Preparing Your Organization for the CRA

Your 12-Month CRA Action Plan

Here’s a step-by-step plan to achieve CRA compliance before the December 2027 deadline.

Month 1-2: Assessment Phase

Product Inventory

For each product, document:
- [ ] Product name and version
- [ ] CRA classification (Default/Class I/Class II/Critical)
- [ ] Applicable ETSI standards
- [ ] Current security posture
- [ ] Gap analysis vs CRA requirements

Stakeholder Alignment

• Brief executive leadership on CRA obligations
• Assign CRA compliance ownership (CISO, VP Engineering, or dedicated role)
• Budget allocation for compliance activities

Month 3-4: Foundation Building

SBOM Pipeline

• Implement SBOM generation in CI/CD
• Choose format (CycloneDX recommended)
• Automate vulnerability scanning against SBOM
• Set up dependency monitoring

Vulnerability Handling

• Create or update security.txt
• Establish coordinated vulnerability disclosure policy
• Set up incident response procedures
• Define ENISA reporting workflow

Month 5-8: Implementation

Security Engineering

• Conduct threat modeling for each product
• Implement security testing in CI/CD (SAST, DAST, fuzzing)
• Review and harden security defaults
• Ensure secure update mechanisms

Documentation

• Begin technical documentation
• Document security architecture
• Record security design decisions
• Prepare conformity assessment evidence

Month 9-10: Testing and Validation

Conformity Assessment

• Self-assessment for Default/Class I products
• Engage third-party assessor for Class II/Critical
• Conduct penetration testing
• Validate SBOM completeness

Process Verification

• Test vulnerability reporting workflow end-to-end
• Verify 24-hour ENISA reporting capability
• Test security update delivery mechanism
• Conduct tabletop exercise for incident response

Month 11-12: Launch

Go-Live

• Publish EU Declaration of Conformity
• Apply CE marking
• Publish security update policy
• Announce CRA compliance to customers

Ongoing

• Continuous vulnerability monitoring
• Regular security testing
• Periodic SBOM updates
• Maintain technical documentation

Key Success Factors

1. Executive sponsorship — CRA compliance needs budget and authority
2. Cross-functional team — engineering, security, legal, and product
3. Start early — 12 months is tight for complex products
4. Automate everything — manual compliance doesn’t scale
5. Document as you go — don’t leave documentation for the end

Need help building your CRA compliance roadmap? I help organizations plan and execute cybersecurity regulation compliance. Get in touch.