Annex III, Class I (16)
Smart home general purpose virtual assistants
Smart home assistants are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Always-on microphones, cloud back-ends and control over other home devices make these products sensitive for privacy and security alike.
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 (16) · Art. 32(2)
What the annex says
Smart home general purpose virtual assistants.
Paraphrase of Annex III, Class I (16); the Official Journal text governs.
Typical products in this category
- Voice assistants and smart speakers
- Home hubs whose core function is a general-purpose assistant
Where the boundary runs
A smart plug that can be controlled by an assistant is not an assistant. Products with security functions (locks, cameras, alarms) are a separate Class I category.
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
- Remote data processing that the product depends on is part of the product; include the cloud components in scope and risk assessment.
- Document data flows for voice data and third-party skills or integrations.
- Plan security update delivery for devices that consumers never touch.
- 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 smart home assistants product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). A smart plug that can be controlled by an assistant is not an assistant. Products with security functions (locks, cameras, alarms) are a separate Class I category.
- 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.