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What does the Cyber Resilience Act require of a product?

Annex I of Regulation (EU) 2024/2847 sets 22 essential cybersecurity requirements for products with digital elements. Fourteen cover product security in Part I and eight cover vulnerability handling in Part II.

Key takeaways​

  • Each requirement has a stable identifier. Cite it as, for example, I-2d.
  • Part I(1) and all of Part II apply to every product. Part I(2)(a) to (m) apply where the risk assessment says so.
  • The clause column lists FprEN 40000-1-2:2026 clauses. That standard is a Formal Vote draft and is not yet cited in the Official Journal. Its numbering can still change.
  • The requirement text is copied from the regulation. The regulation on EUR-Lex is the authoritative version.

Part I, security properties​

I-1. Appropriate level of cybersecurity based on the risks​

Reference ANNEX I Part I (1). Applies to every product.

Products with digital elements shall be designed, developed and produced in such a way that they ensure an appropriate level of cybersecurity based on the risks.

FprEN 40000-1-2:2026 clauses 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, 7.3, 7.4, 7.5, 7.6, 7.7

On the basis of the cybersecurity risk assessment referred to in Article 13(2) and where applicable, products with digital elements shall:

I-2a. No known exploitable vulnerabilities​

Reference ANNEX I Part I (2)(a). Applies where the risk assessment says so.

be made available on the market without known exploitable vulnerabilities;

FprEN 40000-1-2:2026 clauses 6.4, 7.6

I-2b. Secure by default​

Reference ANNEX I Part I (2)(b). Applies where the risk assessment says so.

be made available on the market with a secure by default configuration, unless otherwise agreed between manufacturer and business user in relation to a tailor-made product with digital elements, including the possibility to reset the product to its original state;

FprEN 40000-1-2:2026 clause 7.4

I-2c. Security updates​

Reference ANNEX I Part I (2)(c). Applies where the risk assessment says so.

ensure that vulnerabilities can be addressed through security updates, including, where applicable, through automatic security updates that are installed within an appropriate timeframe enabled as a default setting, with a clear and easy-to-use opt-out mechanism, through the notification of available updates to users, and the option to temporarily postpone them;

FprEN 40000-1-2:2026 clauses 7.2, 7.8

I-2d. Protection from unauthorised access​

Reference ANNEX I Part I (2)(d). Applies where the risk assessment says so.

ensure protection from unauthorised access by appropriate control mechanisms, including but not limited to authentication, identity or access management systems, and report on possible unauthorised access;

FprEN 40000-1-2:2026 clauses 7.4, 7.5, 7.8

I-2e. Confidentiality of data​

Reference ANNEX I Part I (2)(e). Applies where the risk assessment says so.

protect the confidentiality of stored, transmitted or otherwise processed data, personal or other, such as by encrypting relevant data at rest or in transit by state of the art mechanisms, and by using other technical means;

FprEN 40000-1-2:2026 clauses 7.4, 7.6, 7.8

I-2f. Integrity of data​

Reference ANNEX I Part I (2)(f). Applies where the risk assessment says so.

protect the integrity of stored, transmitted or otherwise processed data, personal or other, commands, programs and configuration against any manipulation or modification not authorised by the user, and report on corruptions;

FprEN 40000-1-2:2026 clauses 7.4, 7.6, 7.8

I-2g. Data minimisation​

Reference ANNEX I Part I (2)(g). Applies where the risk assessment says so.

process only data, personal or other, that are adequate, relevant and limited to what is necessary in relation to the intended purpose of the product with digital elements (data minimisation);

FprEN 40000-1-2:2026 clause 7.4

I-2h. Availability of essential functions​

Reference ANNEX I Part I (2)(h). Applies where the risk assessment says so.

protect the availability of essential and basic functions, also after an incident, including through resilience and mitigation measures against denial-of-service attacks;

FprEN 40000-1-2:2026 clause 7.4

I-2i. Minimise impact on other devices​

Reference ANNEX I Part I (2)(i). Applies where the risk assessment says so.

minimise the negative impact by the products themselves or connected devices on the availability of services provided by other devices or networks;

FprEN 40000-1-2:2026 clause 7.4

I-2j. Limit attack surfaces​

Reference ANNEX I Part I (2)(j). Applies where the risk assessment says so.

be designed, developed and produced to limit attack surfaces, including external interfaces;

FprEN 40000-1-2:2026 clause 7.4

I-2k. Reduce impact of incidents​

Reference ANNEX I Part I (2)(k). Applies where the risk assessment says so.

be designed, developed and produced to reduce the impact of an incident using appropriate exploitation mitigation mechanisms and techniques;

FprEN 40000-1-2:2026 clauses 7.4, 7.6

I-2l. Security-relevant logging​

Reference ANNEX I Part I (2)(l). Applies where the risk assessment says so.

provide security related information by recording and monitoring relevant internal activity, including the access to or modification of data, services or functions, with an opt-out mechanism for the user;

FprEN 40000-1-2:2026 clauses 7.4, 7.6

I-2m. Secure data deletion / portability​

Reference ANNEX I Part I (2)(m). Applies where the risk assessment says so.

provide the possibility for users to securely and easily remove on a permanent basis all data and settings and, where such data can be transferred to other products or systems, ensure that this is done in a secure manner.

FprEN 40000-1-2:2026 clause 7.9

Part II, vulnerability handling​

II-1. Identify & document vulnerabilities and components (SBOM)​

Reference ANNEX I Part II (1). Applies to every product.

identify and document vulnerabilities and components contained in products with digital elements, including by drawing up a software bill of materials in a commonly used and machine-readable format covering at the very least the top-level dependencies of the products;

FprEN 40000-1-2:2026 clause 7.5

II-2. Address & remediate without delay​

Reference ANNEX I Part II (2). Applies to every product.

in relation to the risks posed to products with digital elements, address and remediate vulnerabilities without delay, including by providing security updates; where technically feasible, new security updates shall be provided separately from functionality updates;

FprEN 40000-1-2:2026 clause 7.8

II-3. Regular security testing & reviews​

Reference ANNEX I Part II (3). Applies to every product.

apply effective and regular tests and reviews of the security of the product with digital elements;

FprEN 40000-1-2:2026 clauses 6.7, 7.2, 7.6

II-4. Public disclosure of fixed vulnerabilities​

Reference ANNEX I Part II (4). Applies to every product.

once a security update has been made available, share and publicly disclose information about fixed vulnerabilities, including a description of the vulnerabilities, information allowing users to identify the product with digital elements affected, the impacts of the vulnerabilities, their severity and clear and accessible information helping users to remediate the vulnerabilities; in duly justified cases, where manufacturers consider the security risks of publication to outweigh the security benefits, they may delay making public information regarding a fixed vulnerability until after users have been given the possibility to apply the relevant patch;

FprEN 40000-1-2:2026 clause 7.8

II-5. Coordinated vulnerability disclosure policy​

Reference ANNEX I Part II (5). Applies to every product.

put in place and enforce a policy on coordinated vulnerability disclosure;

FprEN 40000-1-2:2026 clause 7.8

II-6. Facilitate vulnerability information sharing​

Reference ANNEX I Part II (6). Applies to every product.

take measures to facilitate the sharing of information about potential vulnerabilities in their product with digital elements as well as in third-party components contained in that product, including by providing a contact address for the reporting of the vulnerabilities discovered in the product with digital elements;

FprEN 40000-1-2:2026 clauses 7.8, 7.10

II-7. Secure update distribution​

Reference ANNEX I Part II (7). Applies to every product.

provide for mechanisms to securely distribute updates for products with digital elements to ensure that vulnerabilities are fixed or mitigated in a timely manner and, where applicable for security updates, in an automatic manner;

FprEN 40000-1-2:2026 clause 7.7

II-8. Timely, free security patches​

Reference ANNEX I Part II (8). Applies to every product.

ensure that, where security updates are available to address identified security issues, they are disseminated without delay and, unless otherwise agreed between a manufacturer and a business user in relation to a tailor-made product with digital elements, free of charge, accompanied by advisory messages providing users with the relevant information, including on potential action to be taken.

FprEN 40000-1-2:2026 clauses 6.3, 7.2, 7.8

Download and cite​

CVD Portal, "CRA Annex I requirements catalogue", 2026-09-30. https://cradata.eu/requirements (CC BY 4.0)

Who publishes this​

Porta Regulus B.V. publishes this catalogue. Porta Regulus B.V. also operates CVD Portal, a CRA compliance tool. The catalogue lists the regulation and a standard. It does not describe or rate any tool. Report an error to research@portaregulus.com.