Cybersecurity

Cyber Resilience Act for machinery: what manufacturers need to do now

The first reporting obligations have applied since 11 September 2026, the full Cyber Resilience Act applies from 11 December 2027. For connected machinery it comes on top of the Machinery Regulation – with its own requirements for security, updates and documentation.

Updated: 19 October 2026 · 8 min read

What is the Cyber Resilience Act?

The Cyber Resilience Act (CRA) – Regulation (EU) 2024/2847 – sets EU-wide mandatory cybersecurity requirements for products with digital elements for the first time. This covers hardware and software that can be connected, directly or indirectly, to a device or network. Like the Machinery Regulation, the CRA is a regulation: it applies directly in all member states.

The aim: products should be developed securely from the start (“security by design”), shipped with secure default settings and receive security updates throughout their support period.

Is my machine in scope?

Very likely, as soon as it contains digital elements with a connection option. Typical examples in machine building:

  • controllers and HMIs with Ethernet, fieldbus or wireless interfaces,
  • remote maintenance and remote service access,
  • machines with cloud connectivity, data acquisition or app control,
  • software supplied with the machine – such as configuration, visualisation or diagnostic tools.

Not covered are, among others, pure SaaS offerings unrelated to a product and areas with their own special rules (e.g. medical devices, motor vehicles). Whether and in which class your product falls – default, “important” or “critical” product – determines the conformity assessment procedure.

Deadlines at a glance

DateWhat applies
10 Dec 2024CRA enters into force
11 Jun 2026Provisions on conformity assessment bodies
11 Sep 2026Reporting obligations for actively exploited vulnerabilities and severe security incidents – also for products placed on the market before 2027
11 Dec 2027All remaining obligations – products may only be placed on the market if CRA compliant

Relevant already: the reporting obligations have applied since 11 September 2026. Manufacturers must report an actively exploited vulnerability within 24 hours (early warning) and 72 hours (notification) via ENISA’s single reporting platform; a final report follows.

Key obligations for manufacturers

  • Cybersecurity risk assessment across the entire product lifecycle – documented in the technical documentation.
  • Essential cybersecurity requirements, including secure default configuration, protection against unauthorised access, data integrity and a minimised attack surface.
  • Vulnerability handling: identify, document and promptly fix vulnerabilities via security updates; provide a contact point for reports.
  • Software bill of materials (SBOM) for the components used.
  • Define a support period – as a rule at least five years unless the expected use time is shorter – and state it.
  • Information for users: secure installation and commissioning, updates, end of support, contact for vulnerability reports.
  • Conformity assessment, EU declaration of conformity and CE marking – CE marking will cover the CRA as well.

How it fits with the Machinery Regulation

From 20 January 2027 the Machinery Regulation (EU) 2023/1230 also requires protection against corruption: connections to other devices or remote access must not lead to hazardous situations, and safety-related software and data must be protected. The CRA adds general cybersecurity, updates and reporting duties.

In practice this means both regulations must be reflected in the risk assessment, technical documentation and instructions of a connected machine. If your documentation is structured and versioned, keeping both bodies of evidence consistent becomes much easier.

What it means for documentation

The CRA creates new content that belongs in documentation and instructions – and that may change with every update:

  • Safety information on installation, network connection and remote access in the instructions
  • The support period and the contact point for vulnerability reports
  • Version-specific information: which software version is installed on which machine?
  • SBOM and cyber risk assessment as part of the technical documentation
  • Updated instructions after security-relevant updates – permanently accessible

This is where documentation generated from product data and linked to each machine’s revision pays off: safety notes come as modules from the template, changes flow into every language version automatically, and in the online catalog every customer sees exactly the state of their machine.

Roadmap: 6 steps to CRA compliance

  1. Inventory: which products contain connectable digital elements?
  2. Classify: default, important or critical product? This determines the assessment procedure.
  3. Set up reporting: responsibilities, 24/72-hour process, access to the ENISA platform – already mandatory.
  4. Adapt development: security by design, SBOM, update mechanism, support period.
  5. Extend documentation: risk assessment, technical documentation, user information.
  6. Declare conformity: assessment, EU declaration of conformity, CE marking by 11 Dec 2027.

Note: this article provides an overview and is not legal advice. The authoritative text is Regulation (EU) 2024/2847.

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FAQ

FAQ

When does the Cyber Resilience Act apply?

The CRA entered into force on 10 December 2024. Reporting obligations for actively exploited vulnerabilities and severe incidents have applied since 11 September 2026, all remaining obligations apply from 11 December 2027.

Does the CRA apply to machinery?

Yes, if the machine is a product with digital elements – i.e. contains hardware or software that can be connected to a device or network. That applies to many modern controllers, HMIs and remote maintenance solutions.

How long do I have to provide security updates?

For the support period defined by the manufacturer. It should reflect the expected use time and is, as a rule, at least five years.

Documentation that keeps pace with your engineering.

Operating manuals, spare parts catalogs and more – automatically from CAD, PDM and ERP.