway controlling critical processes may face different risk scenarios.
Their security controls should reflect those differences.
Manufacturers must determine an appropriate support period during which vulnerabilities are handled.
The CRA generally establishes a minimum support period of five years, unless the product is expected to be used for a shorter period.
The support period must account for factors such as expected product lifetime and reasonable user expectations.
This has major implications for IoT manufacturers.
A device sold today may require security maintenance years after its original firmware development team has moved to other projects.
There is no single technology stack that automatically guarantees CRA compliance.
Compliance depends on product-specific risks, technical controls, documentation, development processes, and conformity assessment.
However, certain technologies can help manufacturers implement relevant security capabilities.
Potential technologies include:
Hardware security features can strengthen device protection, but they may increase component costs and development complexity.
Manufacturers should select controls based on the product's risk profile.
Common practices include:
Automating these checks can help identify vulnerabilities earlier in development.
Cloud platforms can support:
Platforms such as AWS IoT and Azure IoT provide capabilities that can support secure device management.
However, using a major cloud provider does not automatically make a connected product CRA-compliant.
Manufacturers remain responsible for evaluating their overall product and applicable obligations.
Tools such as Syft, Trivy, and Dependency-Track can support software component visibility and vulnerability monitoring.
Their capabilities differ.
For example:
These tools are useful building blocks, but they do not replace cybersecurity risk assessment or regulatory documentation.
Preparing for the EU Cyber Resilience Act should begin with a structured assessment.
The goal is to identify meaningful security gaps and prioritize improvements.
Identify whether the product falls within the CRA's scope.
Consider:
Document all relevant components.
Include:
This helps reveal dependencies and potential attack surfaces.
Identify realistic threats and their potential consequences.
Examples include unauthorized device access, credential compromise, firmware manipulation, and cloud API misuse.
Prioritize controls according to risk.
Assess whether the product has appropriate protections.
A practical checklist includes:
Define how vulnerabilities will be discovered, assessed, corrected, and communicated.
Assign clear responsibilities.
For example, firmware developers may own device-level fixes, while cloud engineers handle backend vulnerabilities.
Someone must also coordinate product-level impact assessment.
Evaluate whether deployed products can receive security fixes reliably.
For devices without existing OTA capabilities, this may require significant architectural planning.
The CRA requires manufacturers to maintain relevant technical documentation.
Depending on the product, this may include:
Determine the appropriate conformity assessment route for the product.
Some product categories may require involvement from a notified conformity assessment body.
Where applicable, successful conformity assessment supports the EU declaration of conformity and CE marking requirements.
A structured readiness assessment is usually more effective than adding isolated security features without understanding the complete product risk.
For organizations developing connected products, Infolitz supports security-focused engineering across embedded firmware, cloud platforms, mobile applications, and device management systems.
Cybersecurity improvements often introduce engineering trade-offs.
Manufacturers must balance protection, performance, cost, and maintainability.
Many IoT devices use microcontrollers with limited memory and processing power.
Cryptographic operations, secure storage, and firmware verification may consume additional resources.
For example, adding firmware signature verification may require changes to bootloader memory allocation.
Security requirements should therefore be considered during hardware selection.
Secure OTA capabilities require more than uploading firmware to a server.
Manufacturers may need:
These capabilities introduce development and operational costs.
However, they can also reduce the need for physical device servicing.
The cost of IoT security extends beyond initial development.
Manufacturers need processes for:
A product designed for a long operational lifetime should account for these responsibilities from the beginning.
Stronger security controls can increase processing requirements, network traffic, and energy consumption.
Battery-powered devices may require particularly careful optimization.
The objective is not to implement every available security mechanism.
It is to implement controls appropriate to the product's risks while maintaining acceptable performance.
Consider a manufacturer developing an industrial IoT gateway for remote equipment monitoring.
The gateway collects sensor data, communicates with cloud services, and allows remote configuration.
The initial product architecture includes:
The product performs its intended monitoring functions.
However, the manufacturer has limited visibility into third-party software vulnerabilities.
Firmware updates require manual intervention.
Device credentials are provisioned through a process that has not been formally assessed for security risks.
As the company prepares to expand into the European market, it must evaluate whether its product can meet applicable CRA requirements.
The engineering team identifies several areas requiring attention:
The manufacturer redesigns selected security components.
The updated architecture includes:
Secure firmware validation
The device verifies firmware authenticity before execution.
Improved device identity
Each gateway receives appropriately protected credentials.
Secure OTA updates
Firmware can be distributed remotely using authenticated and integrity-protected update mechanisms.
Software component visibility
An SBOM helps identify vulnerable dependencies.
Centralized device management
The cloud platform maintains device software versions and relevant operational information.
Defined vulnerability response
The manufacturer establishes procedures for assessing and correcting security issues.
Previously, a firmware vulnerability might require engineers to identify affected devices manually and coordinate on-site updates.
With improved device management and OTA infrastructure, the manufacturer can identify relevant firmware versions and distribute tested fixes remotely.
The organization also gains better visibility into the software components used across its products.
This is an illustrative engineering scenario, not a documented customer implementation or a claim of achieved CRA certification.
The important lesson is that cybersecurity improvements can strengthen both regulatory readiness and day-to-day product operations.
Many manufacturers already follow cybersecurity standards and industry frameworks.
The CRA does not eliminate the value of those practices.
Instead, it introduces legally enforceable requirements for products within its scope.
ETSI EN 303 645 provides cybersecurity provisions for consumer IoT products.
It addresses topics such as password security, vulnerability disclosure, and software updates.
The CRA is broader in scope and establishes mandatory regulatory obligations.
Existing alignment with ETSI EN 303 645 may support certain security practices, but it does not automatically establish CRA compliance.
IEC 62443 is a family of standards addressing cybersecurity in industrial automation and control systems.
It includes requirements relevant to industrial components and secure development processes.
For industrial IoT manufacturers, IEC 62443 practices can provide a useful foundation.
However, manufacturers must still evaluate the CRA's specific legal and documentation requirements.
The CRA and NIS2 address different aspects of cybersecurity.
The CRA primarily focuses on products with digital elements and related manufacturer obligations.
NIS2 focuses on cybersecurity risk management and incident reporting obligations for covered entities in specified sectors.
An organization may be affected by both frameworks, depending on its products and business activities.
A secure cloud platform does not eliminate vulnerabilities in device firmware or local interfaces.
Security must cover the complete product.
Documentation is important, but it cannot replace effective technical controls.
Manufacturers need evidence that relevant security requirements have been addressed.
Many IoT products rely heavily on open-source libraries and external components.
Without software component visibility, manufacturers may struggle to identify affected products when vulnerabilities emerge.
Adding secure firmware updates late in development can require substantial changes.
Update capabilities should be evaluated during initial architecture design.
Security responsibilities continue after deployment.
Manufacturers must plan for vulnerability monitoring, updates, and support throughout the applicable support period.
Existing security certifications and standards can provide useful evidence.
However, manufacturers must still determine whether they satisfy the CRA's applicable requirements and conformity assessment obligations.
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The EU Cyber Resilience Act is Regulation (EU) 2024/2847, which establishes cybersecurity requirements for many hardware and software products with digital elements made available on the European Union market.
The main requirements apply from December 11, 2027. Certain obligations, including specified vulnerability and incident reporting requirements, apply earlier, from September 11, 2026.
Yes. Many connected devices fall within its scope, including smart home products, industrial gateways, connected controllers, and other products with digital elements. Specific exclusions and regulatory conditions must be considered.
Yes. Manufacturers located outside the European Union may be subject to CRA obligations when placing covered products on the EU market.
The CRA requires manufacturers to identify and document product components and vulnerabilities, including by drawing up a machine-readable SBOM covering at least top-level dependencies. The complete SBOM does not generally need to be publicly disclosed.
The CRA requires appropriate mechanisms for addressing vulnerabilities through security updates. For many connected devices, secure firmware update capabilities will be an important part of meeting those requirements.
The CRA generally requires a support period of at least five years, unless the product is expected to be used for less than five years. Manufacturers must consider relevant factors when determining the appropriate period.
Yes. Products within scope must follow the applicable conformity assessment requirements, and CE marking is part of the regulatory framework. The assessment procedure depends on product classification and other relevant conditions.
For certain violations of essential cybersecurity requirements, the CRA provides for administrative fines of up to €15 million or 2.5% of total worldwide annual turnover, whichever is higher. Different limits apply to other categories of violations.
Manufacturers should begin by determining product applicability, reviewing architecture, conducting cybersecurity risk assessments, implementing appropriate security controls, establishing vulnerability management processes, and preparing the required documentation and conformity assessment strategy.
In the connected world, security is no longer a feature you add before launch. It is a responsibility you carry throughout the product's lifetime
The EU Cyber Resilience Act is reshaping expectations for connected products entering the European market. For IoT manufacturers, preparing early means evaluating security across hardware, firmware, connectivity, cloud infrastructure, and ongoing product support.
Infolitz Software helps organizations design, develop, modernize, and maintain connected technology solutions across embedded systems, mobile applications, and cloud platforms.
Developing an IoT product or reviewing an existing connected platform? Contact Infolitz to discuss your architecture, security engineering priorities, and product readiness.