Europe's Cyber Resilience Act: The 'GDPR for things'

Introduction

The European Union has long been at the forefront of digital oversight, with the General Data Protection Regulation setting a global benchmark for data privacy. In December 2025, the EU took another step toward shaping the future of the digital economy with the enactment of the Cyber Resilience Act. This mandate addresses one of the defining vulnerabilities of our age: the insecurity of connected devices, software and digital ecosystems. CRA is expected to be implemented by 2027.

The initiative introduces an enforceable framework for cybersecurity across all products with digital components. Its ambition is to transform baseline expectations for connected technologies, ensuring that security is a prerequisite for participation in one of the world's largest markets. In this sense, CRA can be seen as the "GDPR for things." While GDPR gave individuals control over how their personal data is collected and processed, CRA ensures that the devices and systems handling that data are secure and resilient.

The Take

The Cyber Resilience Act converts what were once considered best practices into legal obligations. Security by design, proactive vulnerability management and supply chain transparency have long been recommended by experts, but compliance has been uneven and often neglected in pursuit of speed-to-market objectives. With CRA, these measures are no longer negotiable. Any company wishing to access the EU market must adopt them as part of their standard operations. Much like GDPR reshaped data privacy not just in Europe but around the world, CRA is expected to redefine global norms for digital product security. Early adopters will likely be rewarded with competitive advantage, brand trust and smoother market access. Organizations that delay may face exclusion, fines and rushed redesigns at great cost.

The Cyber Resilience Act explained

At its core, CRA is a horizontal regulation applied across industries, similar to GDPR. It does not target only healthcare, finance or critical sectors but instead covers the broad category of "products with digital elements." This includes everything from smart speakers and connected thermostats to industrial controllers, embedded systems in automobiles, and rooftop solar panels. Not just consumers are concerned when it comes to the security of their devices. According to 451 Research's Voice of the Enterprise: Internet of Things, OT Security 2025 survey, 45% of US-based respondents are concerned about IoT endpoint and device security, compared with 51% of European respondents.

Figure 1: Top three security concerns for European vendors 

The regulation requires security to be built into products from their earliest design stages. Security cannot be patched in as an afterthought. Devices must incorporate secure defaults, strong authentication and reliable encryption before they reach the market. Once deployed, manufacturers remain responsible for maintaining security throughout a product's supported lifetime. This means continuous monitoring for vulnerabilities, issuing patches, and maintaining transparent communication with customers.

Equally transformative is CRA's emphasis on supply chain accountability. Modern products integrate countless third-party software libraries, hardware modules and open-source components. CRA requires organizations to know what is inside their products and to document these elements in a software bill of materials (SBOM). In practice, this means manufacturers must monitor not only their own security practices but also those of their suppliers. Finally, to gain access to the EU market, digital products must carry the Conform European marking standards, which are already familiar in areas like consumer safety and environmental standards. Under CRA, CE marking confirms cybersecurity compliance. Without it, products cannot be sold in the EU.

CRA vs. GDPR: Shared DNA, different goals

The comparison with GDPR is inevitable. Both regulations are ambitious EU initiatives with profound international influence. Their scopes differ, however. GDPR's primary concern is the protection of personal data — how it is collected, processed and shared. In contrast, CRA focuses on the resilience of the digital products themselves. Both frameworks share a common DNA of enforceability. They impose strict obligations on companies, demand transparency and carry substantial penalties for noncompliance.

Just as GDPR fines reshaped corporate approaches to privacy, CRA penalties — up to €15 million, or 2.5% of global turnover — are designed to ensure executive attention. There is also overlap. Both regulations emphasize confidentiality, integrity, availability, incident reporting and life-cycle management. However, CRA expands these requirements to include secure defaults, coordinated vulnerability disclosure and supply chain transparency. If GDPR handed individuals control over their data, CRA gives societies control over the reliability and safety of the digital infrastructure upon which they increasingly depend.

Transforming industry practices

The Cyber Resilience Act's impact on manufacturers and IT providers will be significant. For developers, it shifts security considerations upstream. No longer can security be bolted on or marketed as an optional feature. Elements such as secure boot mechanisms, robust encryption, automated vulnerability scanning and reliable update channels must be built in from the outset. This will alter product architectures and development timelines. Compliance checks must be embedded into design processes, with every component evaluated against regulatory expectations. For some businesses, this will require retooling development pipelines and investing in new expertise.

The initiative will also likely have a global ripple effect. Because compliance is required for selling products in the EU, non-European manufacturers must adopt CRA standards to access the market. Rather than maintain separate standards for different regions, many multinational organizations will likely apply CRA-level security globally, just as they did with GDPR's privacy rules.

Over time, CRA could raise the baseline of cybersecurity worldwide. Early compliance will function as a market differentiator. Businesses that move quickly will enjoy consumer confidence, smoother partnerships and reduced risk of regulatory disruption. Those that delay risk exclusion, reputational harm and costly emergency redesigns.

Preparing for CRA

The Cyber Resilience Act's phased timeline gives organizations until late 2027 to achieve full compliance, but the scale of the changes means preparation must begin now. Businesses must first designate internal leadership for CRA readiness. This leadership should coordinate risk management, oversee product security architecture, and prepare for audits. Manufacturers must then evaluate their current products against CRA standards, focusing on hardware, firmware, operating systems and third-party dependencies. This requires a detailed inventory of components and a review of vulnerability management practices.

Architectural changes will follow. Products must incorporate secure mechanisms such as cryptographic authentication, encrypted communication and fallback protocols. Strong update mechanisms must be established so that patches can be deployed promptly and transparently. CRA also requires thorough documentation. Companies must integrate reporting and audit-friendly records into their development and maintenance pipelines. These are not only compliance requirements but also defenses against reputational damage in the event of incidents. Finally, businesses must stay attentive to evolving guidance. CRA establishes expert groups and oversight bodies that will continue to refine requirements and interpretations.

Examples

In the automation space, manufacturers of robotics and control systems need to reimagine their development pipelines with security integrated from the start. Controllers should be designed with hardened firmware, authenticated communication between sensors and actuators, and reliable over-the-air updates. Many automation products currently lack consistent long-term patching strategies, leaving them vulnerable as libraries age. To comply, manufacturers will require proactive vulnerability monitoring and life-cycle support plans, ensuring that every device in a production line remains secure throughout its operational life.

In the industrial automation category, where programmable logic controllers and supervisory systems often manage critical infrastructure, the stakes are even higher. Many existing systems rely on legacy components with little transparency about their origins or maintenance. CRA compliance will require the creation of detailed SBOMs, making third-party dependencies visible and accountable. Industrial automation providers will also need to introduce coordinated vulnerability disclosure programs so that flaws are identified and resolved quickly, reducing the gap between discovery and remediation.

Solar inverters add another layer of urgency. Inverters are increasingly connected, forming part of distributed energy systems where vulnerabilities can ripple across the grid. Yet many inverter products still rely on default passwords, insecure communication protocols or outdated cloud integrations. CRA compliance will demand the elimination of insecure defaults, the implementation of strong encryption for device-to-cloud communications, and secure firmware updates throughout the inverter's life cycle. Documenting all embedded software will be critical as well, particularly given the reliance on open-source components in energy technology. These steps will not only satisfy compliance but also help protect Europe's renewable energy networks from systemic risks.

For smart home device manufacturers, compliance will mean a fundamental rethink of product design. Many IoT appliances reach consumers with minimal security and no patch mechanisms. CRA obliges manufacturers to support devices for their declared lifespans, which means investing in patch infrastructure, customer communication and vulnerability reporting. Bolstering default security — such as enabling encryption and strong authentication out of the box — will be necessary to protect end users without requiring technical expertise. If implemented properly, these changes could transform security from a weakness into a trust-building feature for consumers.

Outlook

The Cyber Resilience Act signals the start of the next evolution in digital regulation. Just as GDPR elevated privacy from a niche concern to a global expectation, CRA aims to elevate cybersecurity from a marketing differentiator to a minimum legal requirement. Its global impact will be unavoidable. Supply chains are international, products cross borders daily, and vulnerabilities rarely stay confined to one region.

As a result, CRA-level security is likely to become the baseline worldwide, either through direct adoption in other jurisdictions or via multinationals applying the standards universally. By the final implementation deadline of December 2027, manufacturers will need to demonstrate compliance not as an exception but as a matter of course. Those that succeed will gain trust and leadership in an increasingly competitive market. Those that fail will face exclusion, penalties and reputational damage.