Annex III, Class I (15)
ASICs and FPGAs with security-related functionalities
Security ASICs & FPGAs are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Like secure microcontrollers, these parts implement trust anchors in hardware; bitstream and firmware vulnerabilities are hard to remediate in the field.
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 (15) · Art. 32(2)
What the annex says
Application specific integrated circuits (ASIC) and field-programmable gate arrays (FPGA) with security-related functionalities.
Paraphrase of Annex III, Class I (15); the Official Journal text governs.
Typical products in this category
- Crypto accelerators
- Programmable logic used for secure boot or key storage
- Custom security silicon for network or storage products
Where the boundary runs
Programmable logic without a security function is a default product. The manufacturer of the device that embeds the part classifies the device separately.
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
- Treat bitstreams, HDL-derived firmware and toolchain outputs as software components in the SBOM.
- Document bitstream encryption and authentication design.
- Define the update and revocation path for fielded parts.
- 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 security asics & fpgas product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). Programmable logic without a security function is a default product. The manufacturer of the device that embeds the part classifies the device separately.
- 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.