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PRACTICAL GUIDANCE — NOT LEGAL TEXTNEEDS REVIEW

CRA preparation action plan

Six workstreams and 29 suggested deliverables to prepare for the Cyber Resilience Act, each linked to the provisions that motivate it. Recommendations, not obligations.

Prepared by regulation-cra.euUpdated 2 November 2026Version 1.0Not yet reviewed by a named expert

What it is for

This plan groups the preparation work for the Cyber Resilience Act into six workstreams. Each item is a suggested deliverable: a recommendation that cites the provisions motivating it, not a legal obligation in itself. It is written mainly from a manufacturer's perspective; importers, distributors and open-source software stewards should keep only the items relevant to their role.

What the text requires

Two dates frame the plan: Article 14 (reporting obligations) applies from 11 September 2026 and the Regulation applies from 11 December 2027 (Article 71(2)). The obligations of Article 14 also apply to in-scope products placed on the market before 11 December 2027 (Article 69(3)).

How to use it

  1. Start with workstream 1 (scoping) for each product; the other workstreams depend on it.
  2. Read the cited provisions before planning an item; delete what does not apply to your role and add your own items.
  3. Assign an owner and a target date to each item.
  4. Keep the evidence produced (documents, procedures, records): it feeds the technical documentation and the answers to market surveillance authorities.
  5. Review the plan when delegated acts, implementing acts, harmonised standards or official guidance are published.

Good practice (recommendation, not a legal requirement)

Every item below is a recommendation. Where an item reflects an obligation, the obligation lies in the cited provision, with its exact conditions and exceptions — read it there.

1. Governance and scoping

#Suggested deliverableProvisions
1.1An owner for CRA preparation and an inventory of products with digital elements and versionsArticle 2(1), Article 3, point (1)
1.2A documented scoping analysis per product (see the scoping checklist)Article 2, Article 3, point (2), Article 3, point (22)
1.3Your role per product and market, including cases where an importer, distributor or other person is considered a manufacturerArticle 3, point (12), Article 21, Article 22(1)
1.4A check of each product against the categories of Annexes III and IV, using the technical descriptions adopted under Article 7(4) when availableArticle 7(1), Article 7(4), Article 8(1), first subparagraph
1.5A timeline per product (Article 14 from 11 September 2026; general application from 11 December 2027)Article 71(2), Article 69(2), Article 69(3)

2. Secure design and development (Annex I, Part I)

#Suggested deliverableProvisions
2.1A documented, up-to-date cybersecurity risk assessment per product, used across planning, design, development, production, delivery and maintenanceArticle 13(2), Article 13(3), Article 13(4)
2.2A gap analysis against Part I of Annex I, with a justification where a requirement is considered not applicableArticle 13(1), Annex I, Part I
2.3A due-diligence procedure and inventory for third-party components, including free and open-source componentsArticle 13(5), Article 13(6)
2.4A review of default configurations, reset, update mechanisms, access control and data protectionAnnex I, Part I, point 2(b), Annex I, Part I, point 2(c), Annex I, Part I, point 2(d), Annex I, Part I, point 2(e)

3. Vulnerability handling and support period (Annex I, Part II)

#Suggested deliverableProvisions
3.1A software bill of materials in a commonly used, machine-readable format covering at least top-level dependenciesAnnex I, Part II, point 1, Article 13(24)
3.2A coordinated vulnerability disclosure policy, a reporting contact address and a single point of contact for usersAnnex I, Part II, point 5, Annex I, Part II, point 6, Article 13(17)
3.3A security update process: remediation without delay, separate security updates where technically feasible, secure distribution, dissemination with advisoriesAnnex I, Part II, point 2, Annex I, Part II, point 7, Annex I, Part II, point 8
3.4A support period per product, the information used to set it, and how its end date is shown at purchaseArticle 13(8), second subparagraph, Article 13(8), third subparagraph, Article 13(19), first subparagraph
3.5Availability of each security update for at least 10 years after issue or for the remainder of the support period, whichever is longerArticle 13(9)
3.6A procedure to disclose information on fixed vulnerabilities once an update is availableAnnex I, Part II, point 4

What the text requires

The support period must reflect the time during which the product is expected to be in use. Without prejudice to the second subparagraph, the support period shall be at least five years. Where the product with digital elements is expected to be in use for less than five years, the support period shall correspond to the expected use time. Article 13(8), third subparagraph

4. Reporting readiness (Article 14)

#Suggested deliverableProvisions
4.1Criteria to detect and qualify actively exploited vulnerabilities and severe incidentsArticle 3, point (42), Article 14(5)
4.2Notification templates and an on-call procedure for the deadlines of Article 14Article 14(2), Article 14(4)
4.3Identification of the CSIRT designated as coordinator and access to the single reporting platformArticle 14(7), Article 16(1)
4.4A process and channels to inform impacted usersArticle 14(8)

The vulnerability handling workflow template details the reporting steps and their deadlines as written in Article 14.

5. Documentation and conformity

#Suggested deliverableProvisions
5.1Technical documentation with at least the elements of Annex VII, kept up to date during the support periodArticle 31(1), Article 31(2), Annex VII
5.2The choice of conformity assessment procedure per product and any notified body planning; tracking of harmonised standardsArticle 32(1), Article 32(2), Article 32(3), Article 32(4), Article 27(1)
5.3The EU declaration of conformity and CE marking arrangementsArticle 28(1), Article 30(1), Article 13(20)
5.4The information and instructions to the user listed in Annex IIAnnex II, Article 13(18)
5.5Retention of documentation for at least 10 years or the support period, whichever is longerArticle 13(13)

6. Supply chain and monitoring

#Suggested deliverableProvisions
6.1Verification checklists for importers and distributors before placing or making availableArticle 19(2), Article 20(2)
6.2Agreed channels for vulnerability information between economic operatorsArticle 19(5), second subparagraph, Article 20(4), second subparagraph, Article 13(6)
6.3Records of the economic operators who supplied you and whom you supplied, kept for 10 yearsArticle 23(1), Article 23(2)
6.4Monitoring of delegated and implementing acts, harmonised standards and guidanceArticle 7(4), Article 13(24), Article 14(10), Article 26
6.5For microenterprises and small enterprises: a check of national support measuresArticle 33(1)

Fictional example — Sequencing at Acme Sensors

Acme Sensors, an invented company selling connected sensors with a cloud dashboard, starts with workstream 1 in the first month, then runs workstreams 3 and 4 in parallel because the reporting obligations apply first, and schedules workstreams 2 and 5 product by product according to its release calendar. This sequencing is an illustration, not a recommendation for every organisation.

Downloadable version

The Excel workbook and the Word document contain the same 29 items, with the motivating provisions and a note for each, and empty Status, Owner and Notes columns.

DOWNLOAD — VERSION 1.0

Same content, ready to fill in

Limits. This action plan is a planning aid prepared by regulation-cra.eu. The deliverables it suggests are recommendations; completing them does not establish compliance and does not replace a product-specific analysis or legal advice. It reflects Regulation (EU) 2024/2847 as published in the Official Journal with its corrigenda; delegated and implementing acts, harmonised standards and official guidance may add detail. Only the texts published in the Official Journal of the European Union are authentic.