Does the CRA Apply to WordPress Plugins?

Short answer: Yes, if you sell or commercially distribute WordPress plugins, themes, or extensions in the European Union.

The EU Cyber Resilience Act applies to "products with digital elements" placed on the EU market. WordPress plugins, themes, and WooCommerce extensions clearly fall under this definition as software products. Whether you sell through your own website, the WordPress.org repository, CodeCanyon, or any other marketplace, if your products reach EU customers through commercial activity, the CRA applies.

Which WordPress Products Are Affected?

Let's break down exactly which WordPress products fall under CRA requirements:

Definitely Covered

• Premium WordPress plugins sold for a fee (one-time or subscription)
• Commercial WordPress themes distributed for profit
• WooCommerce extensions and add-ons sold commercially
• Freemium plugins with paid upgrade options or upsells
• Plugin/theme bundles sold as commercial packages
• SaaS platforms built on WordPress infrastructure
• White-label products licensed to agencies or resellers

Gray Areas Requiring Analysis

• Donation-supported plugins: If donations are solicited as part of distribution, this may constitute commercial activity
• Sponsored open source development: Corporate-sponsored plugin development may fall under CRA if tied to commercial interests
• Service-bundled plugins: Plugins distributed free but bundled with paid services (hosting, support, consulting)
• Dual-licensed products: Plugins available both as free open source and commercial versions

Generally Excluded

• Purely non-commercial open source: Plugins developed and distributed entirely outside commercial context by volunteers
• Internal corporate plugins: Plugins developed solely for internal use, never distributed externally
• Educational/research projects: Plugins created purely for educational purposes without commercial distribution

Free vs. Commercial Plugins: The Critical Distinction

This is perhaps the most confusing aspect of the CRA for WordPress developers. Let's clarify:

Free Plugins on WordPress.org

If you distribute a plugin exclusively through WordPress.org repository with no commercial component (no premium version, no paid add-ons, no support fees), and you develop it purely as a volunteer without commercial backing, the plugin likely falls under the open source exception.

However, this exclusion is narrow. If any of the following apply, the CRA likely covers your plugin:

• You offer a "Pro" or "Premium" version with paid features
• The free plugin is a limited version meant to drive paid upgrades
• You sell related products, services, or support
• Your employer or client sponsors the development
• You accept donations through the plugin or WordPress.org page
• The plugin includes affiliate links or monetization

Freemium Model (Most Common)

The freemium model—free core plugin with paid extensions or features—is explicitly subject to the CRA. Both the free and paid components are considered part of a commercial distribution strategy and therefore covered by the regulation.

Example: If you offer a free contact form plugin on WordPress.org but sell premium add-ons for integrations, both the free plugin and paid add-ons must comply with the CRA.

Premium-Only Plugins

Plugins sold exclusively as paid products (whether through your website, marketplaces, or other channels) are unambiguously covered by the CRA with no exceptions or special considerations.

GPL Licensing and CRA Compliance

A common misconception is that GPL licensing affects CRA applicability. It doesn't—at least not in the way many developers think.

Why GPL Doesn't Exempt You

WordPress requires plugins distributed through its official repository to be GPL-compatible. Many developers assume this open source licensing provides protection from regulations like the CRA. This is incorrect.

The CRA cares about commercial activity, not licensing terms. A GPL-licensed plugin sold commercially is still a commercial product subject to the CRA. The GPL dictates redistribution rights; the CRA dictates security requirements. These are separate concerns.

GPL License Text Example

/**
 * Plugin Name: Example Security Plugin
 * Description: Demonstrates CRA-compliant plugin with GPL license
 * Version: 1.0.0
 * License: GPL v2 or later
 * License URI: https://www.gnu.org/licenses/gpl-2.0.html
 *
 * CRA Compliance Information:
 * SBOM: https://example.com/sbom/example-plugin-1.0.0.json
 * Security Contact: security@example.com
 * Support Period: 24 months from release
 * Vulnerability Disclosure: https://example.com/security
 */

Notice how GPL licensing and CRA compliance information coexist. They address different aspects of software distribution.

What GPL Does Mean for CRA

While GPL doesn't exempt you from the CRA, it does affect how you implement certain requirements:

• Transparency: GPL's source code requirement aligns well with CRA transparency obligations
• Security updates: GPL allows users to apply their own patches, but this doesn't eliminate your obligation to provide updates
• Component tracking: GPL compatibility requirements help ensure your SBOM accurately reflects third-party components
• Derivative works: If users create derivatives under GPL, they may assume their own CRA obligations for those versions

Practical Steps for WordPress Plugin Developers

Now that we understand applicability, let's discuss concrete actions you need to take for CRA compliance:

Step 1: Assess Your Products

Create an inventory of all your WordPress products and determine which require CRA compliance:

/**
 * CRA Product Assessment
 *
 * Product: WooCommerce Advanced Shipping
 * Distribution: CodeCanyon + Own Website
 * Pricing: €49 one-time + €15/year updates
 * CRA Applicable: YES (commercial product)
 * Risk Classification: Standard (self-assessment allowed)
 * Priority: High (100+ active EU customers)
 */

Step 2: Implement Secure Development Practices

Adopt secure coding standards specific to WordPress development:

• Input validation: Use WordPress sanitization functions (sanitize_text_field(), wp_kses(), etc.)
• Output escaping: Always escape output (esc_html(), esc_attr(), esc_url())
• SQL injection prevention: Use $wpdb->prepare() for all database queries
• Nonce verification: Implement nonces for all forms and AJAX requests
• Capability checks: Verify user permissions before sensitive operations
• CSRF protection: Use WordPress nonce system for state-changing operations

Step 3: Generate Software Bill of Materials (SBOM)

Document all components and dependencies in your plugin:

{
  "bomFormat": "CycloneDX",
  "specVersion": "1.4",
  "metadata": {
    "component": {
      "name": "example-wordpress-plugin",
      "version": "2.1.0",
      "type": "application"
    }
  },
  "components": [
    {
      "name": "guzzlehttp/guzzle",
      "version": "7.5.0",
      "type": "library",
      "licenses": ["MIT"]
    },
    {
      "name": "firebase/php-jwt",
      "version": "6.3.0",
      "type": "library",
      "licenses": ["BSD-3-Clause"]
    }
  ]
}

CRA Compliance Suite can automatically generate SBOMs from your composer.json, package.json, and plugin dependencies.

Step 4: Establish Vulnerability Management

Create processes for handling security vulnerabilities:

• Security policy: Document how users report vulnerabilities (create SECURITY.md)
• Response timeline: Commit to addressing critical vulnerabilities within 24 hours
• Update distribution: Ensure security updates reach all users promptly
• Version control: Maintain security update history and changelogs

Step 5: Document Security Information

Provide clear security information to users:

/**
 * Security Information (per CRA requirements)
 *
 * Security Contact: security@example.com
 * Vulnerability Disclosure: https://example.com/security-policy
 * Support Period: 24 months from release date
 * Security Updates: Provided for all major versions for support period
 * SBOM: Available at https://example.com/sbom/[plugin-name]-[version].json
 *
 * Last Security Audit: 2025-09-15
 * Known Vulnerabilities: None
 * Dependencies Security Status: All dependencies audited and up-to-date
 */

Step 6: Create Conformity Documentation

Prepare technical documentation demonstrating CRA compliance:

• Security architecture documentation
• Risk assessment and mitigation measures
• Vulnerability testing results
• SBOM and dependency analysis
• Security update procedures
• EU Declaration of Conformity

Common Misconceptions Addressed

Misconception #1: "WordPress.org approval means I'm compliant"

Reality: WordPress.org code review checks for basic security issues and guideline compliance, but it does not verify CRA requirements like SBOM generation, conformity documentation, or incident reporting procedures. WordPress.org approval is necessary but not sufficient for CRA compliance.

Misconception #2: "Small plugins don't need to comply"

Reality: The CRA applies to all products with digital elements placed on the EU market, regardless of size. Even a simple plugin with 100 lines of code must meet essential requirements if distributed commercially. However, the proportionality principle means compliance efforts should be proportionate to risk and complexity.

Misconception #3: "I can claim it's open source and avoid CRA"

Reality: The open source exception only applies to development and distribution genuinely conducted outside commercial context. You cannot simply label a commercial product "open source" to avoid regulation. EU authorities will look at the actual commercial activity, not just licensing labels.

Misconception #4: "The CRA only applies to EU-based developers"

Reality: The CRA applies to all products placed on the EU market, regardless of where the developer is located. If you're based in the US, Australia, or anywhere else but sell to EU customers, the CRA applies to those sales.

Misconception #5: "I can wait until 2027 to start thinking about this"

Reality: While enforcement begins in 2026-2027, implementing the necessary changes to your development processes, documentation, and systems takes substantial time. Starting now ensures you'll be ready and avoids a last-minute scramble.

WordPress-Specific CRA Challenges

Challenge #1: WordPress Core Updates

WordPress releases frequent core updates, sometimes introducing breaking changes. Your CRA obligations include ensuring compatibility and addressing any security implications of WordPress updates that affect your plugin.

Solution: Establish testing procedures for WordPress core updates and commit to compatibility updates within your documented support period.

Challenge #2: Third-Party Dependencies

Many WordPress plugins rely on third-party libraries via Composer or npm. You're responsible for security vulnerabilities in these dependencies.

Solution: Regularly audit dependencies, keep them updated, and document them in your SBOM. Use automated tools to monitor for known vulnerabilities.

Challenge #3: Plugin Interoperability

WordPress plugins often interact with other plugins, creating complex dependencies. A vulnerability in another plugin could affect your plugin's security.

Solution: Document known interoperability and recommended compatible plugins. Clearly define your plugin's security boundary and responsibilities.

Challenge #4: Update Distribution

Ensuring all users receive security updates promptly is challenging, especially for self-hosted WordPress installations where users control update schedules.

Solution: Implement in-dashboard update notifications, email alerts for critical security updates, and clear communication about the importance of updating. Consider requiring recent versions for support.

CRA Compliance Checklist for WordPress Developers

How CRA Compliance Suite Helps WordPress Developers

CRA Compliance Suite is specifically designed to simplify CRA compliance for WordPress plugin developers:

• Automatic SBOM generation: Upload your plugin ZIP and instantly get a complete SBOM including all dependencies
• WordPress-specific vulnerability scanning: Check for common WordPress security issues (SQL injection, XSS, CSRF, etc.)
• Dependency monitoring: Track Composer and npm dependencies for known vulnerabilities
• Compliance documentation: Generate conformity documentation templates customized for WordPress plugins
• Update tracking: Monitor security update requirements and support period obligations
• Batch processing: Analyze multiple plugins or versions simultaneously

Conclusion: Compliance as Competitive Advantage

While the CRA introduces new obligations for WordPress plugin developers, it also creates an opportunity to differentiate your products in the marketplace. Demonstrating robust security practices, transparent vulnerability management, and comprehensive compliance builds customer trust and positions your plugins as professional, enterprise-ready solutions.

Start your CRA compliance journey today. The developers who begin early will have a significant advantage over those who wait until enforcement deadlines approach.

Remember: compliance isn't just about avoiding penalties—it's about building better, more secure software that earns customer trust and stands out in a crowded marketplace.