Zero Day Blog

Introduction : Today, countless everyday devices connect to the internet from gas ranges and refrigerators to microwaves are all equipped with smart modules for remote control and data exchange. Yet, we often don’t know what data they collect or how secure they are. Poorly designed systems can become entry points into home networks, as seen in the 2016 Mirai botnet attack, where malware exploited IoT devices with default passwords and turned them into bots for massive DDoS attacks. This exposed the lack of IoT security standards and the need for regular firmware updates and vulnerability management.

Similarly, the 2020 SolarWinds breach showed how attackers could compromise software supply chains by inserting malicious code into legitimate updates. Over 18,000 organizations, including U.S. government agencies and global companies, were affected with average losses reaching up to 14% of annual revenue in the U.S. The incident emphasized the importance of audits, penetration testing, SIEM, and DLP systems, revealing that traditional perimeter defenses alone are no longer enough.

The focus has shifted from privacy and data protection to a much broader goal of cyber resilience, which is the main driving factor for the EU’s Cyber Resilience Act (CRA).

Today’s voluntary security measures haven’t kept pace with the growing sophistication and scale of cyber threats. The CRA aims to mandate cybersecurity requirements at the product level, especially for digital products that are widely used but often under-secured. This isn’t  about preventing data breaches but it’s about ensuring that software and hardware products are secure by design, right from manufacturing to end-of-life.

Who benefits?

• Consumers and end-users will gain from better-protected devices and transparent security practices.
• Organizations and enterprises will benefit from reduced risk and clearer guidelines.
• Governments will have a framework to enforce and elevate cybersecurity practices across industries.

The CRA sets out to change what’s considered “normal” in product development with long-term support commitments, regular vulnerability disclosures, mandatory patch timelines, and improved transparency about security capabilities.

The Cyber Resilience Act (CRA) spans across digital products, cloud services, supply chains, and even open-source components ensuring that cybersecurity isn’t treated as an afterthought at any stage.

Timeline :  Most CRA rules begin in late 2027(Dec 11 2027). Companies must report serious security incidents and exploited vulnerabilities starting September 11, 2026. The process to approve and list these certification bodies will start on June 11, 2026,  about 1½ years before the rest of the CRA rules apply

Scope :

1. Products with Digital Elements:
According to Article 3(1): “‘product with digital elements’ means any software or hardware product and its remote data processing solutions, including updates, that are intended, directly or indirectly, to be connected to a device or network.” So any software that:

1. Has digital functionality
2. Connects to a network (directly or via API, agent, or cloud)
3. Processes or transmits data
   → qualifies as a product with digital elements.

This refers to any hardware or software that can connect to networks or other devices—essentially, anything that could be a potential attack surface. As defined in Articles 2(1) and 3(1), (4), (5), and (7), this includes in itself a wide umbrella of products and divisions:

• Consumer electronics like laptops, smartphones, tablets
• Smart devices and IoT products such as smart thermostats, lights, home routers, refrigerators, or washing machines with Wi-Fi modules
• Industrial equipment and control systems used in manufacturing or critical infrastructure
• Software components such as antivirus programs, embedded firmware, SDKs, or APIs shipped with commercial products

2. Remote Data Processing Solutions
Article 3(2) extends the CRA to cloud-based services that are essential to how a product functions. These include:

• A smartwatch that syncs health data to a cloud platform
• A home security system where video footage is stored remotely
• Widely used SaaS platforms like Salesforce, GitHub, Asana, Zoom, HubSpot, and Slack – all of which rely on remote backend systems to deliver core functionality

3. Economic Operators
It’s not just about the products, it’s also about the people and organizations that bring them to market. As per Article 3(12), (13), (16), and (17), CRA responsibilities extend to:

• Manufacturers, such as Apple, Samsung, Siemens, or Bosch
• Importers and distributors, like Amazon EU or resellers handling third-party goods
• Authorized representatives, who act on behalf of non-EU companies in European markets

4. Free and Open Source Software (FOSS)
CRA doesn’t ignore open-source. Under Article 3(14), (48), and Recital 10, the regulation applies when open-source components are bundled into commercial offerings. This ensures even freely available code is treated responsibly when used in business contexts. Examples include:

• Products using OpenSSL, Redis, or Linux kernels as part of their architecture
• Commercial appliances that incorporate FOSS in firmware or backend services

Conclusion : The breadth of the CRA’s coverage means that entire industries and not just products will feel its impact. Sectors such as automotive, healthcare, energy, and manufacturing will need to rethink their development lifecycles, especially for connected devices and systems. This will involve re-engineering product design, introducing more rigorous audits, security testing, and ensuring ongoing compliance, keeping a track of vulnerabilities, SBOM and supply chain  on check throughout a product’s lifecycle. While the transition may be demanding, the end goal is a stronger, more cyber-resilient ecosystem where security is not a bolt-on, but a core feature from day one.

For security organizations, this is a pivotal moment. CRA opens new opportunities, not just in compliance consulting, but in product security, vulnerability management, and supply chain risk assessment. Those already aligned with secure-by-design and DevSecOps practices are ahead of the curve. Others will have to catch up fast. Historically, EU regulations like GDPR have had global ripple effects. Many non-EU countries and companies adopted GDPR-like policies to stay compatible and trustworthy in international markets. CRA is expected to do the same, setting the next global benchmark for cybersecurity regulation.

In essence, CRA is not just a European matter. It’s a signal: Cybersecurity is no longer just an IT problem. It’s a product quality issue, a legal obligation, and a business differentiator.

Sources : 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R2847
https://www.fortinet.com/resources/cyberglossary/solarwinds-cyber-attack
https://www.cloudflare.com/learning/ddos/glossary/mirai-botnet/