The EU Cyber Resilience Act (CRA) is no longer a proposal — it's law, with a compliance deadline that most electronics companies are sleepwalking towards. If you're building connected products for the European market, this affects you directly. And if your board hasn't discussed it yet, you're already behind.
What the CRA actually requires
The CRA mandates that all products with digital elements sold in the EU must meet baseline cybersecurity requirements throughout their entire lifecycle. This isn't just about the software on the device — it covers hardware design decisions, firmware update mechanisms, vulnerability disclosure processes, and post-market surveillance obligations.
For electronics companies, this means cybersecurity can no longer be bolted on at the end of the development process. It must be a design input from day one, influencing component selection, architecture decisions, communication protocols, and manufacturing processes.
Why most boards aren't ready
Most electronics company boards treat cybersecurity as an IT issue — something the software team handles. The CRA fundamentally changes this. It places legal obligations on manufacturers, importers, and distributors to ensure products are cyber-secure. Non-compliance carries penalties of up to €15 million or 2.5% of global turnover.
Boards need to be asking specific questions: Do our products have secure boot and encrypted firmware updates? Do we have a vulnerability disclosure and response process? Can we provide a Software Bill of Materials (SBOM)? Do we have ongoing security monitoring for products already in the field?
For most small and mid-sized electronics companies, the honest answer to most of these questions is no — or "we think so, but we haven't formally verified it."
The opportunity for prepared companies
There's a silver lining. Companies that get ahead of CRA compliance will have a genuine competitive advantage. Customers — particularly large enterprises and public sector buyers — will increasingly require CRA compliance as a procurement criterion. Being able to demonstrate compliance early positions you as a trusted supplier in a market where many competitors will be scrambling.
What boards should do now
Commission a gap analysis against the CRA essential requirements. Build cybersecurity into your product development process — not as an afterthought but as a design constraint alongside EMC, safety, and environmental compliance. Ensure you have technical expertise at board level that understands the intersection of hardware, firmware, and cybersecurity.
The companies that treat this as a box-ticking exercise will struggle. The ones that treat it as an opportunity to build genuinely more secure products will thrive.