Annex III, Class I (4)
Software that searches for, removes or quarantines malicious software
Anti-malware are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Security software runs with the highest privileges and parses hostile input all day; a flaw in a scanner turns the guard into the entry point.
Updated 2026-09-12 · Operational guidance, not legal advice.
- Classification
- Important product — Class I
- Conformity route
- Self-assessment only with fully applied standards
- Reference
- Annex III, Class I (4) · Art. 32(2)
What the annex says
Software that searches for, removes, or quarantines malicious software.
Paraphrase of Annex III, Class I (4); the Official Journal text governs.
Typical products in this category
- Endpoint protection and EDR agents
- Mail and file gateway scanners
- Malware removal utilities
Where the boundary runs
A firewall or an intrusion prevention system is Class II, not Class I. Content filters that only block URLs without scanning for malicious code are usually default products.
The test is core functionality (Article 7). Record the reasoning and the approver: the category determines the conformity assessment route and market surveillance authorities can challenge it.
Conformity assessment
Self-assessment only with fully applied standards. Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). (Art. 32(2))
What to prepare operationally
- Keep the SBOM current for parser libraries (archives, PDF, Office formats) — they dominate the exploited-vulnerability history of this category.
- Document privilege boundaries and self-protection mechanisms.
- Define what an 'actively exploited' event looks like for a detection-evasion versus a code-execution flaw; only the latter is typically a security-of-product incident.
- Maintain an SBOM per released version, match it continuously against vulnerability intelligence, and keep the Article 14 runbook rehearsed — these apply to every product with digital elements, listed or not.
Frequently asked
- Is every anti-malware product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). A firewall or an intrusion prevention system is Class II, not Class I. Content filters that only block URLs without scanning for malicious code are usually default products.
- What changes compared with a default product?
- Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). The essential requirements of Annex I, the vulnerability-handling duties and Article 14 reporting apply to every product with digital elements regardless of category.
- From when?
- Article 14 reporting obligations have applied to all manufacturers since 11 September 2026. Conformity assessment and CE marking under the CRA apply from 11 December 2027; products placed on the market before that date are not required to be re-assessed unless substantially modified.