Annex III, Class I (9)
Public key infrastructure and digital certificate issuance software
PKI & certificate issuance are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Certificates underpin trust for TLS, code signing and device identity. Mis-issuance or key compromise propagates to every relying party.
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 (9) · Art. 32(2)
What the annex says
Public key infrastructure and digital certificate issuance software.
Paraphrase of Annex III, Class I (9); the Official Journal text governs.
Typical products in this category
- Certificate authority software
- Certificate lifecycle management platforms
- Hardware security module management software
Where the boundary runs
Software that merely consumes certificates is not PKI software. The category targets products whose core function is issuing, managing or revoking certificates and keys.
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 key ceremonies, HSM integration and revocation infrastructure.
- Treat mis-issuance caused by a vulnerability as a security-of-product incident, potentially severe.
- Publish a CVD policy; PKI software receives high-quality researcher reports.
- 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 pki & certificate issuance product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). Software that merely consumes certificates is not PKI software. The category targets products whose core function is issuing, managing or revoking certificates and keys.
- 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.