Close Menu
  • Home
  • Managing resilience
    • AI resilience
    • Business continuity
    • Business resilience
    • Climate resilience
    • C-suite and the board
    • DORA – the EU Digital Operational Resilience Act
    • Operational resilience
    • Organizational resilience
    • Supply chain resilience
    • Technology
  • Risk
    • Enterprise risk management
    • Operational risk
    • Threatscape
  • Cyber resilience
    • Cyber resilience updates
    • DORA – the EU Digital Operational Resilience Act
    • Product updates
More items
  • All News
  • Research
  • Jobs in Resilience
  • Resilience Resources
  • About Resilience Forward
X (Twitter) LinkedIn
  • Home
  • Managing resilience
    • AI resilience
    • Business continuity
    • Business resilience
    • Climate resilience
    • C-suite and the board
    • DORA – the EU Digital Operational Resilience Act
    • Operational resilience
    • Organizational resilience
    • Supply chain resilience
    • Technology
  • Risk
    • Enterprise risk management
    • Operational risk
    • Threatscape
  • Cyber resilience
    • Cyber resilience updates
    • DORA – the EU Digital Operational Resilience Act
    • Product updates
Login
LinkedIn Bluesky
Resilience Forward
Subscribe Now
  • All News
  • Research
  • Jobs in Resilience
  • Resilience Resources
  • About Resilience Forward
Resilience Forward
You are at:Home»Cyber resilience»The countdown is on: what the EU Cyber Resilience Act requires (Page 10)
Cyber resilience

The countdown is on: what the EU Cyber Resilience Act requires

September 3, 20265 Mins Read
Cyber Resilience Act

By Scott Register

Every connected product ships with a hidden liability: its software components. When the Log4Shell vulnerability surfaced in late 2021, that liability came due. Organizations spent days, sometimes weeks, determining whether a single open-source library was embedded in their products. answer should have been immediate. For most, it was anything but.

The EU’s response was to legislate. The Cyber Resilience Act (CRA), which entered into force in December 2024, imposes mandatory cyber security requirements on a broad range of products with digital elements made available on the EU market, from consumer IoT devices and industrial control systems to standalone software.

The first manufacturer reporting deadline is close: from 11 September 2026, manufacturers must submit an early warning within 24 hours of becoming aware of actively exploited vulnerabilities or severe incidents affecting product security. The notification must be made to the designated national CSIRT and ENISA.

From voluntary best practice to legal baseline

The Cyber Resilience Act represents a fundamental shift in how the EU treats software security. Rather than relying on voluntary frameworks, it positions cyber security as a product safety requirement, much like the standards that have governed hardware for decades.

The CRA provides for substantial penalties. Once Article 64 applies from 11 December 2027, non-compliance with the essential cyber security requirements or the manufacturer obligations under Articles 13 and 14 may attract fines of up to €15 million or 2.5% of global annual turnover, whichever is higher. Authorities may also order product recalls or require non-compliant products to be withdrawn. On 27 July 2026, the European Commission published practical, non-binding guidance on the application of the Act.

Mapping the software you ship

A central Cyber Resilience Act requirement is that manufacturers must identify and document product components and vulnerabilities, including by drawing up a software bill of materials (SBOM). An SBOM is an inventory of the software components within a product, including operating system packages, third-party libraries, and dependencies. The regulation requires the SBOM to use a machine-readable format and to cover at least the product’s top-level dependencies.

Modern software products routinely consist of 75% or more external components, many of them open source. According to the 2025 Open Source Security and Risk Analysis Report, 97% of the audited commercial codebases contained open-source software, with many containing known vulnerabilities. Without a comprehensive SBOM, manufacturers cannot reliably identify whether their products contain a component affected by a newly disclosed vulnerability, let alone respond within the reporting windows that the CRA demands.

This reflects a broader global trend. Germany’s BSI TR-03183-2 guideline is becoming a de facto quality benchmark across the EU, and markets including South Korea and India are developing similar frameworks. For manufacturers selling into multiple jurisdictions, SBOM maturity is a global competitiveness issue, not just a European compliance exercise.

The false-positive problem

An SBOM details what is inside a product; however, it does not tell you whether a flagged vulnerability is exploitable. A library may contain a known flaw, but if the affected code is unreachable in the final build, that particular vulnerability may not be exploitable in that build. SBOM-based vulnerability scanners that rely on version matching can be poor at making this distinction. A 2026 study by researchers at King Abdullah University of Science and Technology found a 92.0% false-positive rate in its case study of SBOM-based vulnerability scanners.

The operational cost is material. Development teams lose hours each week chasing alerts that turn out to be noise, delaying releases, and eroding trust in security tools. Alert fatigue sets in, and genuine threats risk being overlooked. Under the CRA’s 24-hour early-warning obligation, the ability to separate potentially relevant vulnerabilities from false alarms becomes operationally important to meeting the regulatory requirement.

Building a supply chain security capability

Adhering to the Cyber Resilience Act requires more than a scanning tool and an SBOM. Organizations need end-to-end capabilities spanning vulnerability identification, triage, remediation, and communication, both upstream to component suppliers and downstream to customers.

Tooling decisions should reflect the development environment. Source code, build-time, and binary or firmware analysis each address different parts of the problem, and no single approach covers every scenario. Companies should evaluate solutions against their own codebases and look for detection accuracy and false-positive rates rather than feature lists.

Equally important is integration into existing workflows. Vulnerability data sitting in a standalone dashboard, disconnected from CI/CD pipelines, slows response and increases risk. A confirmed vulnerability should automatically generate a prioritised ticket, identify affected products, and trigger notifications up and down the supply chain.

The case for early action

The CRA’s main obligations apply from December 2027, but the September 2026 reporting obligations also apply to products within the CRA’s scope that were placed on the EU market before 11 December 2027. The time to act is now.

There is also a commercial dimension. Enterprise procurement teams are asking increasingly detailed questions about supply chain security posture before signing contracts. Companies that can demonstrate mature SBOM practices and rapid vulnerability response will stand apart in a market where trust is becoming a differentiator.

The CRA makes product cyber security a condition of market access and a factor in commercial relationships. With supply chain transparency contributing to assessments of trustworthiness, no business can afford to wait.

The author

Scott Register, VP, Enterprise at Keysight Technologies

Europe
Share. Facebook Twitter Pinterest LinkedIn Tumblr Email WhatsApp
Previous ArticleThe blind spots in business continuity
Next Article Enterprises are struggling to keep mission-critical applications resilient: despite widespread HA/DR investments

Related Posts

An exploding digital padlock illustrates the requirement for post-quantum cryptography.

Research breakthrough brings reliable quantum computers and Q-day closer to reality

September 10, 2026
A danger sign on a digital background.

New blob URL phishing technique evades detection by using legitimate Microsoft services

September 10, 2026
AI risks

Unmanaged AI workflows expose EMEA organizations to rising compliance and data risks

September 9, 2026
City skyline at sunset with bright light trails and a translucent blue smart-city grid overlay and GPS pins indicating locations.

AI world models: future possibilities for organizational resilience?

September 7, 2026
DRJ and BCI logos

DRJ and BCI publish guidance for governing, managing, and using AI in resilience

September 7, 2026
Decision making with over whelming information.

AI can find the vulnerability. Accountability still sits with your crisis leadership

September 7, 2026
Advertisement
Resilience First
This week's most read articles
Under pressure: An egg cracking under pressure applied by squeezing clamps form the sides.

Managing scenario testing for operational resilience

May 16, 2024
COSO logo

New COSO ERM guidance aims to help organizations with practical implementation

May 12, 2026
Close-up of a green-brown iris peering through a jagged tear in dark paper or wall material.

The blind spots in business continuity

September 2, 2026
Latest resources
Mature businessman smiling talking on smartphone drinking coffee.

A hidden dependency: when trust becomes a vulnerability

June 2, 2026
Load More

Subscribe to Updates

Get our Resilience Updates newsletter.

Most Popular Feature Articles
Three dark coloured light bulbs on a black background illustrate the concept of The Dark Triad in Crisis Management.

The Dark Triad in crisis management

Five stage crisis management framework

A five stage framework for a crisis management process

Blue interconnected gears and network nodes symbolizing automation and complex machinery.

Agent zero – the 2028 digital pandemic

Latest Reports
A futuristic red warning alert icon with glowing exclamation mark.

Cloud Security Alliance publishes Hugging Face Incident Initial Post-Mortem

A person hold a building door open for a person behind who is tailgating to get unauthorised access.

Security Culture: A Strategic Capability That Builds Resilience in a Volatile World

An identity icon with a map marker on it, indicating the concept of identity as a target for attackers. The icon is on a generic IT background predominantly in black and orange.

Identity-based approaches dominate initial access for ransomware attacks

A promo box for an article about resilience governance.
© 2026 Resilience Forward
  • About Resilience Forward
  • Newsletter
  • Newsfeed
  • Advertise
  • Call for Papers
  • Contact
  • Privacy Policy and Cookie Use
  • AI Use Policy

Type above and press Enter to search. Press Esc to cancel.

Manage Cookie Consent
To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behaviour or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
  • Manage options
  • Manage services
  • Manage {vendor_count} vendors
  • Read more about these purposes
View preferences
  • {title}
  • {title}
  • {title}
Manage Cookie Consent
To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behaviour or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
  • Manage options
  • Manage services
  • Manage {vendor_count} vendors
  • Read more about these purposes
View preferences
  • {title}
  • {title}
  • {title}
Ad Blocker Enabled!
Ad Blocker Enabled!
Our website is made possible by displaying online advertisements to our visitors. Please support us by disabling your Ad Blocker.

Sign In or Register

Welcome Back!

Login to your account below.

Lost password?