CRA readiness checklist for software and connected-product manufacturers

Cyber Resilience Act readiness is operational: a product inventory with owners, an SBOM per version, continuous vulnerability matching with exploitation signals, a rehearsed Article 14 workflow with awareness discipline, a coordinated disclosure policy, a defined support period per product and technical documentation you can hand over. This checklist lists each item with the evidence that proves it.

By the Vellaci teamPublished Updated 5 min readOperational guidance, not legal advice

Key facts

Since 11 Sep 2026
Article 14 reporting applies; maintain an active awareness, response and evidence workflow
By 11 Dec 2027
Full conformity: classification, risk assessment, Annex VII documentation, conformity route, CE marking
Continuous
SBOM per release, vulnerability handling, security updates, disclosure

Local checklist

Track your team's next steps

Mark items as you review them. Your selections stay in this browser and are not sent to Vellaci; status means progress, not legal compliance.

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Governance

ItemWhyEvidence to keep
Product inventory with owners and lifecycle statesEvery obligation attaches to a product; unknown products are unmanaged riskRegistry export with owner, security owner, state, versions
Preliminary CRA scope assessment per productDetermines whether and how the regulation appliesAssessment record with reasoning and date
Classification with reasoning and approverSets the conformity routeClassification record, Annex reference, approver
Named roles: product owner, security owner, assigned representative, compliance leadArticle 14 runs on people who can act within hoursRunbook, org chart, deputies

SBOM and vulnerability handling

ItemWhyEvidence to keep
SBOM per supported version, generated in the release pipelineAnnex I Part II(1); the base for triageSBOM files with checksums bound to versions
Continuous matching against OSV/advisories, KEV and EPSSExploitation evidence arrives after releaseMatching job logs, findings with intelligence provenance
Triage with mandatory reasons and remediation ownershipAnnex I Part II(2): remediate without delayDecision history per finding
Fixed releases linked to findings; VEX for non-affectedEvidence of remediation and of due diligenceRelease notes, VEX documents
Regular security testingAnnex I Part II(3)Test reports with scope and date

Disclosure and updates

ItemWhyEvidence to keep
Published CVD policy and security.txt on every product domainAnnex I Part II(5)–(6)Policy versions, security.txt with expiry
Intake process with acknowledgement and handling SLAsA policy needs a working mailboxIntake log, response times
Security advisories for fixed vulnerabilitiesAnnex I Part II(4)Advisory archive
Secure, free update mechanism per productAnnex I Part I and Part II(7)–(8)Update mechanism description, signing procedures

Incidents and reporting

ItemWhyEvidence to keep
Awareness rule defined and trainedEvery Article 14 deadline runs from itWritten rule, training record
Assigned representative and deputy with ENISA platform accessWeekend early warnings happenAccess confirmation, deputy roster
Incident and vulnerability reportability review with rationaleHuman decision on recordReview records including not-reportable decisions
Server-computed deadlines and alert thresholdsCalendars do not survive incidentsCase records with deadline history
Rehearsed 24 h / 72 h workflow with submission evidenceA drill finds the missing password before the regulator doesDrill reports
User communication templateArt. 14(8)Template and sent examples

Support and documentation

ItemWhyEvidence to keep
Support period defined, justified and published per productArt. 13(8); Annex IISupport period record with rationale; product page
Cybersecurity risk assessment per productArt. 13(2)–(3)Assessment mapped to Annex I Part I
Technical documentation assembled per Annex VIIArt. 31Sectioned documentation with evidence links
Retention of documentation and updates for ten yearsArt. 13(9), 13(13)Retention policy, archive
Conformity route chosen; notified body engaged where neededArt. 32; capacity is scarceProcedure decision, body correspondence

How to use this checklist

Assign an owner and an evidence location to each item, then review progress at a cadence that fits your release and support cycles. Two rules keep the checklist useful. First, an item is established only when the evidence exists and can be retrieved; a policy nobody can find still needs work. Second, the 'why' column paraphrases the regulation for operational planning; where an item does not apply to a specific product, preserve the product-specific reasoning and have the conclusion reviewed. The interactive list at the top saves only review ticks in this browser; it is not a compliance score or a shared company record.

Sequence

  1. Now: inventory, scope, owners, SBOM pipeline, vulnerability matching, CVD policy and security.txt.
  2. Now (Article 14 reporting has applied since 11 September 2026): maintain the awareness rule, assigned representative, reporting runbook, rehearsals and submission evidence.
  3. 2026–2027: classification, risk assessment, support periods, Annex VII documentation, conformity route and notified body.
  4. By 11 December 2027: apply the full requirements to products placed on the market from that date, and to earlier products where the regulation's substantial-modification rule applies; complete the relevant conformity route and documentation.
  5. Continuously: SBOM per release, triage, updates, advisories, documentation reviews, quarterly drills.

Frequently asked questions

Where should a small team start?
With the SBOM pipeline and the Article 14 reporting runbook. The SBOM makes component exposure measurable; the runbook supports obligations that have applied since 11 September 2026. Vellaci's free assessment ranks operational gaps in about eight minutes.
How do we prove readiness to a customer or an auditor?
With records, not statements: the registry export, SBOMs with checksums, decision histories, drill reports, the CVD policy and support periods. A readiness score is a management view; the evidence behind each item is what convinces.
We have dozens of products. Where is the leverage?
In the shared processes: one SBOM pipeline pattern applied to every build, one triage workflow, one runbook, one documentation template. Product-specific work — classification, support period, risk assessment — then becomes filling in a structure rather than inventing one. Start with the products on the EU market with the longest expected use; they carry the most obligation-years.
What if our reporting workflow was not ready on 11 September 2026?
Article 14 applies from that date. Put a workable process in place promptly: define how awareness is confirmed and recorded, assign an accountable representative and deputy, maintain access to the official reporting platform, rehearse the deadline workflow and preserve evidence of decisions and submissions. Get qualified advice on event-specific reportability questions.

Ready to operationalise this?

Start with the free preliminary assessment — sixteen questions, about eight minutes.