Annex III, Class II (3)
Tamper-resistant microprocessors
Tamper-resistant MPUs are important product, class ii under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Tamper resistance is a claim about physical and logical attack resistance; the market relies on it for payment, identity and infrastructure. Class II requires third-party conformity assessment.
Updated 2026-09-12 · Operational guidance, not legal advice.
- Classification
- Important product — Class II
- Conformity route
- Third-party assessment required
- Reference
- Annex III, Class II (3) · Art. 32(3)
What the annex says
Tamper-resistant microprocessors.
Paraphrase of Annex III, Class II (3); the Official Journal text governs.
Typical products in this category
- Processors with physical tamper detection and response
- Security co-processors for payment and identity terminals
Where the boundary runs
Microprocessors with security-related functionality but without tamper resistance are Class I. Smartcards and secure elements are Annex IV critical.
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
Third-party assessment required. EU-type examination (Module B) with conformity to type (Module C), or full quality assurance (Module H), involving a notified body; alternatively a European cybersecurity certificate at assurance level 'substantial' or higher where a scheme exists. (Art. 32(3))
What to prepare operationally
- Existing certifications (Common Criteria, EMVCo) inform but do not replace CRA conformity assessment until schemes are recognised.
- Document the threat model for physical attacks in the technical file.
- Coordinate advisories with downstream terminal and device manufacturers.
- 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 tamper-resistant mpus product an important product — class ii?
- Only where the listed function is the product's core functionality (Article 7). Microprocessors with security-related functionality but without tamper resistance are Class I. Smartcards and secure elements are Annex IV critical.
- What changes compared with a default product?
- EU-type examination (Module B) with conformity to type (Module C), or full quality assurance (Module H), involving a notified body; alternatively a European cybersecurity certificate at assurance level 'substantial' or higher where a scheme exists. 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.