> ## Documentation Index
> Fetch the complete documentation index at: https://docs.matproof.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Getting Started with the Cyber Resilience Act

> A practical guide to meeting CRA product security requirements for manufacturers, importers, and distributors of products with digital elements.

# Getting Started with the Cyber Resilience Act

The Cyber Resilience Act (CRA) establishes mandatory cybersecurity requirements for **products with digital elements** sold on the EU market. This covers hardware and software products that can connect to a device or network - from IoT devices and operating systems to firmware and standalone software applications.

The CRA entered into force on December 10, 2024. Reporting obligations for actively exploited vulnerabilities begin **September 11, 2026**, and the full set of product security requirements becomes enforceable on **December 11, 2027**.

Matproof maps CRA obligations to controls, evidence workflows, and vulnerability management processes so manufacturers can demonstrate compliance to market surveillance authorities.

<Note>
  Activate the CRA under **Settings - Frameworks - Cyber Resilience Act**. Controls are pre-populated based on whether your products are classified as default, important (Class I or II), or critical.
</Note>

***

## Am I in Scope?

The CRA applies to any organization that places products with digital elements on the EU market:

| Role             | Definition                                                          | Key Obligations                                                                                           |
| ---------------- | ------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------- |
| **Manufacturer** | Develops or has a product developed and markets it under their name | Full compliance: secure by design, vulnerability handling, technical documentation, conformity assessment |
| **Importer**     | Places a product from a non-EU manufacturer on the EU market        | Verify manufacturer compliance, ensure product bears CE marking, maintain documentation                   |
| **Distributor**  | Makes a product available on the EU market (without modifying it)   | Verify CE marking and documentation, report known vulnerabilities to manufacturer                         |

<Warning>
  Open source software developed in a non-commercial context is generally excluded. However, if an open source project is used commercially or integrated into a commercial product, the CRA may apply to the integrator as the manufacturer.
</Warning>

***

## Product Classification

The CRA uses a tiered classification for products with digital elements:

| Category                 | Examples                                                                                              | Conformity Assessment                         |
| ------------------------ | ----------------------------------------------------------------------------------------------------- | --------------------------------------------- |
| **Default**              | Most consumer and business software, IoT devices without critical functions                           | Self-assessment (Annex VIII)                  |
| **Important - Class I**  | Password managers, VPNs, network management systems, security information and event management (SIEM) | Harmonised standard or third-party assessment |
| **Important - Class II** | Operating systems, firewalls, tamper-resistant microprocessors, industrial automation systems         | Third-party assessment required               |
| **Critical**             | Hardware devices with security boxes, smart meter gateways, smartcards                                | European cybersecurity certification required |

<Tip>
  Most software products fall into the default category and can use self-assessment. Check Annexes III and IV of the regulation for the complete product lists in each class.
</Tip>

***

## Key Enforcement Dates

| Date               | Milestone                                                                                         |
| ------------------ | ------------------------------------------------------------------------------------------------- |
| December 10, 2024  | Regulation enters into force                                                                      |
| June 11, 2026      | Conformity assessment bodies can begin operating                                                  |
| September 11, 2026 | **Vulnerability and incident reporting obligations apply**                                        |
| December 11, 2027  | **Full enforcement** - all product security requirements, conformity assessments, penalties apply |

***

## Core Requirements in Matproof

<CardGroup cols={2}>
  <Card title="Secure by Design" icon="shield-halved">
    **Controls**

    Products must be designed and developed with appropriate cybersecurity measures from the start. No known exploitable vulnerabilities at time of release.
  </Card>

  <Card title="Vulnerability Handling" icon="bug">
    **Incidents, Controls**

    Manufacturers must identify and remediate vulnerabilities throughout the product's expected lifetime (minimum 5 years). Provide security updates free of charge.
  </Card>

  <Card title="Technical Documentation" icon="file-lines">
    **Evidence, Policies**

    Maintain documentation covering security architecture, risk assessment, SBOM (Software Bill of Materials), and testing results.
  </Card>

  <Card title="Conformity Assessment" icon="clipboard-check">
    **Audit Programs**

    Complete the applicable conformity assessment procedure before placing the product on the market. Affix CE marking.
  </Card>

  <Card title="Incident Reporting" icon="bell">
    **Incidents**

    Report actively exploited vulnerabilities to ENISA within 24 hours of becoming aware. Report severe incidents within 72 hours.
  </Card>

  <Card title="Security Updates" icon="arrow-rotate-right">
    **Controls**

    Provide timely, free security updates for the entire support period. Document your update delivery mechanism.
  </Card>
</CardGroup>

***

## Recommended Implementation Plan

<Steps>
  ### Step 1 - Inventory your products with digital elements

  List every product your organization manufactures, imports, or distributes that connects to a device or network.

  1. Go to **Controls - CRA - Product Inventory**
  2. For each product, document: product name, version, intended use, connectivity type, and expected product lifetime
  3. Classify each product (default, important Class I/II, or critical)

  ### Step 2 - Conduct product security risk assessments

  For each product:

  1. Go to **Risk Management - New Risk Assessment**
  2. Assess cybersecurity risks based on the product's intended use, connectivity, and data processed
  3. Document risk mitigation measures built into the product design
  4. Include risks from third-party components and dependencies

  ### Step 3 - Implement secure development practices

  The CRA requires security to be integrated into the development lifecycle:

  * Implement secure coding standards and code review processes
  * Conduct security testing (static analysis, dynamic analysis, fuzz testing)
  * Manage third-party dependencies and track known vulnerabilities
  * Generate and maintain a **Software Bill of Materials (SBOM)** for each product
  * Document these practices in your Secure Development Policy

  Go to **Policies - Generate** to create your CRA-aligned Secure Development Policy.

  ### Step 4 - Establish vulnerability handling

  Set up your vulnerability management process:

  1. Configure the **Incidents** module for vulnerability intake (from researchers, users, and monitoring)
  2. Define your coordinated vulnerability disclosure policy
  3. Establish a process for issuing security updates within a reasonable timeframe
  4. Maintain a vulnerability log with remediation timelines
  5. Provide a public contact point for vulnerability reports

  <Warning>
    From September 2026, you must report actively exploited vulnerabilities to ENISA within 24 hours of becoming aware. Set up your reporting workflow before this deadline.
  </Warning>

  ### Step 5 - Build technical documentation

  The CRA requires comprehensive technical documentation including:

  * Product description and intended purpose
  * Security architecture and design decisions
  * Risk assessment results
  * SBOM listing all components and dependencies
  * Testing and validation results
  * Instructions for secure configuration and use

  Upload all documentation as evidence against the relevant CRA controls in Matproof.

  ### Step 6 - Conformity assessment

  Complete the applicable assessment procedure:

  1. Go to **Audit Programs - New Audit - CRA**
  2. For default products: complete the self-assessment using the internal control procedure (Annex VIII)
  3. For Important Class II and Critical products: engage a notified body for third-party assessment
  4. Affix CE marking and draft the EU declaration of conformity
  5. Register in the EU product database where required

  ### Step 7 - Post-market monitoring

  After placing the product on the market:

  1. Monitor for new vulnerabilities in your product and its components
  2. Issue security updates as needed and notify users
  3. Report actively exploited vulnerabilities to ENISA (24-hour deadline from September 2026)
  4. Report severe security incidents within 72 hours
  5. Update technical documentation when the product changes materially
</Steps>

***

## Penalties

| Violation                                          | Maximum Penalty                                                      |
| -------------------------------------------------- | -------------------------------------------------------------------- |
| Essential cybersecurity requirements (Annex I)     | Up to 15M EUR or 2.5% of global annual turnover, whichever is higher |
| Other CRA obligations                              | Up to 10M EUR or 2% of global annual turnover, whichever is higher   |
| Incorrect or misleading information to authorities | Up to 5M EUR or 1% of global annual turnover, whichever is higher    |

***

## Next Steps

* [Risk Management](/features/risk-management) - product security risk assessments
* [Incidents](/features/incidents) - vulnerability reporting and handling workflows
* [Audit Programs](/features/audit-programs) - conformity assessment procedures
* [Vendor Risk](/features/vendor-risk) - managing third-party component risks in your supply chain
