Annex III, Class I (3)
Password managers
Password managers are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. A password manager concentrates the credentials for everything else a user owns; a single vulnerability can expose thousands of accounts per user.
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 (3) · Art. 32(2)
What the annex says
Password managers.
Paraphrase of Annex III, Class I (3); the Official Journal text governs.
Typical products in this category
- Consumer and enterprise password vaults
- Browser-integrated credential managers shipped as separate products
- Team secret-sharing tools built around a vault
Where the boundary runs
A system that stores its own users' credentials for its own login is not a password manager. The category targets products whose purpose is to store and fill credentials for other services.
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
- Document the cryptographic design (key derivation, zero-knowledge properties, sync) in the Annex VII technical file.
- Treat any exploited vault-extraction or fill-injection vulnerability as a likely Article 14 event.
- Run coordinated disclosure with published SLAs; researchers target this category heavily.
- 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 password managers product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). A system that stores its own users' credentials for its own login is not a password manager. The category targets products whose purpose is to store and fill credentials for other services.
- 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.