Decoding the 13 Essential Cybersecurity Requirements of the CRA

Margaret Ellis

Welcome back to Come Reflect Act, the Tributech podcast guiding you through the maze of the Cyber Resilience Act. I’m Margaret Ellis, joined as always by David Evans. David, today’s spotlight is on what I’d call the very backbone of the CRA—the thirteen essential cybersecurity requirements. Now, we’ve mentioned the requirements in past episodes, but let’s really break down what each one means in practice.

David Evans

Yeah, and it’s a lot to digest if you’re looking at Annex 1 for the first time. These requirements are mandatory for nearly every connected product, unless you’re somehow in a very specific, already-regulated sector. We’re not talking about “nice to have”. It’s law. So, let’s start at the top: requirement (a), the one that always jumps out, is no known exploitable vulnerabilities at product release. Basically, if you know about a vulnerability—public CVE, internal bug tracker, whatever—you’ve gotta deal with it, and you need technical documentation justifying anything that doesn’t get fully closed out. That’s a big shift for some teams.

Margaret Ellis

Yes, and it’s about proportionality, isn’t it? The level of control must fit the product and its risk profile, but if you skip or only partially meet a requirement, you need clear, rock-solid documentation. Regulators, customers, importers—they’ll all scrutinize it. So, then we’ve got (b): secure by default configuration. Devices need to be safe out of the box—no open debug interfaces just waiting for trouble, no rubbish default credentials. Unless, of course, it’s a tailor-made agreement between you and your business user.

David Evans

And this is followed by security updates and opt-out, requirement (c). The product must support timely, ideally automatic security updates with users being informed, but also able to postpone or opt out if they want. That’s a huge one for anything with a long service life—think smart meters tucked away somewhere. The update channel itself? Needs proper cryptographic signing, rollback prevention, audit logs. That sort of thing.

Margaret Ellis

Then there’s requirement (d), which is about protection against unauthorized access. Access controls, identity management, two-factor authentication—it’s all about not letting anyone just stumble into your system. Logging suspicious activity is key too—do not skimp on the monitoring.

David Evans

Absolutely, and (e) lands us at data confidentiality. Encrypt everything, basically—from personal data to configuration settings. Keep your key management tight. Segregate sensitive data so it’s not freely floating around the architecture. And don’t forget about strong audit logs for data access.

Margaret Ellis

Requirement (f) is protecting the integrity of both the data and your product’s functions. If someone tries to mess with your firmware or your configuration, it needs to get flagged—and stopped. Signed firmware images, cryptographic hashes. If you’re manufacturing, this means runtime verification is your new standard, not an afterthought.

David Evans

Data minimization, that’s (g). Only gather what you really need. Don’t just hoover up telemetry and diagnostics because “maybe someday we’ll use it.” Anything beyond core functions needs opt-in and justification—privacy impact assessments are your friend here.

Margaret Ellis

Moving right along, (h) is resilience and availability. You want your core functions to keep running even in a crisis. Build in rate limiting, watchdogs, fallback processes... so attacks don’t take you entirely offline.

David Evans

Number nine—(i)—is about not harming other connected systems. Your product can’t be the noisy neighbor. No excessive traffic, no flooding the local network, no quirky behavior that brings other devices down. If you’re shaping traffic, make sure it fits the ecosystem you’re in.

Margaret Ellis

Absolutely.And hang in there, we have a few left. Tenth one, (j), is to limit the attack surface. Shut off the unnecessary ports, disable features unless someone genuinely needs them. Every point of entry you remove is one less worry.

David Evans

Which links pretty closely to (k): mitigating incident impact. If someone gets in, they shouldn’t be able to take down your whole system. Use sandboxing, privilege separation—basically, make sure the blast radius of any problem is contained and can’t escalate sideways.

Margaret Ellis

We’re nearly there—(l), logging. Keep reliable logs of security-relevant activities access, changes, and make it exportable or streamable. But, and this is important, there needs to be an opt-out if the user wants it, depending on the privacy context.

David Evans

And the last one, (m), is secure deletion and data portability. Users must be able to irretrievably wipe their data and settings, and if data is moving to another product, that transfer has to be secure. No dangling backups. No old login tokens sitting around.

Margaret Ellis

It really is a comprehensive foundation, David. And the overall point is, these requirements will apply to almost all connected products come December 2027, unless you’re in a sector with stricter rules. Compliance is mandatory, documentation is everything, and the risk-based approach doesn’t mean shortcuts—just tailored, well-justified decisions.

David Evans

Alright, so now that the “what” is clear, let’s move into the “how.” Because for many manufacturers, bridging from intention to implementation is the real test. Vulnerability management needs to be a lifecycle process, not just a launch checklist. You’ve gotta be continuously checking databases such as the Common Vulnerabilities and Exposures, using static and dynamic application security testing, and, crucially, documenting your choices. That means technical files that actually stand up under regulatory scrutiny!

Margaret Ellis

That’s it—and it’s not just a technical shift, but a cultural one for a lot of firms. You’ll need secure update systems—with cryptographic signing, rollback prevention, and full logging—and a way to update documentation in real time as incidents unfold. Let’s not forget about access control: enforcing strong authentication, using multi-factor wherever feasible, and keeping a close eye on failed login attempts or other indicators of compromise.

David Evans

And on top of that, you’re expected to implement strong encryption to keep data confidential, both in storage and in transit. But you need to make sure your key management systems don’t create new vulnerabilities. The same goes for logging—lots of organizations collect logs, but if they’re not secure, or if log management itself isn’t robust, you’re just trading one kind of risk for another.

Margaret Ellis

Now, let’s address this headache of aligning with standards. Right now, IEC 62443 is probably your best bet if you’re in industrial IoT. ETSI EN 303 645 and ISO/IEC 1 8031 also offer valuable guidance for IoT and radio-connected devices more generally. But—here’s the catch—these don’t completely map to the CRA, and we’re still waiting for a dedicated CRA standard in the months ahead. So, you need to build controls that are adaptable, ready to be mapped to new requirements once harmonized standards arrive.

David Evans

Yeah, and until those finalized standards drop, you’ll want to take a composite approach. That change in mindset—from “good enough” to “provable”—is not small.

Margaret Ellis

Exactly. Regulators will want to see not just that you claim compliance, but that you can show how and document why. Every risk-based decision should be transparent. The technical documentation is not a formality—it’s your evidence, and without it, you simply won’t get your products on the market.

David Evans

And the deadline December 2027 probably sounds far off, but if you look at product lifecycles and supply chains, it’s really… well, tomorrow. If you’re not compliant after that date, you’re in for more than a slap on the wrist: we’re talking being barred from the EU market, products recalled, and yes, some hefty fines.

Margaret Ellis

And losing access to the European market is a nightmare scenario. For many manufacturers, it’s their largest customer base. The CRA doesn’t mess around here—enforcement isn’t just by the regulators, but also importers, distributors, even your customers, all checking your technical file and documentation. The risk of sudden exclusion is very real if you let this slide.

Margaret Ellis

I think—and again, we’ve said this in earlier episodes—early action is less about ticking off a regulatory checkbox, and more about building a culture where cybersecurity is at your core. You’re not only avoiding costly disruptions down the road, but actually increasing trust with your customers and partners. It sets you up for whatever the next wave of regulation will be, too—because the CRA sets the tone for future international rules.

David Evans

Exactly, Margaret. And even if the harmonized standards are still on the horizon, the requirements are clear. Start with what you have—risk assessments, gap analysis, technical documentation—build momentum, and you’ll thank yourself in 2027. And if you’re feeling uncertain, find expert partners. You don’t have to do it alone.

Margaret Ellis

That’s a good note to end on. We’ve unpacked the thirteen essentials today, thank you for sticking with us. David, always a pleasure dissecting these topics with you.

David Evans

Likewise, Margaret. Thanks everyone for tuning in—don’t forget to check out Tributech’s CRA Knowledge Hub if you want to read more, and we’ll see you next time.

Margaret Ellis

Goodbye, everyone! Take care and stay secure.