- Background source for coordinated vulnerability disclosure as the process context behind Annex I Part II vulnerability reporting and disclosure controls.
"Coordinated Vulnerability Disclosure is crucial"
Translate the Cyber Resilience Act's product-security and vulnerability-handling requirements into controls that engineering, product, and compliance teams can evidence.
This page helps separate risk-based product properties from lifecycle duties, then connect both to technical documentation and release evidence.
Structured answer sets in this page tree.
Cited legal and guidance references.
Annex I contains the Cyber Resilience Act's . Part I point (1) requires an appropriate level of cybersecurity based on risk, while the detailed Part I point (2) product properties apply where relevant on the basis of the cybersecurity risk assessment. Part II defines the manufacturer's vulnerability-handling processes, which apply when the product is placed on the market and throughout the support period.
Article 6 ties market access to Annex I. A product with digital elements may be made available on the market only if the product meets the applicable Part I requirements and the manufacturer's processes comply with Part II.
That means Annex I should be treated as a conformity argument, not as a generic security wishlist. The useful working file is a requirement register that shows the requirement, the product boundary, the risk assessment outcome, the implemented control, the test or review evidence, and the documentation location.
Annex I applies to all in-scope product categories, not only important or critical products. Classification changes the conformity route; it does not remove the .
Most Annex I obligations apply from 11 December 2027. For products placed on the market before that date, Article 69 generally makes the remaining CRA requirements applicable only if the product undergoes a substantial modification from 11 December 2027. Article 14 reporting starts earlier, on 11 September 2026, and applies to all in-scope products placed on the market before 11 December 2027.
Part I starts with an overall requirement for an appropriate level of cybersecurity based on the risks, then lists product properties that apply where relevant. The Commission FAQ explains that manufacturers must determine relevance through the cybersecurity risk assessment, and that non-applicability needs a clear justification.
A practical Annex I Part I assessment should therefore avoid yes-or-no labels without evidence. Each answer should point to design choices and tests that show how the product meets the relevant outcome.
Assessment Autopilot can convert CRA Annex I product-security and vulnerability-handling requirements into assigned controls, evidence requests, and review checkpoints in Sorena.
Create an Annex I requirements register with owners, applicability decisions, control evidence, and documentation gaps.
Review your current product-security process, technical-documentation gaps, and vulnerability-handling evidence.
Part II is not limited to launch readiness. It sets the manufacturer's vulnerability-handling process for the product, including integrated components, throughout the support period.
The CRA does not require the same patch response for every vulnerability, but it does require the manufacturer to assess relevance and risk, then put appropriate remedies in place without delay. A remedy may be a patch, mitigation, configuration guidance, advisory, documentation change, or another suitable measure, depending on the risk.
The CRA covers planning, design, development, production, delivery, and maintenance. For Annex I, secure-by-design work is strongest when it produces records that are usable at release review and later by a notified body or market surveillance authority.
The goal is not to publish every internal engineering record. It is to maintain enough traceability to show how the product and the manufacturer's processes meet the applicable Annex I requirements.
A standard or guidance document can help design and test a control, but it creates a CRA presumption of conformity only when the legal conditions for that effect are met and only for the requirements it covers. Keep the product-specific risk assessment and any uncovered Annex I requirement in the file.
Use a crosswalk with four columns: CRA outcome, product-specific control, implementation source, and evidence. Record whether the source is a harmonised standard cited in the Official Journal, a common specification, a certification scheme with recognised effect, or supporting technical guidance.
"Coordinated Vulnerability Disclosure is crucial"
"Manufacturers need to comply with all essential cybersecurity requirements related to vulnerability handling"
"planning, design, development and maintenance"
"ESSENTIAL CYBERSECURITY REQUIREMENTS"