The entry into force of the Cyber Resilience Act (CRA) introduces a new framework for organisations that develop or deliver digital products in Europe. By 2027, it will be mandatory to ensure that these products meet security requirements throughout their entire lifecycle.
At first glance, the timeline may seem comfortable. In practice, it is not. The main challenge is not the time available, but the way security continues to be treated in many organisations: as a final validation step, disconnected from design, development and operations.
The CRA changes this starting point. It requires far more than incremental adjustments. It demands a structural shift that can prove highly challenging for organisations.
CRA compliance begins before development
One of the most common mistakes is to associate compliance with formal checkpoints such as audits or certifications.
In the context of the CRA, this approach is not only insufficient, but also risky. Compliance is no longer something verified at the end; it must be built from the beginning. This means integrating security across the entire product lifecycle, from design to maintenance.
In practice, ensuring CRA compliance begins by recognising that:
- risk must be considered before development
- security must accompany all phases of the product
- processes must be continuous rather than reactive
Without this shift in approach, any attempt at compliance will inevitably be limited.
Security by Design: the real starting point
The CRA turns the concept of security by design into an operational requirement. This means risk is no longer assessed only after development but must be considered at the design stage. Threat modelling, attack surface analysis and control definition become part of the initial process.
This is one of the most critical elements for ensuring compliance.
The later risk is identified, the greater the impact on the product, the costs and the organisation’s ability to respond. Reversing this logic is not optional — it is a condition for compliance.
Software visibility: from limitation to requirement
Another key pillar of the CRA is visibility over software.
Many organisations still lack a clear understanding of the dependencies they rely on, particularly in environments with extensive use of third-party and open-source components. This lack of visibility limits the ability to assess risk.
The CRA introduces a clear requirement: to understand what composes the product.
The Software Bill of Materials (SBOM) becomes a central element, not only as a technical requirement, but as a control mechanism. It enables the identification of vulnerabilities, critical dependencies and risks associated with third parties.
For many organisations, this will be the first real point of friction with the regulation.
Vulnerability management: the element that sustains compliance
CRA compliance is not limited to prevention. It depends on the ability to respond continuously.
This means vulnerability management must be treated as a structured process rather than a one-off activity.
This includes:
- systematically identifying vulnerabilities
- assessing their impact in the context of the product
- remediating them consistently
- maintaining active processes over time
More than solving isolated issues, the objective is to ensure that risk is continuously managed.
Post-release becomes part of compliance
One of the most relevant changes introduced by the CRA is the extension of responsibility beyond product release.
Security is no longer validated only at the moment of market entry. It becomes an ongoing obligation throughout the product lifecycle.
This requires processes for updates, patch management and continuous monitoring, as a product that does not evolve quickly becomes vulnerable.
In practice, ensuring CRA compliance requires operational continuity, not just initial validation.
The impact of compliance goes beyond technology
Treating the CRA as a purely technical topic is a strategic mistake.
This is a regulation that directly affects access to the European market. Products that do not meet the requirements may no longer be commercialised. In other words, cybersecurity becomes a factor of competitiveness.
Organisations that anticipate these requirements will be better positioned. Those that do not will face concrete operational and commercial limitations.
How to ensure CRA compliance by 2027
More than a set of isolated requirements, the CRA demands a shift in approach.
Organisations that are closer to compliance tend to share a number of characteristics:
- clear visibility over their application portfolio
- integration of security into the development lifecycle
- continuous vulnerability management processes
- the ability to identify and monitor risk over time
This is not about implementing specific tools, but about structuring processes that allow organisations to respond to regulatory requirements in a consistent way.
The 2027 deadline should be seen as an opportunity for transformation, not as a final validation point.
If your organisation is preparing for the Cyber Resilience Act and still lacks a clear view of the exposure level of its application portfolio, this is precisely where the real challenge begins.
At Balwurk, we work with organisations to structure security across the entire software lifecycle, from risk identification to the implementation of continuous practices that ensure sustained compliance.
