The EU Cyber Resilience Act (CRA) isn’t just another regulatory regime – it’s a sweeping reset for how software producers are held accountable across the European Union. With full enforcement slated for 11 December 2027, CRA mandates rigorous standards for product cybersecurity, particularly focusing on Software Bill of Materials (SBOM) transparency, proactive vulnerability handling, and lifecycle-wide security design.
Crucially, it isn’t just about ticking compliance off a checklist. Rather, the CRA envisions SBOMs as living, actionable assets – especially vital in high-risk sectors like finance, healthcare, and telecom. They serve not only as proof of compliance but as powerful tools for evaluating third-party risk, verifying provenance, and responding swiftly to zero-day threats.
Timeline: When CRA Becomes Operational
| Milestone | Date |
|---|---|
| Entry into force | 10 December 2024 (published, enters into force) |
| Full enforcement of all obligations | 11 December 2027 |
| Vulnerability reporting earlier effective date | September 2026 – manufacturers must be ready to report actively exploited vulnerabilities within 24 hours |
1. What the CRA Requires: In-Depth Breakdown
a) Scope and Applicability
CRA applies to “products with digital elements” (PDEs) – a broad category that includes software, hardware with embedded software, IoT devices, desktop/mobile apps, firmware, and more .
While most consumer and industrial products fall under CRA, certain sectors – such as automotive, aviation, and regulated medical devices – are exempt as they already operate under stringent cybersecurity frameworks .
b) Secure by Design and Lifecycle Security
CRA instills security-by-design principles across the entire product lifecycle:
- Products must ship with secure-default configurations, minimal attack surfaces, and mechanisms to roll back to secure states (e.g., factory reset) .
- Continuous security testing, audits, and regular vulnerability scans are mandatory.
- Secure update mechanisms must be in place, offering free, opt-in updates indefinitely (minimum five years; ten years in some provisions) .
c) SBOM Requirements: More Than a Checklist
The CRA elevates the Software Bill of Materials (SBOM) from optional inventory to foundational compliance:
- Every product must include a machine-readable SBOM (formats like SPDX, CycloneDX, SWID), covering at least “top-level dependencies”.
- SBOMs are to be included in the technical documentation and supplied to market surveillance authorities on request – not necessarily made public .
- SBOMs must be continuously updated over the product lifecycle to reflect changes, patches, and new dependencies .
d) Vulnerability / Incident Reporting: Rapid and Transparent
CRA mandates fast, structured reporting for actively exploited vulnerabilities:
- Within 24 hours: Initial report to ENISA and national CSIRTs (Computer Security Incident Response Teams) .
- Within 72 hours: A more detailed vulnerability notification.
- Within 14 days: A comprehensive description and mitigation report, once available .
Plus, products must go to market free from known exploitable vulnerabilities, and updates must promptly address any that emerge .
e) Risk Management, Technical Documentation, Conformity Assessment
Manufacturers must establish robust security processes:
- Conduct cyber risk assessments, ensuring products ship without known exploitable vulnerabilities .
- Provide technical documentation, including SBOM, risk assessments, development practices, and security strategy .
- Issue EU Declaration of Conformity and, depending on risk class (important/critical products), engage third-party or external conformity assessments .
- A vulnerability handling process must exist (e.g., a public point of contact for disclosures, responsible disclosure policy) .
f) Penalties for Non-Compliance
CRA puts real teeth behind the requirements:
- Fines up to €15 million or 2.5% of global annual turnover, whichever is higher .
2. What Enterprises Must Do
Here’s what organizations selling digital products in the EU must do to comply and gain strategic security posture:
a) Build SBOM Generation into Your Process
- Automate SBOM creation with tools that support standard formats (SPDX, CycloneDX).
- Ensure SBOM reflects real dependencies (open-source, third-party modules) and top-level components.
- Keep SBOMs live and versioned – part of CI/CD, updated after every release/patch.
- Embed SBOM in technical documentation and be ready to deliver it to authorities on request.
b) Integrate Vulnerability Management with Rapid Response
- Continuously scan SBOM-listed components (via automated vulnerability scanning).
- Detect and address actively exploited vulnerabilities – ideally before they can be abused.
- Establish workflows for timeboxed vulnerability reporting: initial alert within 24 h, followed by deeper reports within 72 h and remediation details within 14 days.
c) Secure Design and Update Infrastructure
- Build products with secure defaults, minimal attack surfaces, and the ability to rollback or reset securely.
- Provide secure, trusted update mechanisms (preferably automated), separating security updates from feature updates.
- Commit to long-term support: at least 5 years, better if extended to 10 years where applicable.
d) Risk Assessment, Documentation, and Certification
- Perform rigorous cyber risk assessments pre-market.
- Maintain detailed technical documentation including SBOM, security design, update strategy, risk assessment, and disclosure policies.
- Execute the EU Declaration of Conformity and if applicable, engage external conformity assessments (e.g., for critical products).
e) Establish Governance and Operational Readiness
- Set up a vulnerability response team with clear responsibilities.
- Design a responsible disclosure process: public contact point, triage workflows, and public advisories for fixed vulnerabilities.
- Ensure audit logs, testing artifacts, and security documentation can support auditors or authorities.
f) Monitor and Update Continuously
- Make compliance part of your product lifecycle – not a one-off project.
- Review SBOMs, update mechanisms, and vulnerability management regularly.
- Audit and iterate: CRA compliance requires ongoing attention.
3. SBOM as a Strategic Tool: Not Just Compliance
In regulated or high-risk sectors (finance, medical, telecom), SBOMs aren’t just compliance tokens -they’re strategic assets:
- Third-party risk evaluation: SBOM gives you clear visibility into all software components, helping assess supplier risk proactively.
- Provenance validation: Understand exactly which open-source or vendor components went into your product.
- Zero-day readiness: When a vulnerability is disclosed, you can quickly scan SBOMs across products to pinpoint affected releases – accelerating response.
- Governance integration: When SBOMs are integrated into change and release governance, they become part of regular audits, risk dashboards, and incident response playbooks.
CRA effectively mandates this smart usage. SBOMs must be machine-readable, updated, and integrated into workflows, turning them from compliance artifacts into living security infrastructure.
4. How LabradorLab Helps You Meet CRA and Gain Security Advantage
At LabradorLab, we provide an integrated suite of solutions tailored precisely for CRA compliance – and beyond. Here’s how our tools align with every CRA requirement – and turn them into powerful business assets.
a) Automated, Continuous SBOM Generation and Management
Our platform integrates seamlessly into CI/CD pipelines to:
- Generate machine-readable SBOMs (SPDX, CycloneDX, SWID) per build.
- Track top-level dependencies, third-party libraries, open-source components.
- Maintain a versioned SBOM repository to support audits, traceability, and compliance documentation.
- Provide visualization tools and exportable reports to simulatemarket surveillance requests—no more ad hoc scrambling when auditors come calling.
b) Comprehensive Vulnerability Scanning & Alerting
We layer vulnerability context onto every SBOM:
- Scan components against threat intel, vulnerability databases, and exploit feeds.
- Flag actively exploited vulnerabilities immediately.
- Automate escalation per CRA timelines:
- 24-hour critical alert triggered to your response team.
- 72-hour ongoing alert detail.
- 14-day mitigation report once fix is deployed.
- Provide structured report generation suitable for submission to ENISA and CSIRTs.
c) Secure-by-Design Guidance & CI Integration
Our tooling supports product teams in applying secure defaults:
- Identify unnecessary components – help streamline and reduce attack surface.
- Support secure update workflows: build, test, deploy update pipelines (including rollback mechanisms).
- Help enforce secure build configurations and encryption standards.
d) Risk Assessment & Documentation Tools
LabradorLab helps generate CRA-aligned documentation:
- Risk assessments: automated export of threat models, vulnerability profiles, and risk prioritization.
- SBOM documentation: export-ready technical docs including SBOM, update strategy, risk assessments, and disclosure policies.
- Declaration of Conformity templates: fill-in forms aligning with CRA Annex I requirements.
- Audit-ready dashboards with logs, version history, SBOM changes, risk events.
e) Governance, Reporting & Compliance Dashboard
A centralized governance layer:
- Track compliance status per product: SBOM freshness, vulnerability backlog, response SLA completion.
- Visibility into long-term support commitments (5–10 years) and update timelines.
- Role-based access: developers, security teams, compliance auditors can collaborate in one system.
- Automated artifacts for authorities: pull request-style view of reporting events, risk assessment, SBOM evolution.
f) Lifecycle Support and Ongoing Maintenance
Our platform is built for durability:
- Continuous monitoring of dependencies and newly disclosed vulnerabilities.
- Regular SBOM updates and automatically with each build/release.
- Long retention of historical SBOMs and audit logs (aligned with CRA’s expected lifecycle periods).
- Upgrade support to align with evolving SBOM standards and CRA amendments.
5. Enterprise Scenario: High-Risk Financial Software
Let’s walk through an example to showcase how CRA compliance becomes a differentiator with LabradorLab:
Scenario: A European bank vendor delivers mission-critical financial applications globally.
CRA Compliance with LabradorLab
- SBOM Production: CI pipeline auto-generates SBOMs with each build. Every dependency, open-source or proprietary, is captured.
- Vulnerability Overlay: SBOMs are cross-scanned against threat feeds; a zero-day emerges in a third-party library.
- Rapid Response: Affected SBOM flagged – team receives 24-hour alert; fix planned. At 72 hours, the team sends a detailed vulnerability status update to security authorities (ENISA, national CSIRTs). By Day 10, patch is released; 14-day report with mitigation is generated and archived.
- Secure-by-Design Enforcement: Platform identifies unnecessary components; teams strip them, reducing attack surface and simplifying future SBOMs.
- Risk & Documentation: The system auto-generates risk assessment artifacts, SBOM documentation, and Declaration of Conformity for internal audit or external compliance checks.
- Governance Dashboard: Executives see real-time compliance status: SBOM freshness, pending vulnerabilities, support timeline – all in one view.
Business benefits:
- Compliant launching by end of 2027 and ahead of competitors.
- Faster zero-day response reduces risk exposure.
- Trust from regulators and customers reinforced by demonstrable governance.
- SBOM used operationally – not just filed away – enhances risk posture and vendor transparency.
CRA as Security Imperative and Opportunity
The EU Cyber Resilience Act (CRA) represents a watershed moment: software accountability is no longer voluntary – it’s embedded in law. Requirements are robust: machine-readable SBOMs, rapid vulnerability reporting, secure-by-design development, long-term support, and conformity frameworks, with heavy penalties for failure.
But CRA also ushers in a new paradigm: using SBOMs as strategic levers, not just compliance obligations – especially for high-risk sectors. Companies that treat SBOMs as dynamic assets, integrate them into security workflows, and automate CRA timelines gain real competitive advantage.
That’s where LabradorLab shines. We turn CRA compliance into secure-by-default operations, enabling organizations to meet regulatory demands and move faster, smarter, and more confidently in an evolving threat landscape.
Is your software vendor or team ready to deliver usable SBOM intelligence and truly leverage it under CRA? With LabradorLab, the answer isn’t just “yes” – it’s that you’ll do more than comply. You’ll lead.