CRA MANDATORY FROM 2027

Implement the Cyber Resilience Act
and reduce
complexity

From December 2027 there will be no CE marking without CRA conformity. We guide manufacturers of industrial and railway components through CRA and IEC 62443 in a structured way — with a clear roadmap, the right priorities and security engineering that fits your existing product roadmap.

4-6 weeks to
your CRA roadmap
Prioritised measures
instead of scattergun
Full transparency on
CRA effort and budgets

The Cyber Resilience Act in brief

The CRA links the CE marking to cybersecurity requirements. Without proof of conformity, products with digital elements may no longer be placed on the EU market from December 2027. Violations are subject to fines of up to EUR 15 million or 2.5% of worldwide annual turnover.

In force since December 2024 · Reporting obligation from September 2026 · Full conformity from December 2027

IEC 62443 AS THE IMPLEMENTATION FRAMEWORK

IEC 62443 forms the technical basis for CRA implementation. We work along the standard parts for risk analysis, development process, component requirements and system requirements

  • IEC 62443-4-1
  • IEC 62443-4-2
  • IEC 62443-3-2
  • TS 50701/ IEC 63452
  • IEC 62443-3-3
BENEFITS

Our CRA solution for manufacturers

If you are a manufacturer of connected devices, software or IoT products struggling with the requirements of the Cyber Resilience Act, you are not alone.

MANY COMPANIES WASTE VALUABLE RESOURCES BECAUSE THEY ...

  • ... misjudge the cybersecurity requirements.
  • ... implement all requirements in an overly complex way.
  • ... start implementation too late and miss statutory deadlines.

OUR STRUCTURED COMPLIANCE APPROACH WAS DESIGNED TO ELIMINATE THIS COMPLEXITY.

It helps you achieve CRA conformity faster, more easily and without unplanned costs or technical overload.

CRA READINESS CHECK

The structured entry point into your CRA project. After a runtime of 4-6 weeks you will hold a reliable maturity report with a prioritised action plan and effort estimate — the basis for your internal decision-making and budget planning.

Maturity assessment - process (IEC 62443-4-1)
Maturity assessment - product (IEC 62443-4-2)
CRA Annex | gap comparison
Initial threat modeling
Prioritised action plan with effort estimate
Recommended target security level
YOUR BENEFIT

What you achieve with our CRA offering

As a manufacturer, you bear responsibility across the entire product lifecycle — from development through operation to updates, strict requirements apply for conformity, vulnerability management and security updates. This is exactly where we come in: we prioritise what is really necessary and guide you to CRA conformity with clear priorities and predictable effort.

As a component manufacturer, you are the primary point of responsibility for CRA obligations. We make sure your components meet the CRA requirements in time and remain CE-compliant even after 11 December 2027. You avoid being removed from tenders and delivery stops imposed by your customers.

COLLABORATION

Typical course of a CRA project

CRA check

Phase 1

PRODUCT ANALYSIS AND CATEGORISATION

  • 01 Scoping
  • 02 Analyse

Assessing your products comes right at the beginning. All relevant devices, software products and connected components are recorded and classified into the CRA product classes.

Products with digital elements must undergo a risk assessment, and vulnerabilities must be documented and handled to ensure conformity with the requirements of the CRA.

Products in higher risk classes are subject to more demanding security measures, including deeper risk assessments and advanced security mechanisms.

METHODEN & FRAMEWORKS

STRIDE • MITRE ATT&CK FOR ICS • MITRE EMB3D • ATTACK TREES • DATA FLOW DIAGRAMS • 62443-4-1 PRACTICES • CRA ANNEX • MATURITY ASSESSMENT

Phase 2

IMPLEMENT REQUIREMENTS

  • 03 Konzept
  • 04 Umsetzung & Test

Implementing the security-by-design and security-by-default principles forms the core of this phase. Products must be supplied with security updates throughout the entire support period — at least five years, and correspondingly longer where a longer expected service life is anticipated (as is common for railway and industrial components).

A systematic process for monitoring, reporting and remediating vulnerabilities is mandatory for companies. Manufacturers must also maintain a precise Software Bill of Materials of the components and third-party libraries they use.

Companies are further obliged to provide regular security updates and patches over a defined period. This phase transforms technical requirements into concrete development and operational processes.

METHODEN & FRAMEWORKS

DEFENSE IN DEPTH • LEAST PRIVILEGE • SECURE BOOT • KEY MANAGEMENT • LIBFUZZER • AFL++ ASAN / MSAN • CI/CD

Phase 3

ENSURE ONGOING CONFORMITY

  • 05 Lifecycle

The declaration of conformity is required to demonstrate that a product meets all requirements of the CRA. The conformity assessment procedure varies by product category — from self-assessment for standard products to external evaluation for critical components.

The CE marking is proof of conformity for products that must meet the security requirements.

In parallel, documentation and reporting procedures are established, as the obligation for manufacturers to report actively exploited vulnerabilities and security incidents comes into force on 11 September 2026.

METHODEN & FRAMEWORKS

SBOM MAINTENANCE • CVE TRACKING • VULNERABILITY HANDLING • INCIDENT REPORTING • CE CONFORMITY

No guesswork. No wasted effort.

Just structured progress towards full CRA compliance.

01 Scoping

Definition of the target security level and project scope.

"Only those who know complex systems such as process control technology or train control in detail can embed security holistically."

Timon Eßlinger - Project Lead Cyber Security, Codewerk

Timon Eßlinger, Project Lead Cyber Security at Codewerk
FROM THE FIELD

Structured implementation with concrete results

We do not work from standard checklists. We derive recommendations and protective measures from a concrete analysis of your product and its operating environment, so the result really fits your component. Four examples from our practice.

WHY CODEWERK

SYSTEM KNOW-HOW MEETS SECURITY ENGINEERING

We develop software for safety-critical systems and bring this knowledge into every security assessment.

COMPLETE RAILWAY STACK

Vehicle control and train communication from hands-on development: MVB, WTB, TRDP, ETCS environment. This lets us cover TS 50701 and IEC 63452 from deep system understanding, not just from a standards perspective.

ISO 27001 CERTIFIED

Information security is lived practice for us, certified to ISO 27001 since 2020 and audited annually. What we require of you, we practise ourselves.

RESEARCH & STANDARDISATION

Active involvement in international research and standardisation projects in the railway industry. We see new requirements before they appear in the standard.

FAQ Cyber Resilience Act

Frequently asked questions

Here you will find answers to frequently asked questions about the Cyber Resilience Act and our services.

What is the EU Cyber Resilience Act?

The Cyber Resilience Act (CRA) is an EU-wide regulation that, for the first time, establishes binding security requirements for all products with digital elements. The aim of this regulation is to significantly raise the level of cybersecurity within the European Union and to better protect consumers and businesses against cyber threats.

The CRA obliges manufacturers, importers and distributors to ensure that their products — whether hardware or software — meet fundamental cybersecurity requirements and are supplied with up-to-date security updates throughout the entire product lifecycle.

The scope of the CRA covers all products with digital elements made available on the European market. This includes classic IT hardware, smart devices, industrial controllers, software products and connected applications. The regulation applies both to new products and to existing products that are substantially modified after the CRA enters into force.

Manufacturers must demonstrate that their products comply with the requirements of the Cyber Resilience Act (CRA) before they may sell them in the EU.

With the CRA, the EU sets a new standard for cybersecurity and product safety that is relevant to every company that develops, manufactures or imports digital products. Compliance with the security requirements is a prerequisite for market access and strengthens the trust of users and consumers in the security of digital products.

How quickly can we become CRA-compliant?

The Cyber Resilience Act is being implemented in stages through to the end of 2027. With our structured approach, most companies reach full conformity within 6-12 months, depending on product complexity and existing processes. Important: the reporting obligations already take effect from September 2026.

Do we need additional technical expertise?

That depends on your product class. For standard products we support your team with clear specifications, templates and checklists, so you can implement much of it yourself. Important and critical products require an external conformity assessment — here we take on the necessary security engineering and guide you through the evaluation.

What are the risks of non-compliance with the CRA?

Violations of the CRA requirements are monitored by national supervisory authorities and can be penalised with substantial fines of up to 15 million euros or 2.5% of worldwide annual turnover. Sales of non-compliant products can be prohibited, and products can be withdrawn from the European market. The market surveillance authorities of the EU member states have extensive powers to verify and enforce compliance.

How do the requirements differ for different product classes?

Standard products (around 90% of all products with digital elements) can carry out a self-assessment. Important products of class I can be self-assessed, provided the relevant harmonised standards are fully applied — otherwise an external conformity assessment is required. Class II products generally require the involvement of a notified body or an EU certification. Critical products are subject to the strictest requirements, with an EU certification scheme at the substantial level.

What is CE marking?

The CE marking is a central element of the Cyber Resilience Act and signals that a product meets the security requirements applicable in the EU. For manufacturers, this means they must carry out a comprehensive conformity assessment before placing their products with digital elements on the market. This process ensures that all requirements of the CRA — from technical security to organisational measures — are met.

As part of the conformity assessment, manufacturers document how their products meet the specific requirements of the CRA. Once this process has been successfully completed, a declaration of conformity is issued confirming compliance with the EU requirements. Only then may the CE marking be affixed and the product offered on the European market.

The CE marking is therefore not only a legal requirement but also a visible sign to consumers and business partners that the product meets current security standards. For companies, carrying out the conformity assessment correctly is crucial to minimise liability risks and secure access to the European market.

Start your CRA project today

The earlier you start, the more predictable effort and budget remain — and the more reliably you will meet the deadline of 11 December 2027.

DO NOT WAIT UNTIL THE DEADLINES BECOME CRITICAL.