EU Cyber Resilience Act puts secrets and access control in scope

At a glance

What this is: This is an analysis of how the EU Cyber Resilience Act changes secrets management, privileged access, and lifecycle controls for products with digital elements.

Why it matters: It matters because IAM, NHI, and PAM teams now have to treat credential handling and access auditability as product compliance requirements, not just internal hygiene.

By the numbers:

• The regulation entered into force in December 2024, vulnerability reporting obligations begin in 2026, and full compliance becomes mandatory by December 2027.

👉 Read Akeyless's analysis of CRA compliance for secrets and access control

Context

The CRA is a European Union regulation that makes cybersecurity obligations mandatory for products with digital elements, including software, connected hardware, and embedded systems. For identity teams, the key issue is not the regulation alone but the governance gap it exposes: static credentials, standing access, and fragmented control planes are now compliance liabilities as well as security risks.

That shifts responsibility toward provable control over secrets, certificates, and privileged access across the product lifecycle. The article frames this through secrets management, just-in-time access, and auditability, which makes it relevant to NHI governance, PAM, and broader IAM lifecycle design.

Key questions

Q: What breaks when product teams keep using standing privilege under the CRA?

A: Standing privilege creates a gap between policy and evidence. Under the CRA, organizations need to show that sensitive functions are protected throughout the product lifecycle. Persistent access makes it harder to prove who had access, when it was used, and whether unnecessary exposure was removed before audit or incident review.

Q: When should organisations prioritise secret and certificate lifecycle controls for CRA readiness?

A: They should prioritise them early, before compliance deadlines force emergency redesign. Secret and certificate lifecycle controls matter when products rely on distributed access, embedded credentials, or multiple deployment environments. If those controls are not centralised, the organisation will struggle to demonstrate secure-by-design behaviour or consistent incident traceability.

Q: What do security teams get wrong about just-in-time access for regulated products?

A: Teams often treat just-in-time access as a convenience layer rather than a governance model. Under CRA-style expectations, access must be time-bound, purpose-bound, and fully auditable. If elevation is not tied to a clear task and evidence trail, it may reduce convenience without materially improving compliance or control.

Q: Who is accountable when product identities and secrets are exposed?

A: Accountability sits with the organisation that manufactures or sells the digital product, even when tools or services are outsourced. The CRA places responsibility on the manufacturer to prove secure-by-design controls, so third-party dependency does not remove the need for identity governance, auditability, or lifecycle management.

Technical breakdown

Why static credentials fail the CRA security model

The CRA pushes organizations away from long-lived secrets because exposed credentials undermine both confidentiality and accountability. Static API keys, hardcoded passwords, and persistent certificates are hard to evidence, hard to rotate cleanly, and easy to reuse across systems. Once those secrets are embedded in software or operational workflows, they become lifecycle problems, not just authentication problems. In product environments, the control failure is usually not a single missing setting but an accumulated trust debt: the same credential is copied, shared, and forgotten across development, deployment, and support paths.

Practical implication: inventory every persistent credential path and prioritize elimination of long-lived secrets in product and operational workflows.

Just-in-time access and zero standing privilege for regulated products

Just-in-time access changes the access model from persistent entitlement to ephemeral authorization. That matters under CRA because the regulation expects organizations to reduce unnecessary exposure and demonstrate control over who or what can reach sensitive functions. Zero Standing Privilege is the governance principle behind that shift. It prevents dormant access from becoming an unreviewed attack path and makes access events easier to audit. For product teams, the issue is not only human admins but also build systems, support tools, and service accounts that can quietly accumulate privileged reach over time.

Practical implication: replace persistent admin paths with task-scoped access that expires after use and is logged end to end.

Auditability, traceability, and certificate lifecycle management

CRA compliance depends on proving what happened, when it happened, and which identities touched the system. That makes audit logs, correlation, and certificate lifecycle management central rather than optional. Certificates and keys need the same lifecycle discipline as other privileged artifacts because they are often the control plane for machine-to-machine trust. If the organisation cannot reconstruct access history or prove cryptographic hygiene, it will struggle with conformity assessment, incident handling, and secure update obligations. In practice, traceability becomes a control surface, not just a reporting feature.

Practical implication: bind secrets, certificates, and access events to a single audit trail that supports evidence collection and incident response.

NHI Mgmt Group analysis

CRA compliance turns credential governance into product governance. The regulation does not treat secrets, certificates, and privileged access as back-office controls. It makes them part of the security case for the product itself. That means identity teams can no longer separate access design from regulatory evidence. The practical conclusion is that product lifecycle controls now need the same scrutiny as application security controls.

Standing privilege is the wrong default for regulated software. The CRA’s emphasis on secure-by-design and secure-by-default products exposes how much risk accumulates from access that remains live without active use. Persistent access is easier to forget, harder to evidence, and more likely to violate the principle of minimised exposure. The implication is that access governance must move from review-based cleanup to task-scoped design.

Secret sprawl creates compliance ambiguity, not just attack surface. When credentials, keys, and certificates are scattered across tools and teams, no one can confidently prove where trust starts or ends. That weakens both security posture and regulatory defensibility. For practitioners, the issue is not simply rotating secrets more often but reducing the number of places where regulated trust is represented.

Zero Trust for products is now an identity governance problem. The article correctly ties Zero Trust, least privilege, and auditability to CRA readiness. Those are not standalone technical features. They are governance patterns that determine whether machine identities, service identities, and privileged operators can be controlled consistently across the product lifecycle. The practitioner takeaway is to align product compliance evidence with identity architecture rather than treating them as separate programmes.

From our research:

• 91% of former employee tokens remain active after offboarding, leaving organisations vulnerable to potential security breaches, according to The 2025 State of NHIs and Secrets in Cybersecurity.
• From our research: 44% of NHI tokens are exposed in the wild, being sent or stored over platforms like Teams, Jira tickets, Confluence pages, and code commits, according to The 2025 State of NHIs and Secrets in Cybersecurity.
• If your programme is moving from policy to implementation, NHI Lifecycle Management Guide shows how rotation, revocation, and offboarding fit together in practice.

What this signals

Secret lifecycle maturity is becoming a compliance signal, not just an operational metric. The CRA raises the cost of leaving long-lived credentials and certificates unattended across product environments. For teams managing regulated products, the real question is whether identity evidence can be produced fast enough to satisfy audit, incident reporting, and product conformity demands.

Standing privilege will be harder to justify in product and platform teams. As more digital products ship with embedded connectivity and external dependencies, the access model needs to become explicit and reviewable. That means product security, IAM, and compliance teams have to align on where elevation is allowed, how it expires, and which logs prove it happened.

With 44% of NHI tokens exposed in the wild, the governance pressure is no longer abstract. Identity programmes that cannot account for machine credentials across development, deployment, and support will struggle to keep regulatory evidence coherent.

For practitioners

• Map regulated product identities end to end Identify every human, service, and machine identity that can access product build, update, support, or telemetry functions. Include secrets, certificates, and tokens that enable those paths, then assign ownership for each identity and its lifecycle.
• Replace standing admin paths with task-scoped access Use just-in-time access for privileged tasks and require explicit expiry after the work is complete. Make sure every elevation event is logged, correlated, and retained so that access evidence is available for audits and incident review.
• Centralise secret and certificate lifecycle controls Reduce fragmented vaulting and remove duplicated credentials across teams and environments. Tie rotation, expiry, and revocation to a single lifecycle process so that product teams can prove which credentials were active at any point in time.
• Build CRA evidence into access governance Collect audit trails, approval records, and change history in a way that supports conformity assessment and vulnerability reporting. Evidence should show not only that controls exist, but that regulated identities were managed consistently across the product lifecycle.

Key takeaways

• The CRA makes access control and credential handling part of product compliance, not optional security hygiene.
• Standing privilege, fragmented secrets, and weak audit trails are the control failures most likely to undermine CRA readiness.
• Teams should centralise lifecycle governance for secrets, certificates, and privileged access before enforcement deadlines tighten.

Key terms

• Secret lifecycle management: Secret lifecycle management is the discipline of issuing, storing, rotating, expiring, and revoking credentials in a controlled way. It reduces the chance that keys, tokens, or passwords outlive their intended use and become silent trust failures across product, cloud, and support environments.
• Zero Standing Privilege: Zero Standing Privilege is an access model where no identity keeps persistent elevated access. Privileges are created only when needed, limited to a specific task, and removed immediately after use, which reduces exposure and improves auditability across human, service, and machine identities.
• Certificate lifecycle management: Certificate lifecycle management covers the creation, distribution, renewal, rotation, and revocation of certificates used to establish trust between systems. In regulated environments, it is essential because certificates frequently sit at the centre of machine identity, encrypted communication, and proof of system authenticity.
• Conformity assessment: Conformity assessment is the process of demonstrating that a product or system meets a regulatory requirement. For identity teams, it means proving that access controls, secrets handling, logging, and vulnerability processes are not just present but operating consistently enough to satisfy audit and compliance checks.

What's in the full article

Akeyless's full article covers the operational detail this post intentionally leaves for the source:

• How the CRA maps to specific secrets management, encryption, and access control requirements in day-to-day operations
• Implementation detail on just-in-time access and zero standing privilege for regulated product environments
• The platform architecture behind zero-knowledge storage and distributed fragments cryptography
• Examples of how centralized governance is positioned across multi-cloud and hybrid environments

👉 The full Akeyless article covers the CRA control areas, lifecycle obligations, and compliance positioning in more detail.

Deepen your knowledge

NHI governance, agentic AI identity, and machine identity security are core topics in our NHI Foundation Level course, the industry's only accredited NHI security programme. If you are responsible for identity security strategy or NHI governance in your organisation, it is worth exploring.