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WEBINAR

How to Achieve CRA Compliance Starting With Secure by Design

Watch Parasoft’s compliance experts, Arthur Hicken and Ricardo Camacho, as they break down what the CRA means for your organization, regardless of where you’re based. They’ll outline a practical, engineering-focused path to compliance.

Learn how automation, shift-left security, and modern DevOps practices can significantly reduce compliance effort while strengthening your overall security posture. We’ll translate mandatory and recommended steps you can take today, like how to:

  • Audit your environment for CRA compliance gaps.
  • Embed security into DevOps and CI/CD workflows.
  • Prepare for mandatory vulnerability reporting.
  • Align development practices with OWASP and CWE guidance.
  • Validate software readiness through independent assessment.

Key Takeaways

The EU Cyber Resilience Act (CRA) is here, and it’s changing the game for how we think about software security and compliance. This new regulation means businesses need to build security into their products right from the start, covering everything from design to ongoing maintenance. It’s not just about avoiding fines; it’s about building better, more trustworthy products for the EU market.

  • CRA is Mandatory: If you sell products with digital elements in the EU, you must comply, regardless of your company’s location.
  • Secure by Design is Key: Security needs to be a core part of your product development lifecycle, not an afterthought.
  • Accountability is High: Manufacturers are responsible for security, including third-party components.
  • Reporting is Crucial: Timely reporting of vulnerabilities and incidents is required.
  • Fines are Significant: Non-compliance can lead to hefty financial penalties.

Understanding the EU Cyber Resilience Act

The Cyber Resilience Act is a binding regulation from the European Union. It sets out mandatory cybersecurity requirements for any product with digital elements that’s sold in the EU. This covers both hardware and software, including things like embedded systems and connected devices. The main idea is that manufacturers need to bake security into their products throughout their entire life cycle. This means thinking about secure design from day one, doing proper risk assessments, having ways to manage vulnerabilities, and making sure you can provide security updates when needed.

If your company sells products in the EU, you’re in scope. It doesn’t matter where your company is based. The CRA also links cybersecurity to the CE marking, which is like a stamp of approval. Products need to show they meet these requirements before they can be sold in the EU. For technical teams, this means that things like creating a software bill of materials (SBOM), handling vulnerabilities in a structured way, and keeping records of your compliance efforts are now official requirements, not just good ideas.

The act officially came into force in December 2024, but the main obligations won’t be fully active until December 2027. However, the rules about reporting vulnerabilities and incidents start much sooner, in September of this year.

Why the CRA Exists: The Growing Cyber Threat

So, why did the EU decide to put this regulation in place? Well, the numbers are pretty staggering. Cybercrime damages are expected to hit 1.5 trillion dollars annually, and that’s without even considering if the rate of attacks increases. We’re seeing more and more attacks targeting critical areas like government systems, hospitals, and essential infrastructure – basically, systems that affect everyone.

A big part of the problem is how interconnected everything is. Often, a single vulnerability in an open-source component can lead to a massive cybersecurity incident, taking down countless systems. It’s like one weak link in a chain causing a global failure. The CRA aims to bring some much-needed control by enforcing things like secure coding practices, making vendors accountable, requiring vulnerability disclosures, and using the CE marking to show that products meet security standards. It also mandates incident reporting.

A Real-World Example: The MOVEit Breach

To illustrate the impact, consider the MOVEit breach that happened in May 2023. Attackers exploited critical security flaws in MOVEit Transfer, a widely used software for transferring files securely. Thousands of organizations worldwide used this software to exchange sensitive data. Hackers found and used a zero-day SQL injection vulnerability – a type of flaw that is entirely preventable with good coding practices. This vulnerability allowed them to access the software’s database without needing to log in.

Even though the flaw was patched within a few days of being discovered, the damage was already done. Over 2,700 organizations and potentially 90 million individuals had their sensitive personal and financial data compromised. This breach is a prime example of a supply chain attack, showing how a single flaw in a third-party software can have widespread global consequences and how cybercrime is increasingly focused on large-scale data extortion.

The CRA is essentially the EU’s response to these pervasive and serious risks in modern software. It aims to create clear rules, hold vendors accountable through potential fines, and ensure that vulnerabilities are disclosed so that users are aware and can take action to mitigate the domino effect of system failures.

Who Needs to Comply and What’s at Stake?

If you sell software, hardware, or even software-based services in the cloud within the EU, you need to comply with the CRA. This applies whether your organization is based in the EU or elsewhere. It includes cloud-connected devices, IoT products, and remote services – think smartphones, smart devices, robots, and cars.

A key requirement is that organizations are responsible for the security of third-party components they use. You can’t just assume a component is secure because someone else made it. You need to ensure its security just like any other part of your system.

The Financial Penalties

The consequences of not complying can be severe:

  • Failure to meet essential requirements: Up to €15 million or 2.5% of global annual turnover.
  • Missing or incorrect documentation: Up to €10 million or 2% of global annual turnover.
  • Failure to report exploited vulnerabilities: Up to €5 million or 1% of global annual turnover.

These fines can add up quickly. It’s essential to ensure your software is built with security in mind from the start and that you’re transparent with your customers about your security practices. Beyond compliance, building secure software makes your products more stable, reliable, and builds customer trust.

Practical Steps to Achieve CRA Compliance

While the CRA might sound daunting, there are concrete steps you can take. The focus is on integrating security into your daily engineering and operational processes, well before the enforcement deadlines.

1. Audit Your Environment for CRA Compliance Gaps

The CRA places a strong emphasis on accountability. Article 13 requires manufacturers to conduct and maintain cybersecurity risk assessments throughout the product’s life cycle. This isn’t a one-off task; it needs to adapt as the product evolves and new threats emerge. This assessment guides the selection of security controls, testing, and documentation.

Article 31 mandates comprehensive technical documentation that proves how cybersecurity was handled during design, development, and verification. Authorities will use this evidence to check for compliance. Annex 1, Part 2, requires structured vulnerability handling, including maintaining a software bill of materials (SBOM), having formal processes for disclosing vulnerabilities, and efficiently developing and distributing security patches.

Article 14 introduces strict reporting obligations: actively exploited vulnerabilities or serious incidents must be reported within 24 hours of becoming aware of them. These reports go through a platform managed by the EU Agency for Cybersecurity, which then forwards them to the relevant national response teams.

Finally, products need to be classified as ‘important’ or ‘critical’ under Annex 3 or 4. This classification determines the level of scrutiny and the conformity assessment required.

Key Questions to Ask:

  • Is our risk assessment up-to-date?
  • Is our technical documentation complete?
  • Do we have vulnerability management processes in place?
  • Can we report within 24 hours if needed?
  • Have we correctly classified our product?

If the answer to any of these is uncertain, you’re not fully ready for CRA compliance.

Getting Started with Auditing:

  1. Gain Visibility: Start with a complete inventory of everything in your product, including open-source and third-party components. SBOMs are the foundation for tracking vulnerabilities.
  2. Review Documentation: Check your existing design and test artifacts against Annex 7. Are they consistent and clearly linked to security requirements?
  3. Assess Practices: Evaluate if secure-by-design principles are actually being followed. Are vulnerabilities detected early? Are they tracked to resolution? Are security updates tested before release?

The outcome of this audit should be a gap analysis report that directly maps to CRA articles, followed by a remediation roadmap with clear deadlines. The goal is to be ready for market surveillance by 2027, allowing you to confidently prove compliance and avoid penalties.

Leveraging Automation:

Tools like static code analysis can identify many types of vulnerabilities early in development. Unit testing, integration testing, and system testing are also vital. You need to demonstrate not just that testing occurred, but what code was covered, what risks were addressed, and how findings were resolved. All this data should feed into a centralized reporting system to generate the evidence regulators will need.

2. Embed Security into DevOps Workflows

The CRA emphasizes building security into the development process. Article 13 and Annex 1 highlight secure design, development, and production phases, which align perfectly with modern DevOps practices. This means security checks need to run continuously throughout the software life cycle.

Continuous Vulnerability Management:

Annex 1, Part 2, defines continuous vulnerability management. You need to integrate security checks into your CI/CD pipelines. This is where you enforce security, perform vulnerability management, generate documentation, and validate updates before each release. Your CI/CD pipeline becomes the primary mechanism for compliance.

Automated Controls:

Implement automated, repeatable security controls as gates in your pipeline. This automation generates evidence of compliance, creates audit trails for every build, and allows for timely vulnerability remediation with automated patch validation.

Practical Steps:

  • Integrate Early: Incorporate security tools as early as possible in the development process. Developers should get feedback on security issues directly in their IDEs and during commit stages, not weeks later.
  • Scan Dependencies: Perform dependency scanning during builds to maintain an accurate SBOM.
  • Automate Gates: Set up automated security gates in your pipeline. High-risk vulnerabilities should stop the pipeline, while lower-risk issues are tracked with clear remediation plans.
  • Document Everything: Pipeline configurations, security rules, and results should be version-controlled artifacts. This creates a defensible audit trail linking CI/CD controls to CRA requirements.

Automation is key to making this process sustainable. By integrating testing and analysis directly into the CI/CD pipeline, you can consistently perform security testing on every build. Policy enforcement ensures that secure coding rules are applied uniformly, reducing reliance on manual reviews. Fast, actionable feedback keeps developers engaged and minimizes friction.

3. Prepare for Mandatory Vulnerability Reporting

Article 14 of the CRA introduces some of the most operationally challenging requirements, particularly the 24-hour reporting window for actively exploited vulnerabilities. If malicious actors have successfully exploited a flaw in your product, you must report it within 24 hours.

Beyond the initial alert, you have 72 hours to provide technical details and mitigation steps, and within 14 days, a full analysis including the root cause and proof of remediation. All of this must be reported to both national Computer Security Incident Response Teams (CSIRTs) and relevant government agencies.

What You Need in Place:

  • A single point of contact for reporting.
  • A published vulnerability disclosure policy.
  • Strong internal detection and classification processes.
  • Documented procedures and pre-written notification templates.
  • Integration with official reporting systems.

The clock is already ticking, as reporting requirements begin in September.

A Phased Approach to Reporting Readiness:

  1. Establish the Foundation: Define roles, create policies, develop templates, and set up internal workflows.
  2. Integrate and Train: Connect your processes with external reporting mechanisms (CSIRTs, EU platforms). Train your teams on meeting the tight CRA timelines, especially under pressure.
  3. Validate End-to-End: Run simulations, capture evidence, and refine the process. Reporting readiness must be demonstrated, not just assumed.

Think of building your CRA reporting capability like setting up an emergency response system. You need to build the muscle memory through drills and preparation, not just react when an incident occurs.

4. Align Development Practices with Recognized Security Guidance

While the CRA doesn’t mandate specific frameworks, it does accept harmonized standards or equivalent measures to prove compliance. This is where frameworks like OWASP (Open Web Application Security Project) and CWE (Common Weakness Enumeration) become invaluable.

These are globally recognized standards that help prevent the types of vulnerabilities referenced throughout the CRA. Using them provides auditable evidence of secure development practices, shows regulators you’re using state-of-the-art security, and speeds up compliance verification.

Mapping CRA to OWASP and CWE:

  • Secure by Design (Annex 1): Aligns with OWASP Proactive Controls.
  • Vulnerability Prevention: Directly relates to OWASP Top 10 and CWE Top 25.
  • Documented Security Practices (Article 31): Easier to manage with standardized vulnerability taxonomies.
  • Regular Security Testing (Annex 1): Maps cleanly to OWASP Testing Guides.

Putting It into Practice (Phased Approach):

  1. Assessment and Mapping (Approx. 30 days): Compare your current practices against OWASP Top 10 and known CWE weaknesses in your code. Identify gaps and prioritize fixes.
  2. Integration and Training (Approx. 60 days): Adopt secure coding standards tied to OWASP and CWE. Train your teams on common vulnerabilities and update development documentation. Embed security into your definition of ‘done’ – code isn’t done just because it works; it’s done when it meets security requirements too.
  3. Automation and Validation (Approx. 90 days): Integrate security testing into your CI/CD pipelines. Automatically enforce OWASP and CWE rules, fail builds on critical issues, and retain evidence of these controls.

For example, strong input validation to prevent injection attacks maps directly to injection risks identified by OWASP and specific CWE weaknesses like SQL injection (CWE89) or command injection. Compliance means proving it through automated checks and test cases that show your code rejects malicious inputs.

5. Validate Software Readiness Through Independent Assessment

The CRA requires external, verifiable proof of cybersecurity due diligence. This means demonstrating that security has been addressed across the entire life cycle and that your product is ready for release before it reaches customers.

Product Classification:

The CRA uses a three-tier system based on risk:

  • Default Products: Most products (around 90%) fall here. They are considered lower risk, and manufacturers can typically rely on self-assessment.
  • Important Products (Annex 3): This includes products like password managers or smart locks (Class 1), which might still use self-assessment if they follow harmonized standards. However, products like operating systems or firewalls (Class 2) usually require mandatory third-party evaluation.
  • Critical Products (Annex 4): These are high-impact systems like smart meters or hardware security modules. They require formal third-party assessment or EU cybersecurity certification.

Determining Your Product’s Classification:

  1. Check the Annexes: See if your product is listed under Annex 3 (important) or Annex 4 (critical).
  2. Consider Real-World Impact: If a compromise of your product could significantly affect public safety, essential services, or government functions, it may be treated as critical, even if not explicitly listed.

This classification will dictate the depth of testing, the amount of evidence needed, and your overall compliance strategy.

Automating Evidence for Assessment:

Tools can automatically analyze your code, identify serious security risks based on OWASP and CWE, and provide a clear picture of potential vulnerabilities. If critical issues are found in components affecting public safety, it’s a strong signal for a critical classification. Automating the audit trail through CI/CD integration, security rule enforcement, and documentation of tests, findings, and fixes provides a fully verifiable record for the CRA without extensive manual effort.

AI-Powered Security:

Emerging AI capabilities can further assist by analyzing violations, prioritizing the most severe ones, and even suggesting or applying code fixes. This can streamline the process of identifying and remediating vulnerabilities, producing reports that summarize what was found and what actions were taken. This integration of AI with development tools and security analysis offers a powerful way to manage quality and security, making day-to-day workflows more efficient.

By adopting a secure-by-design approach and leveraging automation, organizations can not only meet the requirements of the EU Cyber Resilience Act but also build more robust and trustworthy products, turning compliance into a competitive advantage.