Implementing CRA in Embedded Projects

The Cyber Resilience Act affects manufacturers of digital products with embedded software not only at the process level, but also in relation to specific technical issues involving bootloaders, drivers, operating systems, update mechanisms, and the associated documentation. We help you systematically classify CRA-relevant requirements for new or existing embedded system integrations and implement defined measures in your embedded software.

Discuss your CRA requirements

What the CRA Means for Your Embedded System in Practice

In the embedded systems environment, the Cyber Resilience Act affects not only formal requirements but also specific technical and organizational decisions made during the product development process. For many manufacturers, the challenge lies less in the term itself than in determining how it will impact their own systems, software architecture, and existing development processes.

Unclear impact on our own product

Many manufacturers are initially unsure which CRA-related requirements actually apply to their specific embedded system. Without this classification, it remains unclear which software components, interfaces, communication channels, or update mechanisms need to be considered at all.

Security requirements for system-level software

In the embedded sector, necessary measures often affect not only the application software but also system-level components such as the operating system, drivers, bootloaders, and update mechanisms. This quickly gives rise to technical questions that cannot be answered in general terms but only within the context of the existing architecture.

CRA fehlende Verbindung Prozess und technische Umsetzung

Lack of alignment between processes and technical implementation

Requirements in the CRA context do not merely concern documentation and organization; they must ultimately be technically feasible. Manufacturers are therefore faced with the task of linking process-related requirements to specific measures in embedded software, system validation, and development documentation.

Uncertainty regarding prioritization and approach

Especially in existing projects, it is often unclear where to begin: analysis, hardening, documentation, testing, bootloaders, data exchange, or security mechanisms. Without a structured assessment, there is a risk of starting in the wrong places or addressing security-related issues too late.

CRA-related consulting in the embedded systems field therefore primarily helps to clarify requirements at an early stage, clearly define the scope of technical work, and derive realistic measures for the specific product.

Please note the following deadlines!

Since 11th September 2026: Obligation to report the discovery of exploited vulnerabilities and serious security incidents
From 11th December 2027: Full entry into force of the CRA requirements for products containing digital components

How We Can Help in the Embedded Environment

We help companies technically assess CRA-related issues in embedded projects and develop actionable solutions. In doing so, we work within the jointly defined parameters of your product and development environment.

Preliminary Technical Assessment of CRA-Related Issues

Analysis of safety-critical requirements

Hardening of the OS and system-level software components

Revision or validation of drivers

Modifications to bootloaders

Support for Secure Boot solutions

Code security, management, and data exchange

Documentation of implemented software measures

Tests conducted under laboratory conditions

The appropriate measures always depend on the specific product, its architecture, and the defined requirements. In order for us to provide you with targeted support, we need you to provide as detailed a description as possible of your issues and the type of assistance you require.

CLARIFY TECHNICAL CRA QUESTIONS

What we cannot provide

When it comes to the CRA, clear boundaries are essential. We therefore deliberately communicate in a technically precise manner and avoid making blanket assurances. We specialize in embedded software and support you with the technical analysis and implementation of CRA-relevant measures within the context of your project.

What we do not promise in general terms:

No comprehensive evaluation of an entire product in the legal sense
No blanket or legally binding statement regarding a product’s full compliance
No issuance of certificates or certification services
No assumption of manufacturer liability

Our role lies in technical collaboration. This includes classifying relevant requirements, implementing defined measures in the embedded software, as well as documentation and software testing within the agreed-upon project scope.

Project workflow for CRA-compliant embedded projects

Initial Consultation and Clarification

We will work with you to determine which technical and organizational issues are actually relevant to your product.

Classification of Requirements

Together, we organize CRA-related topics and, if necessary, bring in experienced contacts from the SIGMA Group.

Technical Implementation

Our developers implement defined measures in software, drivers, bootloaders, and system-level components.

Documentation and Testing

We document the measures implemented and test them under laboratory conditions.

Experienced contacts within the SIGMA Group

If needed, experienced experts from the SIGMA Group can be consulted for questions regarding the EU Cyber Resilience Act. This allows us to jointly address technical, organizational, and process-related issues and integrate them into the project in a structured manner.

Our embedded developers will then design the code for you in accordance with the constraints and specifications agreed upon, and will take responsibility for documenting it. Testing is then carried out under laboratory conditions where possible. In addition to safety-critical code components or drivers, this may also include code security, management and data exchange.

Topics for which an initial consultation is recommended

An initial consultation is particularly useful if you still need to define CRA-related requirements for an embedded system in more detail, or if it is already clear that technical modifications will be necessary.

Typical starting points include, for example:

You want to assess which CRA-related issues actually affect your embedded system.
You want to determine which software components are likely to require modification.
You want to integrate security requirements into an existing system in a structured manner.
You want to prepare technical documentation early on.
You want to evaluate hardening measures for the operating system, drivers, or bootloaders.
You want to technically and clearly allocate security-related requirements within the project context.

Especially in early project phases, a structured approach helps avoid additional work and misunderstandings later on.

FAQ

For existing embedded systems, it is necessary to determine which software components, interfaces, update mechanisms, and safety-related functions must be considered in light of the specific requirements. Technical measures and documentation requirements can then be derived from this.

The Cyber Resilience Act is already in effect. However, the requirements do not take full effect on a single effective date but will be phased in gradually.

Key dates are:

Effective September 11, 2026: Obligations to report actively exploited vulnerabilities and serious security incidents
As of December 11, 2027: The key CRA requirements for products with digital elements will apply in full

For manufacturers, this means that even though key product requirements will not fully apply until later, technical and organizational preparations should begin much earlier. Especially for embedded systems, issues such as architectural review, hardening, bootloaders, update mechanisms, documentation, and testing generally require sufficient lead time.

Yes, we provide support for the technical classification and implementation of CRA-related measures in an embedded context. Depending on the project, this may include operating systems, drivers, bootloaders, secure boot concepts, documentation, and testing.

No. We do not make any blanket statements regarding the full compliance of a finished product, nor do we assume any manufacturer’s liability. Our role is to provide technical support within the agreed-upon scope of the project.

Yes. Especially with legacy systems, it makes sense to conduct a structured analysis of the relevant software components, update mechanisms, interfaces, and security-related functions.

During the initial consultation, we can determine, among other things, which CRA-related requirements actually apply to your embedded system, which areas of software might be affected, and what technical measures can realistically be implemented.

Depending on the product, this includes operating systems, drivers, bootloaders, update mechanisms, communication interfaces, data exchange, and security-related software functions.

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We will be happy to present solutions for your industry and your processes. Talk to the specialists for SMEs.

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