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CRA GUIDE

EU CRA overview: timeline, core duties and product classes

The CRA (Regulation (EU) 2024/2847) sets cybersecurity requirements for "products with digital elements" sold on the EU market, covering design, updates, vulnerability handling and pre-market assessment. A product that connects directly or indirectly to another device or network is generally in scope, wherever its manufacturer is based.

Published 2026-11-122 min readFor hardware makers

01Key dates

Key dates--days until full application
2024-10-23Adopted and signed

The legislative process is complete.

2024-12-10Enters into force

The transition period starts.

2026-06-11Conformity bodies rules

Rules on conformity assessment bodies apply.

Today2026-09-11Reporting duties apply

Reporting of exploited vulnerabilities and severe incidents applies, including products already on the market.

2027-12-11Full application

Products must meet all requirements and conformity assessment.

Reporting applies 15 months before full compliance, and it also covers products already on the market.

02Four core duties

01

Secure by design

Secure-by-default configuration and a smaller attack surface, meeting the Annex I essential requirements.

02

Vulnerability handling and updates

Fix vulnerabilities and provide security updates through the support period, with a disclosure channel.

03

Conformity and technical file

Assessment by product class, a technical file, a declaration of conformity and CE marking.

Watchpost focus04

Vulnerability and incident reporting

For exploited vulnerabilities and severe incidents: 24-hour early warning, 72-hour notification, final report.

Chain of responsibility
Manufacturermain duties
›
Importerverifies
›
Distributorverifies
Authorised rep.per written mandate

03Product classes and assessment routes

DefaultDEFAULT

Most connected products

Module AMostly self-assessment (internal control)
Important ICLASS I

Operating systems, browsers, VPNs, password managers, routers, general-purpose smart home products

Self or third partySelf-assessment where a harmonised standard or certification scheme is applied, otherwise third-party involvement
Important IICLASS II

Hypervisors, firewalls, intrusion detection and prevention systems, tamper-resistant microprocessors

Notified bodyAssessment with a notified body
CriticalCRITICAL

Hardware devices with security boxes, smart meter gateways, smart cards

EUCCMay require European cybersecurity certification (such as EUCC)
lighter assessmentstricter assessment

Classification follows Article 7 and Annexes III and IV. Which class a given product falls in depends on the annexes and later implementing acts; confirm with your compliance adviser.

04Harmonised standards

Harmonised standards that turn Annex I into verifiable technical requirements are being developed in Europe. Until they are cited in the Official Journal, industry standards can be used for gap analysis; only full application of a harmonised standard gives a presumption of conformity. Follow the official publication status.

05A seven-step roadmap

  1. 1Scope and classIn scope? Which class? · free tool →
  2. 2Annex I gap analysisCheck essential requirements · free tool →
  3. 3Vulnerability and reportingAlready applies: first
  4. 4Assessment routeSelf, notified body or EUCC
  5. 5Technical fileDesign, tests, evidence
  6. 6Declaration and CESign, then market
  7. 7Post-market upkeepUpdates, reports, reassessment
Step 3 · already applies

Watchpost covers the reporting part

The other steps have until December 2027; reporting already applies. See the readiness checklist and the 24-hour reporting guide. Watchpost does not submit for you and does not provide certification, assessment or technical-file services.

  • Keeps watching exploited vulnerabilities against your products
  • Starts the 24-hour countdown on a hit and alerts owner and backup
  • Drafts the English report for each stage, to review and copy

?FAQ

When does the CRA apply?

It entered into force on 10 December 2024; reporting duties apply from 11 September 2026; full application is 11 December 2027.

Which products does the CRA cover?

Products with digital elements made available on the EU market, generally hardware and software that connects directly or indirectly to other devices or networks, regardless of where the manufacturer is based.

How many product classes does the CRA have?

Four: default, important class I, important class II and critical, each with a different conformity assessment route.

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This article summarises the public text of the EU Cyber Resilience Act (Regulation (EU) 2024/2847) for general information. It is not legal advice; rely on the regulation itself and your own counsel.