CRA Compliance Checklist for Embedded & IoT Manufacturers

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CRA Compliance Checklist for Embedded & IoT Manufacturers

Is your device ready for EU market access under the Cyber Resilience Act?

The EU Cyber Resilience Act is moving fast, and embedded/IoT manufacturers cannot afford to wait until 2027 to prepare.

If your product contains firmware, software, connectivity, OTA updates, or third-party components, CRA readiness needs to start now.

This checklist helps engineering and product teams quickly assess key gaps across Secure Boot, OTA security, SBOM, vulnerability handling, and audit-ready documentation.

Early action means fewer redesigns, smoother CE/CRA compliance, and safer EU market access. Use this practical checklist to evaluate your embedded product before the CRA deadline.

Product Coverage & Classification

  • Does the product contain firmware/software (“digital element”)?
  • Does it connect directly or indirectly to networks?
  • Have you classified it as Default / Important / Critical?

Secure Boot & Firmware Integrity

  • Secure Boot chain implemented (ROM → Bootloader → Kernel → App)
  • Hardware Root of Trust enabled (TPM, Secure Element, TrustZone)
  • Debug ports locked down (JTAG/SWD)

Secure OTA Update Readiness

  • Firmware updates are cryptographically signed
  • Updates are encrypted in transit and storage
  • Rollback protection (A/B partitions, version pinning)
  • Update audit logs and traceability maintained

SBOM & Software Transparency

  • SBOM generated (CycloneDX/SPDX)
  • Open-source dependencies tracked continuously
  • Vulnerability monitoring process defined

Vulnerability Handling & Lifecycle Support

  • PSIRT / vulnerability response workflow in place
  • Patch timelines and responsibilities assigned
  • Incident reporting readiness (2025 obligations)

Logging, Monitoring & Access Control

  • Critical security events logged securely
  • Authentication and access control enforced
  • Sensitive data encrypted and protected

Compliance Documentation (Audit-Ready)

  • Threat modeling / risk assessment completed (TARA)
  • Technical file prepared for CE + CRA conformity
  • Evidence reports available (tests, logs, SBOM, update policy)

Need Help Becoming CRA-Ready?

At Epteck GmbH, we help embedded and IoT manufacturers implement:

✔ Secure Boot
 ✔ Secure OTA pipelines
 ✔ SBOM automation
 ✔ Firmware security testing
 ✔ CRA + CE + GPSR audit documentation

👉 Book a free CRA readiness consultation:
 https://calendly.com/epteck/discovery

 

Learn Also: Does the EU Cyber Resilience Act applies to your product and what exactly counts as ‘in scope’?

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