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EU Cyber Resilience Act Readiness Checklist for Manufacturers: Self-Assessment Before December 2027

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By NHI Mgmt Group, edited by Lalit Choda Updated 13 November 2026 12 min read
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The Cyber Resilience Act's reporting duties have applied since 11 September 2026, yet many manufacturers still cannot list which of their products are in scope, which class each falls into, or who would file a 24-hour early warning tonight. This readiness checklist is a self-assessment for manufacturers of products with digital elements: twelve checks mapped to the Regulation's article and annex numbers, each with a measure, a data source type and green, amber and red bands, plus a cadence table, a findings log and a remediation map. It is run by the product security lead with compliance, engineering and support owners, and signed off by the executive accountable for product compliance. The Regulation itself is explained in the EU Cyber Resilience Act Guide; this page tests whether you are ready for it.

Status (checked 13 November 2026): Regulation (EU) 2024/2847 applies in full from 11 December 2027 (Article 71). Article 14 reporting has applied since 11 September 2026, through the Single Reporting Platform that ENISA runs and that the European Commission states became operational that day. Under Article 69(3), reporting covers products placed on the market before 11 December 2027 as well, while the other obligations reach those older products only if they are substantially modified from that date (Article 69(2)). The Commission's implementation pages showed no amendment to these dates when checked.

What this health check covers

If you searched for a CRA readiness checklist or a Cyber Resilience Act compliance checklist, this is the working version. It covers the eight areas the plan for most manufacturers turns on: product inventory, class assignment, SBOM coverage, the vulnerability handling process, a tested 24-hour reporting path, a declared support period, the conformity route and technical file completeness. Four further checks cover component due diligence, the documented risk assessment, update delivery and the reporting scope for legacy products.

It does not repeat what each obligation means; the EU Cyber Resilience Act Vulnerability and Incident Reporting Guide and the EU CRA Product Classes Guide do that in depth. Importers, distributors and open-source software stewards have different duties and are out of scope here.

Key takeaways

  • Reporting is live now: an actively exploited vulnerability or severe incident in any product on the EU market, old or new, starts the 24-hour clock under Article 14 today.
  • Classification drives cost: default products can use internal control, but important class II and critical products need third-party assessment or certification under Article 32, which takes months to book.
  • The SBOM is a requirement, not a nice-to-have: Annex I Part II point 1 asks for a machine-readable SBOM covering at least top-level dependencies, and it forms part of the technical documentation.
  • Support periods are a product decision: at least five years unless the product's expected use is shorter (Article 13(8)), with the end month and year shown at purchase (Article 13(19)).
  • The technical file is the proof: Annex VII lists eight elements; gaps there are what a market surveillance authority finds first.

How to use this template

Copy the checklist table and the findings log into your own tracker. Run checks C1 and C2 first, because the product list and its classes set the denominator and the route for every other check, then score the rest per product line. Record every amber or red result as a finding with an owner and a due date. Re-run the checklist at the cadence below until 11 December 2027 and keep each completed version: the history shows a market surveillance authority that compliance work was planned and tracked.

Cadence and sign-off

ReviewFrequencyOwnerApproverEvidence kept
Reporting path test (C5)Quarterly, and after any change of contact, tool or main establishmentProduct security incident response leadHead of product securityExercise log with timestamps, platform account check, contact list
Product and class register (C1, C2)Before each product launch and quarterlyProduct compliance leadHead of productProduct register, classification decisions with reasoning
SBOM and vulnerability handling (C3, C4, C9, C11)MonthlyProduct security leadHead of engineeringSBOM inventory per release, vulnerability tracker, advisories issued
Full readiness run (C1 to C12)Quarterly until December 2027, then twice a yearProduct security leadAccountable executiveChecklist workbook, findings log, sign-off record
Independent re-performanceYearlyInternal audit, second line or external assessorAudit or risk committeeRe-performed samples, variance notes

Metrics

Each check is a readiness metric with a formula, scored per product or product family. NHI Mgmt Group recommended thresholds; adjust to your risk appetite. Where a duty already applies (C5, C12), anything below green is a compliance gap today.

IDCheck (article)Formula (numerator / denominator)Data source typeGreenAmberRed
C1Product inventory (Art 2 scope)Products with digital elements made available in the EU that are in the CRA product register with a scope decision / such products in sales and product catalogue recordsProduct register; sales and catalogue data100%95% to below 100%< 95%
C2Class assignment (Art 7, Art 8, Annexes III and IV)In-scope products with a recorded class (default, important class I or II, critical) and reasoning against the technical descriptions / in-scope productsClassification records100%90% to below 100%< 90%
C3SBOM coverage (Annex I Part II(1))Current releases with a machine-readable SBOM covering at least top-level dependencies, generated in the build / current releasesBuild pipeline artefacts; SBOM store≥ 95%80% to below 95%< 80%
C4Vulnerability handling process (Annex I Part II(2) to (8), Art 13(17))Annex I Part II points 2 to 8 with a documented, operating process, plus a published single point of contact / 8Process documents; published CVD policy and contact; vulnerability tracker8 of 86 or 7Below 6
C5Reporting within 24 hours tested (Art 14)Quarterly exercises in which the early warning was drafted and ready to submit within 24 hours of the awareness timestamp / exercises runExercise logs; platform account and role recordsAll exercises within 24 h; at least two named submittersOne or more exercises late, or only one named submitterNo exercise in the quarter, or no working platform access
C6Support period declared (Art 13(8), Art 13(19), Annex II(7))In-scope products with a determined support period, its reasoning recorded, and end month and year shown to buyers / in-scope productsSupport policy; product pages and packaging captures100%90% to below 100%< 90%, or any period below five years without an expected-use reason
C7Conformity route (Art 32)In-scope products with a selected route (module A, B+C, H or certification scheme) matching their class, and notified body booked where needed / in-scope productsConformity plan; notified body correspondence100%Route chosen for all, bookings below 100%Any class II or critical product without a route
C8Technical file completeness (Art 31, Annex VII)Annex VII points present and current in the file / 8, per productTechnical documentation index8 of 86 or 7Below 6
C9Component due diligence (Art 13(5), 13(6))Third-party and open-source components in current releases with a recorded due diligence check and a route to report vulnerabilities to the maintainer / such componentsComponent register; SBOM; supplier records≥ 95%80% to below 95%< 80%
C10Risk assessment documented (Art 13(2) to (4))In-scope products with a cybersecurity risk assessment covering Annex I Parts I and II, updated in the last 12 months / in-scope productsRisk assessment records100%90% to below 100%< 90%
C11Update delivery (Annex I Part II(2), (7), (8); Art 13(9))Security fixes in the quarter delivered free, through a secure channel, with an advisory, and separately from feature updates where feasible / security fixes in the quarterRelease notes; advisories; update channel records≥ 95%85% to below 95%< 85%
C12Legacy product reporting scope (Art 69(3))Products already on the market before 11 December 2027 that are covered by the reporting process and vulnerability monitoring / such productsProduct register; monitoring scope100%95% to below 100%< 95%

Deadlines and routes at a glance

ItemRequirementSource
Actively exploited vulnerabilityEarly warning within 24 hours, notification within 72 hours, final report within 14 days after a corrective measure is availableArt 14(2)
Severe incidentEarly warning within 24 hours, notification within 72 hours, final report within one month of the notificationArt 14(4)
Where to reportSingle Reporting Platform, to the CSIRT designated as coordinator in the Member State of main establishment and to ENISA at the same timeArt 14(1), 14(7)
Default productsAny Article 32(1) procedure, including internal control (module A)Art 32(1)
Important class IModule A only where harmonised standards, common specifications or certification were fully applied; otherwise B+C or HArt 32(2)
Important class IIB+C, H, or a certification scheme at assurance level at least substantialArt 32(3)
CriticalCertification scheme under Article 8(1), otherwise a paragraph 3 procedureArt 32(4)
RecordsTechnical documentation and declaration kept at least 10 years or the support period, whichever is longerArt 13(13)

Article 64 sets maximum fines of EUR 15 million or 2.5% of worldwide annual turnover for breaches of Annex I and Articles 13 and 14, whichever is higher, with lower tiers for other obligations.

How to collect the data

  1. Start from what you sell: pull the catalogue and sales records for products made available in the EU, including firmware, apps and remote data processing that the product needs, and record a scope decision per product.
  2. Classify against the official descriptions: compare each product's core functionality with the Annex III and Annex IV categories and the Commission's implementing act on technical descriptions, and store the reasoning.
  3. Take SBOMs from the build: count releases with an SBOM produced by the pipeline, not documents assembled by hand afterwards.
  4. Walk Annex I Part II point by point: for C4, ask for the evidence of each point operating in the last quarter, such as an advisory published or a report received through the contact address.
  5. Time the exercise: for C5, start the clock when a simulated report reaches the contact point and stop it when the early warning is ready, with the platform account checked as working.
  6. Read the file, not the plan: for C8, open each Annex VII element in the technical documentation and confirm it is current.

Red flags that need action now

  • No one in the organisation can sign in to the Single Reporting Platform, or only one person can.
  • No agreed definition of the awareness moment that starts the 24-hour clock.
  • Products already on the market left out of reporting because the team believes the CRA starts in December 2027.
  • No published contact point or coordinated vulnerability disclosure policy.
  • Class II or critical products with no notified body or certification plan.
  • Support periods set by marketing without the Article 13(8) factors recorded, or shorter than five years with no reason.
  • SBOMs produced only on request, or covering only some product lines.
  • Security fixes shipped only inside feature releases with no advisory.

A tampered update channel is the kind of event that can make an incident severe under Article 14(5), because it can introduce malicious code. That is why update signing and build integrity belong in the readiness scope, even though no single check above names them.

Findings log

Finding IDFindingCheckSeverityOwnerDue dateStatus
HC-CRA-01[Only one platform submitter; no deputy]C5[Critical][PSIRT lead][DD/MM/YYYY][Open]
HC-CRA-02[Router family not yet classified against Annex III]C2[High][Product compliance lead][DD/MM/YYYY][In progress]
HC-CRA-03[Mobile app releases have no SBOM]C3[High][Mobile engineering lead][DD/MM/YYYY][Open]
HC-CRA-04[Support end date missing from product pages]C6[Medium][Product marketing lead][DD/MM/YYYY][Open]
HC-CRA-05[Technical file lacks test reports for Annex I Part II]C8[Medium][Quality lead][DD/MM/YYYY][Open]

Rate a finding critical when it affects a duty that applies now (reporting) and high when it blocks the conformity route before December 2027.

Remediation map

Finding typeWhere to fix it
Scope and obligations unclear (C1, C10)EU Cyber Resilience Act Guide
Class and conformity gaps (C2, C7)EU CRA Product Classes Guide; EU Cyber Resilience Act Harmonised Standards Guide
SBOM and component gaps (C3, C9)SBOM Guide; SBOM operations
Disclosure and handling gaps (C4, C11)ISO/IEC 29147 and 30111 Vulnerability Disclosure and Handling Guide; Bug Bounty and Vulnerability Disclosure Guide
Reporting path gaps (C5, C12)EU Cyber Resilience Act Vulnerability and Incident Reporting Guide
Hardware and firmware components (C3, C9)Hardware and Firmware SBOM Guide

References

This guide summarises obligations under Regulation (EU) 2024/2847 and is not legal advice. Related NHI Mgmt Group resources: EU Cyber Resilience Act Guide · EU CRA Product Classes Guide · SBOM Guide · EU Cyber Resilience Act Executive Briefing

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NHIMG Editorial Note
Researched and written by the NHI Mgmt Group editorial team using AI tools, under the editorial direction of Lalit Choda. Facts are drawn from the sources listed on this page and checked by our automated quality process. Last updated 13 November 2026. Spotted an error? Use our contact page.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM and Agentic AI security. nhimg.org

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