Annex III, Class I (11)
Operating systems
Operating systems are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Everything else runs on top. Operating systems combine the largest code base, the widest deployment and kernel-level privilege.
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 (11) · Art. 32(2)
What the annex says
Operating systems.
Paraphrase of Annex III, Class I (11); the Official Journal text governs.
Typical products in this category
- Desktop, server and mobile operating systems
- Embedded and real-time operating systems shipped commercially
- Commercial Linux distributions placed on the market
Where the boundary runs
Free and open-source operating systems developed outside a commercial activity are not placed on the market; commercial distributions and OEM-customised systems are. An appliance that embeds an OS is classified by its own core function.
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
- The SBOM will be large; automate generation per release and diff between releases.
- Publish security advisories with fixed versions; downstream manufacturers need them to update their own SBOMs and VEX statements.
- Support periods for embedded OS lines commonly exceed ten years — document and price accordingly.
- 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 operating systems product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). Free and open-source operating systems developed outside a commercial activity are not placed on the market; commercial distributions and OEM-customised systems are. An appliance that embeds an OS is classified by its own core function.
- 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.