Cyber Resilience Act (CRA)

A Comprehensive Guide for Companies

Preparing for the CRA

FAQ

Security Requirements

Abstract

The following blog article provides a comprehensive overview of the upcoming Cyber Resilience Act (CRA), focusing on its impact on companies that produce products with digital elements (PDEs). It outlines key requirements, such as security-by-design, automatic updates, and data protection, and emphasizes the importance of compliance to avoid severe penalties. The article also discusses strategies for businesses to prepare for the CRA, ensuring their products meet stringent cybersecurity standards, thereby enhancing trust and competitiveness in the EU market.

Preparing for the Cyber Resilience Act

In the ever-evolving digital landscape, cybersecurity has become a top priority for businesses worldwide. The European Union is taking a significant step forward with the introduction of the Cyber Resilience Act (CRA), a new regulation that sets stringent cybersecurity standards for products with digital elements (PDEs). This article aims to guide companies in understanding the CRA, its requirements, and how to prepare effectively for its implementation.

Understanding the Cyber Resilience Act

The Cyber Resilience Act is a groundbreaking regulation designed to ensure that all products with digital elements, from hardware to software, meet minimum cybersecurity requirements before being placed on the EU market. The CRA mandates that these products adopt a security-by-design approach, emphasizing the need for secure development practices from the outset. Products that comply with the CRA will receive a CE marking, signifying their adherence to these new standards. The primary goal of the CRA is to enhance the security of PDEs in response to the increasing number of cyberattacks across the EU, which have a staggering global annual cost estimated at €5.5 trillion. By enforcing these cybersecurity measures, the CRA aims to strengthen trust in the EU's digital infrastructure and boost the global competitiveness of European companies.

Security Requirements Under the CRA

The CRA outlines specific security requirements that manufacturers must integrate into their products. These include:

  • Access Protection: Ensuring that only authorized individuals can access sensitive systems and data.
  • Confidentiality: Protecting information from unauthorized disclosure.
  • Integrity: Safeguarding data and systems from unauthorized alterations.
  • Availability: Ensuring that systems and data are accessible when needed.

In addition, the CRA requires manufacturers to manage vulnerabilities and provide security updates for their products for a specified period. This proactive approach to cybersecurity aims to mitigate risks throughout the product's lifecycle.

See also the chapter Expert insight: Essential Security Requirements for PDEs.

The Scope of the Cyber Resilience Act

The CRA's scope is comprehensive, covering all products with digital elements that have communication capabilities, including embedded systems and standalone software. It applies to both hardware and software products under the New Legislative Framework, requiring compliance before these products can be marketed in the EU. Manufacturers, importers, and distributors of PDEs within the EU must ensure that their products meet these rigorous cybersecurity standards. The CRA also mandates that products carry the CE marking, indicating conformity with the new cybersecurity requirements. Importantly, the CRA covers the entire lifecycle of PDEs—from planning and design to production, delivery, and maintenance. This ensures that cybersecurity is maintained at every stage, preventing and managing cyber vulnerabilities effectively.

The Consequences of Non-Compliance

The CRA imposes severe penalties for non-compliance. Products that do not meet the CRA's standards cannot be placed on the market, and suppliers must withdraw any non-compliant products already available. Fines for failing to meet essential requirements can reach up to €15 million or 2.5% of global revenue, whichever is higher. Non-compliance with other obligations can result in fines of up to €10 million or 2% of global revenue. Furthermore, providing incorrect, incomplete, or misleading information to regulatory bodies can result in additional fines of up to €5 million or 1% of global revenue.

Meeting the CRA's Product Security Requirements

To comply with the CRA, manufacturers must integrate security requirements throughout the development process. This includes ensuring access protection, confidentiality, integrity, availability, and secure delivery. The CRA also mandates that manufacturers scrutinize their products for vulnerabilities and provide immediate rectification when issues are identified. Security updates must be provided free of charge for a period of at least five years, ensuring ongoing protection for users.

Conformity Assessment and CE Marking

Before launching products on the market, manufacturers must conduct thorough conformity assessments to ensure compliance with the CRA. These assessments are based on the product's criticality, with particular emphasis on critical infrastructures. Compliance requires adherence to European standards or testing by authorized institutions. Once a product meets the necessary requirements, the manufacturer can affix the CE marking, signaling its conformity with the CRA.

Market surveillance authorities (MSAs) in each EU Member State will enforce the CRA, with the power to conduct sweeps of Internet of Things (IoT) products and collaborate with the European Union Agency for Cybersecurity (ENISA) and the European Data Protection Board (EDPB).

Implementation Timeline and Next Steps

The European Commission published the draft regulation of the CRA on September 15, 2022. Following the European Parliament's acceptance on March 12, 2024, the CRA is expected to come into force in 2024, with full implementation anticipated over a 36-month period. The CRA's provisions will apply fully within two years of its entry into force, likely by late 2026.

Strategies for Complying with the CRA

To comply with the CRA, companies must adopt a proactive approach to cybersecurity. This includes developing secure-by-design products, conducting regular risk assessments, and maintaining transparency with users regarding security updates and known vulnerabilities. Companies should also consider leveraging automation to streamline compliance activities, such as vulnerability management, software bill of materials (SBOM) management, and automated reporting. A centralized platform can provide real-time monitoring, ensuring that the organization remains compliant with CRA requirements.

Challenges and Opportunities

While the CRA presents challenges in terms of ensuring continuous compliance with evolving cybersecurity standards, it also offers significant opportunities. By prioritizing cybersecurity, companies can gain a competitive edge in the market, offering products that meet the highest security standards.

Global Influence of the CRA

The CRA is poised to set a global precedent for cybersecurity standards, influencing policies and practices beyond the EU. This regulation encourages international manufacturers to adopt similar practices, contributing to a higher level of global cybersecurity. As companies prepare for increased compliance costs due to the CRA's stringent requirements, those that already follow good practices will find themselves better positioned to meet these new standards.

Conclusion

The Cyber Resilience Act is set to transform the cybersecurity landscape, demanding rigorous standards that companies must meet to remain compliant and competitive. Achieving these standards isn't just about ticking boxes - it's about safeguarding your business and building trust with your customers. This is where Rasotec GmbH steps in. We provide the expert insights and assessments needed to ensure your systems are resilient and ready for the CRA's demands. Don't wait for vulnerabilities to be exposed - partner with Rasotec today to secure your future and stay ahead in a rapidly evolving digital world.

Frequently Asked Questions (FAQ)

What is the Cyber Resilience Act?

The Cyber Resilience Act (CRA) is a European Union regulation designed to enhance cybersecurity across all products with digital elements (PDEs). It sets strict security requirements that manufacturers must meet before their products can be placed on the EU market. The CRA aims to ensure that these products are secure by design, addressing vulnerabilities throughout their lifecycle.

Which products are affected by the CRA?

The CRA applies to all products with digital elements that have communication capabilities, including both hardware and software. This includes embedded systems, standalone software, and any product with remote data processing capabilities. However, it does not apply to products regulated under other EU laws, cloud computing services, or non-commercial free and open-source software.

What are the main security requirements under the CRA?

The CRA requires products to meet security standards in access protection, confidentiality, integrity, and availability. Additionally, manufacturers must manage vulnerabilities, provide security updates for at least five years, and ensure secure development processes during the design, development, and manufacturing stages.

What is the CE marking, and why is it important?

The CE marking is a certification that indicates a product's conformity with EU regulations, including the CRA. Products with the CE marking have been assessed to meet the necessary safety, health, and environmental protection requirements. For PDEs, this means they have passed the cybersecurity standards mandated by the CRA, allowing them to be legally marketed in the EU.

What are the penalties for non-compliance with the CRA?

Penalties for non-compliance with the CRA are significant. Products that do not meet CRA standards cannot be sold in the EU, and suppliers must withdraw any non-compliant products already on the market. Fines for non-compliance can reach up to €15 million or 2.5% of global revenue, whichever is higher. There are also fines for other obligations, such as incorrect reporting, that can be as high as €5 million or 1% of global revenue.

How does the CRA impact manufacturers?

Manufacturers must ensure that their products comply with the CRA's cybersecurity requirements before they can be sold in the EU. This involves conducting risk assessments, ensuring secure development practices, and providing ongoing security updates. Non-compliance can result in fines, product recalls, and increased scrutiny from regulatory authorities.

When will the CRA come into force?

The CRA is expected to come into force in 2024, with a full implementation timeline of approximately 36 months. The regulations will be fully applicable by late 2026, giving companies time to adjust their practices and ensure compliance.

What steps should companies take to comply with the CRA?

Companies should begin by assessing their current cybersecurity posture, conducting thorough risk assessments, and aligning their product development processes with the CRA’s requirements. They should also consider implementing automation tools for vulnerability management, software bill of materials (SBOM) management, and compliance reporting to streamline these processes.

How does the CRA align with other cybersecurity standards?

The CRA aligns with international standards such as IEC 62443, which covers secure development processes and technical product requirements. Implementing these standards can help manufacturers meet the CRA's requirements effectively, ensuring their products are secure and compliant.

Will the CRA impact companies outside the EU?

Yes, the CRA will impact any company that wishes to sell products with digital elements in the EU market. Non-EU manufacturers must ensure their products meet CRA requirements, including obtaining the CE marking, to legally market their products in the EU. This regulation is expected to set a precedent for global cybersecurity standards, influencing policies and practices beyond the EU.

What is the role of automation in complying with the CRA?

Automation can significantly ease the compliance process by managing vulnerability assessments, SBOM management, and real-time risk assessments. A unified platform can help monitor and maintain compliance with CRA requirements efficiently, reducing the time and resources needed for manual processes.

How does the CRA benefit users?

The CRA benefits users by ensuring that products with digital elements meet high cybersecurity standards, reducing the risk of vulnerabilities and cyberattacks. Users will also benefit from mandatory security updates and better protection of their data and privacy.

What are the next steps for companies in preparing for the CRA?

Companies should start by understanding the specific requirements of the CRA that apply to their products. They should assess their current security measures, develop a plan to address any gaps, and begin implementing the necessary changes to ensure compliance before the CRA comes into full effect. Engaging with cybersecurity experts and investing in automated compliance tools are also recommended steps.

Expert insight: Essential Security Requirements for PDEs

As companies gear up to comply with the Cyber Resilience Act, it's crucial to understand the key security requirements that apply to products with digital elements (PDEs). These requirements are designed to ensure that PDEs are robust, secure, and capable of withstanding the complex cybersecurity threats that modern businesses face. Below, we present a subset of these essential requirements, highlighting the core ideas that your organization needs to focus on.

Secure by Design and Default Configuration

  • Products with digital elements must be designed, developed, and produced with cybersecurity as a foundational principle. This means considering potential risks and implementing appropriate security measures throughout the product’s lifecycle.
  • Products should come with secure configurations by default. This minimizes the risk of cyber incidents due to weak initial settings. In business-to-business contexts, there might be agreements to adjust these settings, but the default should always prioritize security.

Automated and Transparent Security Updates

  • PDEs must be capable of receiving automatic security updates. This ensures that vulnerabilities are patched promptly, reducing the window of exposure to potential attacks. Users should be notified of these updates and provided with an easy-to-use opt-out mechanism if necessary.
  • Separation of Updates: Where feasible, security updates should be separated from functionality updates. This allows businesses to focus on maintaining security without necessarily altering the functionality that their operations depend on.

Data Protection and Confidentiality

  • To protect sensitive information, PDEs must employ state-of-the-art encryption for data at rest and in transit. This is critical for safeguarding personal and business data from unauthorized access or breaches.
  • Beyond encryption, products must also ensure the integrity of data—ensuring that information is not tampered with during storage or transmission. Systems should be in place to detect and report any unauthorized access or data corruption.

Access Control and Identity Management

  • PDEs must include robust access control mechanisms. These can range from basic authentication methods to more advanced identity and access management (IAM) systems, ensuring that only authorized individuals can access sensitive functions or data.

Minimizing Attack Surfaces

  • Products should be designed with a minimal attack surface, meaning they should limit the number of potential entry points for cyberattacks. This includes careful consideration of external interfaces and ensuring that any exposed functionality is securely managed.
  • In the event of a security incident, PDEs should have mechanisms in place to reduce the impact, such as isolation of compromised components and resilience measures to maintain essential functions.

Vulnerability Handling and Disclosure

  • Manufacturers are required to identify, document, and address vulnerabilities in their products promptly. This includes maintaining a comprehensive Software Bill of Materials (SBOM) to track and manage dependencies.
  • When vulnerabilities are discovered, manufacturers must distribute security updates promptly and provide clear, accessible information to users about the nature of the vulnerabilities, their potential impact, and the actions users should take.

User Data and End-of-Support Notifications

  • PDEs must enable users to securely and permanently withdraw and remove their data when they choose to do so. This is essential for maintaining trust and ensuring data privacy.
  • Users should be notified when the product’s support period is ending, allowing them to make informed decisions about continued use and potential security risks.

Links

Document:

https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52022PC0454

EU Observatory:

https://oeil.secure.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2022/0272(COD)&l=en

EU Publication:

https://digital-strategy.ec.europa.eu/en/policies/cyber-resilience-act