CRA Wake-Up Call for IoT Vendors

Margaret Ellis

Welcome back to Come Reflect Act by Tributech. I’m Margaret Ellis, and joining me is David Evans, as always. Today we’re zooming in on what is quickly becoming a real wake-up call for the entire IoT sector—the EU Cyber Resilience Act, or CRA.

Margaret Ellis

Now. we’ve unpacked the basic scope and structure of the CRA in our earlier episodes, so let’s just quickly set the stage here. The CRA is this sweeping new regulation—coming fully into force by December 11, 2027. Basically, if you’re making, selling, or even importing anything with digital bits—IoT devices, connected software, you name it—then you’re in the frame. That goes for industrial or good old consumer use cases, too.

David Evans

Yeah, and it’s not just about the tech anymore. The enforcement side is a whole new level. The fines alone—I mean, they’re very much inspired by the GDPR model. We’re talking up to €15 million, or 2.5% of your global annual turnover, whichever is higher, if you miss core requirements. There are three main tiers. The top tier is for things like falling short on the essential requirements—secure-by-design, incident reporting, the works. Then a €10 million or 2% turnover tier kicks in for operational issues—patching, vulnerability management...and then, there’s even a €5 million or 1% penalty for supplying false or incomplete info to the authorities. It’s...kind of jaw-dropping.

Margaret Ellis

It certainly puts cybersecurity on a par with financial compliance, doesn’t it? And those numbers aren’t just for show. It’s real, and the EU is signaling it here. But the CRA isn’t just about the money. Market access is on the line. No CE mark, or no proper Declaration of Conformity—your product can be pulled from the market, literally halted at the borders. And this applies even after launch; if that new update or feature changes your security posture, you might need to reassess your documentation and possibly your whole certification process.

David Evans

Exactly, and the authorities aren’t going to wait around. If they see a cybersecurity risk, you could be looking at sales bans, recalls, or customs just sending your shipments back. I think one part that really doesn’t get enough attention is the increased liability exposure, especially for companies working in critical sectors—energy, smart infrastructure, all of that. With the CRA, legal liability for damages goes way up if you can’t show—like, literally show—your documented, tested security processes were in place and compliant.

Margaret Ellis

That’s a good point, and it’s worth emphasizing—compliance isn’t a box you tick once and forget. The obligation of proof—really, the burden of ongoing documentation—is much heavier now.

David Evans

And speaking of obligations, let’s talk about what’s top of mind for IoT manufacturers—mandatory incident reporting. So, under Article 14, companies have to report any actively exploited vulnerability or major cybersecurity incident within twenty-four hours to both ENISA and their national CSIRT. That’s the Computer Security Incident Response Team, in case anyone’s lost in the acronym soup.

Margaret Ellis

You’re absolutely right—the reporting clock starts ticking the moment something bad is detected. First the initial notification within a day, then a technical report within seventy-two hours, then a final update two weeks after you’ve rolled out a fix. This is about real actionable transparency, not just a nod to good intentions. The regulators want to see that you’re not only aware of problems, but actually tracking, resolving, and learning from them in a way that can be audited if needed.

David Evans

And, the reporting rules? They’re the same for everyone. Big companies, small companies—you’re all on the hook for those tight timelines. But, there are special measures for small and micro-enterprises: CSIRTs have to give SMEs extra support—think helpdesk assistance for dealing with vulnerability reports. Plus, small firms get access to what the CRA calls regulatory sandboxes, basically controlled spaces to test products before going to market, and there are streamlined documentation requirements if you qualify as a microenterprise.

David Evans

And for many in the IoT sector, it’s going to require a cultural shift—incident reporting must become part of daily routines, not just something filed when something really bad happens.

Margaret Ellis

And really, that idea of embedding these practices brings us to where the CRA’s ripple effects grow even bigger: how it shapes strategy, competitiveness, and reputation. Compliance is quickly turning into a gatekeeper for more than just market access—it’s becoming a passport to major contracts, public procurement, and, honestly, basic business survival. Buyers, especially in smart infrastructure or public services, are already looking for suppliers who meet or exceed CRA standards, and being able to show solid, audit-ready documentation can be a real differentiator.

Margaret Ellis

For those ready to lead, the CRA is a launchpad for trust and long-term resilience. Early compliance is how companies can actually stand out, not just survive, in this new landscape.

David Evans

Right, and that’s probably the main thing for anyone listening today—don’t treat the CRA as a short-term hurdle or just another checklist. It’s about building digital trust, operational maturity, and long-term strategic value. If you get those foundations in place now, with the right partners and the right approach, you’re gonna find doors opening, as the 2027 deadline comes closer.

Margaret Ellis

Exactly. If you haven’t already, now is the moment to act—review your processes, document everything, put solid incident response in place, and look to partners who are setting the bar high, not just getting by. With that, we conclude today’s episode of Come Reflect Act. David, it’s great having these discussions with you—

David Evans

Always, Margaret. And thanks to everyone tuning in. We’ll be diving even deeper into CRA in the next episodes, so subscribe and join us again soon!

Margaret Ellis

Goodbye for now, and take care.

David Evans

See you next time!