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How SafeBreach Propagate Fills Critical Cybersecurity Needs for Enterprise & Mid-Sized Security Teams
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On December 10, 2024, the EU Cyber Resilience Act (CRA) officially entered into force, marking the start of a three-year runway before its main obligations apply on December 11, 2027. While that might seem distant, the reality is clear: compliance preparation must begin now.
For CISOs, the CRA isn’t just another regulatory hurdle—it’s a fundamental shift in how digital products are designed, secured, validated, and maintained throughout their lifecycle. The CRA raises the bar for manufacturers, importers, and distributors of products with digital elements (PDEs) by making cybersecurity a legal obligation, not a voluntary best practice. This means CISOs must rethink risk management, vulnerability handling, and board-level reporting to avoid penalties and to stay competitive in an increasingly regulated market.
In the blog below, we’ll provide a high-level overview of the EU Cyber Resilience Act, including what it covers, who is responsible, and what key compliance requirements are. We’ll also explore why the current threat landscape makes CRA compliance urgent and what tools can help support readiness.
The CRA in Context: Why This Regulation Matters
The CRA forms part of a broader EU effort to strengthen digital resilience alongside regulations like Network and Information Security 2 (NIS2) and the Digital Operational Resilience Act (DORA). While NIS2 and DORA focus on operations and governance, the CRA targets products — the foundation of those operations.
This means CRA compliance cannot live in isolation. It intersects with procurement, supply chain security, customer assurance, and even M&A due diligence. Organizations that act early will not only mitigate compliance risk but can also leverage CRA readiness as a competitive differentiator — signaling trust, maturity, and resilience to the market.
Scope: What Products Are & Aren’t Covered
The CRA applies to virtually all software or hardware products with digital elements placed on the EU market, whether manufactured within the EU or imported from abroad. This includes both physical and software-only PDEs, as well as remote data processing components such as cloud-connected services.
Examples of included PDEs:
- Consumer devices: smart TVs, routers, connected toys, wearables.
- Enterprise software: password managers, antivirus solutions, and operating systems.
- IT infrastructure: firewalls, network management tools.
- Industrial IoT (IIoT): controllers, sensors, smart manufacturing systems.
Exclusions include: medical devices, aviation systems (certified under EU 2018/1139), motor vehicles, marine equipment (Directive 2014/90/EU), products developed solely for national security or defense purposes, and certain open-source software.
Spare parts made available solely to replace identical components in existing PDEs are also excluded.
Who is Responsible?
The CRA assigns the following obligations across the supply chain:
| Role | Responsibilities | Examples |
| Manufacturers | Design security by default, manage vulnerabilities, provide updates for ~5 years, report incidents, and ensure CE conformity | Device makers, software vendors |
| Importers | Ensure imported PDEs comply before placing them on the EU market | EU distributor of U.S. routers |
| Distributors | Verify PDEs carry CE marking, ensure instructions/updates provided | Retailers, resellers |
Importantly, if an importer or distributor rebrands a product under their own name or trademark, they are legally considered the manufacturer under the CRA.
Key Requirements Every CISO Must Plan For
The CRA builds cybersecurity directly into the product lifecycle. CISOs should prepare for five major areas of compliance:
- Cybersecurity by Design and Default
- Incorporate secure development practices from the outset, including threat modeling and secure update mechanisms.
- Default configurations must be secure (e.g., no “admin/admin” credentials).
- Vulnerability Handling
- Establish processes to detect, document, and remediate vulnerabilities.
- Manufacturers must provide security updates for a defined support period, typically five years.
- Information Transparency
- Provide clear security instructions and update policies for users.
- Conformity Assessment & CE Marking
- Demonstrate compliance via documentation, audits, and third-party assessments where required.
- CRA compliance will be indicated by a CE mark confirming conformity with cybersecurity standards.
- Incident and Vulnerability Reporting
- Manufacturers must report both actively exploited vulnerabilities and security incidents without undue delay (similar to GDPR’s 72-hour window).
Common Pitfalls to Avoid
In order to avoid underestimating the impact of CRA, CISOs must not:
- Treat CRA as purely a legal exercise rather than a technical and cultural transformation.
- Wait until 2027 — compliance will require long lead times and process redesign.
- Fail to align CRA reporting with NIS2 and DORA processes.
- Overlook third-party PDEs in the supply chain — a critical CRA exposure area.
Emerging Threat Landscape: Why CRA Compliance Is Urgent
SafeBreach research on the manufacturing sector highlights that it remains the single most targeted industry by Ransomware-as-a-Service (RaaS) groups from 2023–2025.
Groups such as RansomHub, LockBit, Play, Cl0p, and Akira have repeatedly targeted manufacturers, exploiting vulnerabilities in VPNs, file transfer tools, and operational technology systems. Nation-state APTs (e.g., APT41, APT40, and Lazarus Group) also pursue IP theft and disruption across European supply chains.
This real-world context makes CRA requirements—particularly vulnerability handling, secure updates, and rapid incident reporting—not just compliance imperatives, but operational necessities.
Where SafeBreach Helps CISOs Accelerate CRA Readiness
SafeBreach uniquely aligns with CRA obligations by turning regulatory pressure into proactive resilience:
- Continuous Validation (Validate + Propagate): The SafeBreach Exposure Validation Platform simulates both pre- and post-breach attacker behavior to test PDEs, integrations, and propagation paths.
- Vulnerability Handling Alignment: Validate new CISA alerts within 24 hours — showing regulators proactive controls.
- Board-Ready Reporting: Dashboards aligned to CRA, DORA, and NIS2 frameworks provide audit-ready evidence.
- Risk Quantification: Translate technical findings into breach likelihood and business risk, helping justify investments.
Action Plan: CRA Readiness Roadmap for CISOs
- Map Your PDEs: Identify all hardware/software under CRA scope.
- Assess Supply Chain: Ensure importers and distributors align with requirements.
- Establish Vulnerability Handling Processes: Integrate the SafeBreach Exposure Validation Platform for continuous exposure validation.
- Run Conformity Gap Analysis: Benchmark against CRA requirements.
Prepare Board & Regulator Reporting: Develop consistent reporting across CRA, DORA, and NIS2.
Conclusion: Turning Compliance Into Confidence
The EU Cyber Resilience Act sets a new security baseline for digital products in Europe, one that CISOs can either treat as a burden or leverage as a competitive advantage. Early preparation enables organizations to gain more than compliance—they gain validated resilience, audit confidence, and enhanced customer trust.
With SafeBreach, CISOs can move beyond “checking the box” to proving security effectiveness continuously. To learn more, check out the SafeBreach Exposure Validation Platform solution brief, then schedule a personalized demo.
