Introduction: A New Era of Software Regulation

The EU Cyber Resilience Act (CRA) represents the most significant change to software regulation in European history. Formally proposed in September 2022 and expected to enter into force in 2024-2025, this regulation establishes mandatory cybersecurity requirements for products with digital elements sold in the European Union.

Unlike traditional software regulations that focused primarily on data protection or privacy, the CRA introduces comprehensive security requirements throughout the entire product lifecycle—from design and development through distribution, maintenance, and end-of-life. For software developers, manufacturers, and distributors, understanding the CRA is no longer optional; it's essential for continuing to operate in the EU market.

Why Was the CRA Created?

The European Union created the Cyber Resilience Act in response to several pressing cybersecurity challenges facing consumers and businesses across Europe:

1. Increasing Cyber Threats

Cyberattacks have grown exponentially in recent years, with the EU experiencing millions of cyber incidents annually. From ransomware targeting critical infrastructure to supply chain attacks affecting thousands of businesses, the digital threat landscape has never been more dangerous. Many of these attacks exploit known vulnerabilities in software products that manufacturers failed to address.

2. Lack of Security Standards

Before the CRA, there were no harmonized cybersecurity requirements for software products across the EU. Manufacturers could release products with minimal security features, no vulnerability management processes, and no obligation to provide security updates. This created a fragmented market where security quality varied wildly between products and vendors.

3. Consumer Protection Gap

European consumers and businesses had no reliable way to assess the security quality of products before purchase. There was no standardized security information, no guarantee of security updates, and limited recourse when products shipped with serious vulnerabilities. The CRA addresses this by mandating transparency and accountability throughout the product lifecycle.

4. Supply Chain Vulnerabilities

Modern software relies on complex supply chains with numerous third-party components, libraries, and dependencies. High-profile attacks like Log4Shell demonstrated how a vulnerability in a single component can impact millions of products worldwide. The CRA's requirements for Software Bill of Materials (SBOM) and supply chain security directly address this challenge.

Scope and Applicability: What Products Are Covered?

The CRA applies to "products with digital elements," which is broadly defined to include:

• Software products: Applications, plugins, extensions, themes, and standalone software
• Hardware with digital elements: IoT devices, smart home products, industrial equipment
• Remote data processing solutions: Cloud services, SaaS platforms, web applications
• Software components: Libraries, frameworks, and modules integrated into other products

Critical vs. Non-Critical Products

The CRA categorizes products into different classes based on risk level, with varying requirements:

• Critical Products (Class I and II): Identity management systems, network equipment, operating systems, and other high-risk products face stricter requirements including mandatory third-party conformity assessment
• Important Products: Password managers, VPNs, antivirus software, and similar security-focused products with enhanced obligations
• Standard Products: Most software products, including WordPress plugins and themes, fall into this category with self-assessment allowed

What's Excluded?

Certain products and situations are explicitly excluded from the CRA:

• Medical devices covered by existing medical device regulations
• Aviation products covered by aviation safety regulations
• Motor vehicles covered by automotive type-approval regulations
• Open source software developed outside commercial activity (with important nuances—see our detailed article on this topic)

Timeline and Key Deadlines

Understanding the CRA timeline is critical for planning your compliance strategy:

Phase 1: Regulation Adoption and Transition

• September 2022: CRA proposed by European Commission
• 2024: Expected final adoption by European Parliament and Council
• 2024-2025: 24-month transition period begins after publication in Official Journal

Phase 2: Enforcement Begins

• 2026-2027: CRA becomes fully applicable (exact date depends on final adoption date)
• Day 1 of enforcement: All products placed on the market must comply with essential requirements
• Ongoing: Continuous obligations for vulnerability management, security updates, and incident reporting

Products already on the market before the enforcement date may continue to be sold during a limited grace period, but security update obligations apply to all products, regardless of when they were first introduced.

Key Requirements Overview

The CRA establishes several categories of requirements that manufacturers must meet:

1. Secure by Design and Default

Products must be designed and developed with security as a fundamental consideration from the outset. This includes:

• Implementing appropriate technical and organizational measures during development
• Following secure coding practices and security development lifecycle principles
• Protecting against known vulnerabilities and attack patterns
• Minimizing attack surface and limiting unnecessary features
• Ensuring products are configured securely by default (no weak default passwords, unnecessary services disabled, etc.)

2. Vulnerability Management and Handling

Manufacturers must establish and maintain processes for:

• Identifying and documenting vulnerabilities in products and components
• Addressing vulnerabilities in a timely manner (24 hours for actively exploited critical vulnerabilities)
• Providing security updates throughout the product's support period
• Implementing a coordinated vulnerability disclosure program
• Reporting serious incidents and actively exploited vulnerabilities to ENISA (EU cybersecurity agency)

3. Transparency and Documentation

The CRA mandates extensive documentation and transparency requirements:

• Software Bill of Materials (SBOM): A comprehensive inventory of all components and dependencies
• Instructions for secure use: Clear guidance on secure installation, configuration, and operation
• Security information: Contact details for reporting vulnerabilities, expected support period, etc.
• Technical documentation: Detailed security documentation for conformity assessment
• EU Declaration of Conformity: Formal declaration that the product meets all essential requirements

4. Incident Response and Reporting

Manufacturers must report certain cybersecurity incidents to authorities:

• Within 24 hours: Early warning of actively exploited vulnerabilities or severe incidents
• Within 72 hours: Detailed incident report with impact assessment
• Within 14 days: Final report including remediation measures

5. Conformity Assessment

Before placing products on the market, manufacturers must:

• Conduct risk assessment and cybersecurity testing
• Verify compliance with essential requirements
• Create and maintain technical documentation
• For critical products: Undergo third-party conformity assessment by notified body
• Affix CE marking to compliant products

Impact on the Software Industry

The CRA will have far-reaching consequences for the software industry:

For Small and Medium Developers

SMEs and individual developers face significant new compliance burdens. Creating SBOMs, establishing vulnerability management processes, and maintaining comprehensive documentation requires time and resources that smaller organizations may struggle to allocate. However, the regulation does provide some flexibility for micro-enterprises and recognizes proportionality in enforcement.

For Enterprise Software Vendors

Large software companies will need to transform their development practices, implement robust security programs, and establish comprehensive compliance frameworks. The investment required is substantial, but many enterprises already have foundations in place through existing security programs and regulatory compliance efforts.

For Open Source Ecosystems

The CRA creates complex implications for open source software. While non-commercial open source development is generally excluded, commercial distributions of open source software are covered. This affects WordPress plugin developers, Linux distributors, and anyone who monetizes open source software in the EU market.

Market Consolidation Risks

Some industry observers worry the CRA could lead to market consolidation, with smaller players unable to bear compliance costs. The European Commission has emphasized support for SMEs through guidance, tools, and potentially simplified procedures for low-risk products.

Global Impact

Like GDPR before it, the CRA is expected to influence cybersecurity regulation globally. Software vendors serving international markets may adopt CRA-compliant practices worldwide rather than maintaining separate processes for EU products. This "Brussels Effect" could raise security standards globally.

What This Means for WordPress Developers

If you develop WordPress plugins, themes, or WooCommerce extensions sold in the EU, the CRA likely applies to your products. You'll need to:

• Implement secure coding practices and security testing throughout development
• Generate and maintain SBOMs for your products and dependencies
• Establish a vulnerability disclosure program and incident response process
• Provide security updates for a defined support period
• Create required documentation and declarations of conformity
• Report serious security incidents to EU authorities

The good news? Tools like CRA Compliance Suite can automate much of this process, from SBOM generation to vulnerability scanning to compliance documentation. Our platform is specifically designed to help WordPress developers meet CRA requirements efficiently and affordably.

Next Steps: Preparing for Compliance

Don't wait until the enforcement deadline approaches. Start preparing for CRA compliance now:

1. Assess your current state: Evaluate your development practices, security measures, and documentation against CRA requirements
2. Identify gaps: Determine what processes, tools, and documentation you need to add or improve
3. Create a roadmap: Develop a timeline for implementing necessary changes before the enforcement deadline
4. Implement security practices: Adopt secure development lifecycle principles and security testing
5. Establish processes: Create vulnerability management, incident response, and update processes
6. Use automation tools: Leverage platforms like CRA Compliance Suite to automate compliance tasks
7. Stay informed: Monitor regulatory developments and guidance from EU authorities

Conclusion

The EU Cyber Resilience Act represents a fundamental shift in how software security is regulated in Europe. While compliance requires significant effort, the regulation ultimately aims to create a safer digital ecosystem for everyone—consumers, businesses, and developers alike.

By understanding the CRA's requirements and starting preparation early, software developers can turn compliance from a burden into an opportunity: to improve security practices, build customer trust, and differentiate products in an increasingly security-conscious market.

The journey to CRA compliance starts with education and assessment. Continue learning with our other resources on this topic, and don't hesitate to reach out if you need guidance specific to your products or situation.