Mastering CRA Vulnerability Handling

Margaret Ellis

Welcome back to Tributech's Come Reflect Act, everyone, and thanks for tuning in again. I’m Margaret Ellis. Today, we’re diving into a Cyber Resilience Act topic that has been frequently discussed—the CRA's vulnerability handling requirements. We’ve spoken before about the 13 essential cybersecurity requirements the regulation outlines, but today we’re zooming in on these eight specific vulnerability handling obligations that are, frankly, about to become table stakes for manufacturers of connected products in the EU.

David Evans

The Cyber Resilience Act introduces this structural shift—it's not just ‘add a patch and go.’ You're legally expected to document, triage, fix, and communicate about security issues, all the way through the life of your product.

Margaret Ellis

Absolutely. And as a reminder, the timeline is tight—active vulnerability reporting and serious incident notification obligations will already land in September 2026, with the broader vulnerability handling requirements due by December 2027. So, as we go through today’s discussion—don’t think of these as guidelines; these are obligations, and the consequences for missing them are pretty serious. We’re talking CE marking refusal, market bans, even fines up to, what, 15 million euros or 2.5% of global revenue? It’s not small change.

Margaret Ellis

So let’s break down what these obligations really mean, and then we’ll talk about how to actually meet them, step by step.

Margaret Ellis

So, the Cyber Resilience Act lays out eight distinct vulnerability handling requirements. The first—identify and document vulnerabilities—essentially means you need to know and keep track of every critical software component in your product, and that’s where software bill of materials come in. You create a software bill of materials that’s always current and machine-readable, so you can check for known vulnerabilities in all those dependencies. By the way, we talked a bit about SBOMs and technical documentation in the 13 essential requirements episode, but here, the focus is on that ongoing process through the product lifecycle.

David Evans

Right, I think the real shift here is that it’s now mandatory to, you know, integrate SBOM generation directly into your development pipelines. Ideally, that means every new software build spits out an updated SBOM, and you’ve got automated scanning set up to catch new CVEs, new issues, as soon as they come up. The less manual this is, the better, so you’re not playing catch-up when an audit happens. And, keep it all as part of your compliance documentation—because the authorities may ask for it anytime.

Margaret Ellis

The second obligation is about managing those risks and pushing security updates as soon as a vulnerability is found. It sounds simple, but the tricky part is making sure your product is built to accept critical patches rapidly, ideally even separately from big feature updates, so users aren’t left hanging. Think modular updates and secure delivery, with logs to track what’s been installed and when.

David Evans

Yeah, so requirement three—security testing. It’s not enough just to test before release; you’ve got to keep testing throughout the product’s lifetime. I mean, that means—uh—pen testing, static and dynamic code analysis, fuzzing, you name it. But you should tailor the frequency and depth based on risk assessments: what you’d do for, say, a consumer smart bulb isn’t quite the same as for an industrial PLC. Keeping those test results documented and tied to versioning is also critical.

Margaret Ellis

That naturally leads into obligation number four: notification and disclosure when you release a security update. You can’t just push the patch and go silent; you have to publish advisories that explain which vulnerabilities were fixed, what versions are affected, how severe they are, and—for non-technical users—what action they need to take, if any. And, in rare cases, you can withhold some info for a short time if public disclosure would open up new risks, but it’s the exception, not the norm.

David Evans

Obligation five ties into this: you’ve gotta have a coordinated vulnerability disclosure—or CVD—policy. So, researchers and customers can securely report issues, and, more importantly, they see you’re taking their reports seriously. There’s an expectation you’ll get back to them, keep them in the loop, and together decide when it’s safe to disclose the vulnerability publicly. This is now a formal requirement under the CRA, not a ‘nice to have.’

Margaret Ellis

Exactly. And number six extends that by making sure you’ve got a clear—ideally public—contact method for anyone to report vulnerabilities, either in your product or in any third-party component you’re using. Companies sometimes overlook the third-party element, but under the CRA, integrated components absolutely count.

David Evans

Requirement seven, which is about secure distribution of updates, is pretty technical. It’s not just about putting a zip file on your website. Updates have to be distributed securely, with digital signatures and integrity checks, ideally allowing for automatic installs or, at least, a reliable notification to users. Failing to do this leaves—well—a lot of doors wide open for attackers if users aren’t patched promptly.

Margaret Ellis

Spot on. And the last of the eight—is making sure updates actually reach users fast and for free. Unless you’ve made a unique agreement for a tailor-made business device, updates should be provided promptly, without extra charges, and you should include simple, clear advisories—plain English, not just technical jargon—explaining the fix and what, if anything, the end user needs to do.

David Evans

The big thing here is that all eight are interconnected. If your product isn’t designed for rapid patching, then the rest kind of falls apart, right? The CRA is pushing everyone toward a secure development lifecycle, regular scanning, automated update pipelines—all those tools we used to think of as ‘gold standard’ are now requirements.

Margaret Ellis

And, as you just hinted, David—the organizational change is probably the toughest part. Let’s talk about how manufacturers can actually get ready for this.

Margaret Ellis

So—where to begin? Building CRA readiness around these vulnerability handling requirements isn’t just a quick tech fix. You need to treat security as part of your development DNA. That usually starts with a Secure Software Development Lifecycle, or SDLC, with security reviews baked into every phase. Not just for show, but so that you catch vulnerabilities early, before they ever ship.

David Evans

Yeah. And look, those technical enablers matter—SBOMs, automated scanning tools, update frameworks, etcetera—but the real hurdle for most companies is changing how people think. The CRA means product, engineering, compliance, comms—they all have to work together. If your vulnerability disclosure process is just stuck in IT’s inbox, or if updates can’t ship unless a dozen teams sign off, you’re asking for problems. I’ve seen too many organizations treat security as a thing to ‘bolt on’ after the fact. The CRA is making that mindset unsustainable.

Margaret Ellis

That’s right. And the culture shift is almost more important than the toolkits themselves. Manufacturers need to make it safe and even expected for researchers to report issues, for teams to test and question assumptions, and for updates to be seen as routine business, not a last resort. Remember, these aren’t just legal checkboxes—they’re a way to demonstrate trust and a long-term commitment to resilience. Building that trust with customers and partners is, honestly, worth more than avoiding fines.

David Evans

You know, exactly. And, look, it’s a lot to take in, but you don’t need to go it alone—there are emerging best practices, and harmonized standards like IEC 62443 or ISO 27001 can steer you in the right direction. What matters is getting started early, and viewing these obligations as, well, opportunities to build something better, not just regulatory burdens. It can differentiate your product in a landscape that’s only gonna get tougher.

Margaret Ellis

We’ll keep exploring how to operationalize all these requirements in future episodes, but for now, remember that tackling CRA vulnerability handling is about mindset and long-term readiness.

David Evans

And that's a good note to end this on, thank you, Margaret. And thank you to everyone listening—don’t forget to check out Tributech’s CRA Knowledge Hub if you need more resources. We’ll catch you next time on Come Reflect Act. Bye, Margaret!

Margaret Ellis

Thanks, David. And goodbye, everyone. Until next time.