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CRA security testing cadence: what evidence do teams need now?


(@nhi-mgmt-group)
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Joined: 1 year ago
Posts: 19382
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TL;DR: The Cyber Resilience Act makes effective and regular security testing a defensible compliance requirement, and Equixly argues that manufacturers need repeatable evidence for LLM apps, MCP servers, web apps, and APIs, not just one-off scans. The compliance burden now sits on testing cadence, remediation proof, and product-scoped documentation rather than on a single method.

NHIMG editorial — based on content published by Equixly: The Cyber Resilience Act and the key role of security testing

By the numbers:

Questions worth separating out

Q: How should manufacturers prove that security testing under the CRA is effective?

A: They should link each test to a product risk, record what was tested, document what was not assessed, and keep retest evidence after fixes.

Q: Why do APIs and remote processing create CRA governance risk?

A: Because they may be part of the product’s actual function, not just supporting infrastructure.

Q: What breaks when security testing is not repeated after meaningful product changes?

A: The evidence chain breaks.

Practitioner guidance

  • Define a product-scoped testing policy Tie test frequency to product risk, release cadence, and security-relevant changes such as authentication updates, new APIs, and remote processing dependencies.
  • Preserve evidence from test to retest Keep the original finding, severity or exploitability assessment, remediation record, and verification evidence together so they can support CRA technical documentation.
  • Map identity-dependent components into the testing scope Include service accounts, tokens, tool permissions, and hosted backends in the test plan wherever the product function relies on them.

What's in the full article

Equixly's full blog post covers the operational detail this post intentionally leaves for the source:

  • Exact interpretation of CRA scope for LLM apps, MCP servers, browser-only web apps, and APIs
  • How Equixly positions continuous penetration testing as evidence for repeatable compliance records
  • Examples of findings, retest records, and remediation proof that can support CRA technical documentation
  • The article's step-by-step explanation of how testing cadence should follow product risk and change events

👉 Read Equixly's analysis of CRA security testing for LLM apps, MCP servers, web apps, and APIs →

CRA security testing cadence: what evidence do teams need now?

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(@mr-nhi)
Member Moderator
Joined: 3 months ago
Posts: 18973
 

Evidence quality is now a compliance control, not a post-release luxury. The CRA shifts security testing from an internal assurance task to a documentable obligation. Manufacturers need to show not only that they tested, but that the tests were meaningful, repeated, and tied to product risk. That raises the bar for engineering teams and compliance teams alike, because a finding without context is not defensible evidence. The practical conclusion is that test artefacts must be preserved with the same discipline as release records.

A question worth separating out:

Q: Which regulatory control area is most directly affected when testing evidence is weak?

A: Technical documentation and conformity assessment are the most immediate pressure points, because regulators may ask how the manufacturer tested the product, what changed since the last test, and whether identified issues were verified as fixed. Weak evidence also complicates incident and vulnerability reporting where proof of diligence matters.

👉 Read our full editorial: Cyber Resilience Act testing turns product security evidence into compliance



   
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