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Across 40 modules • Updated Mar 10, 2026
Author
Sorena AI
Published
Mar 10, 2026
Updated
Mar 10, 2026
CRA Notified Bodies

What certificate does a notified body issue under Module B?

If the product type and vulnerability-handling processes meet the applicable essential cybersecurity requirements, the notified body issues an EU-type examination certificate. The certificate identifies the manufacturer, states the conclusions of the examination, records any validity conditions, and includes the data needed to identify the approved type and vulnerability-handling processes.

If the type or vulnerability-handling processes do not meet the requirements, the notified body must refuse the certificate and give detailed reasons. Modifications that may affect conformity or certificate validity require additional approval as an addition to the original EU-type examination certificate.

Citations
Cyber Resilience Act

Annex VIII Part II points 6 and 7 set the EU-type examination certificate contents, refusal duty, and approval route for relevant modifications.

CRA Notified Bodies

Does Module B+C include ongoing notified-body surveillance?

Yes, but the surveillance is specific. Under Module B, the notified body must carry out periodic audits to ensure that the manufacturer's vulnerability-handling processes are implemented adequately.

That does not turn Module C into notified-body production surveillance. The production-control obligation remains with the manufacturer under Module C.

Citations
Cyber Resilience Act

Annex VIII Part II point 8 requires periodic audits of vulnerability-handling processes; Part III keeps production conformity under manufacturer control.

CRA Notified Bodies

What does the notified body assess under Module H?

Module H is full quality assurance. The manufacturer operates an approved quality system for design, development, production, final product inspection and testing, and vulnerability handling. The notified body assesses whether that quality system satisfies the CRA requirements.

The quality-system documentation must cover responsibilities, design and development specifications, vulnerability-handling process specifications, production and quality assurance techniques, examinations and tests, quality records, and monitoring of product quality and system effectiveness.

Citations
Cyber Resilience Act

Annex VIII Part IV points 1 to 3 define Module H and the required quality-system content.

European Commission CRA FAQs

Section 6.3 explains Module H as a full quality control system covering design and production with notified-body assessment.

CRA Notified Bodies

How does surveillance work under Module H?

Module H has surveillance under the responsibility of the notified body. The purpose is to make sure the manufacturer fulfils the obligations arising from the approved quality system.

For assessment, the manufacturer must allow access to design, development, production, inspection, testing, and storage sites and provide quality-system documentation and quality records. The notified body carries out periodic audits and provides an audit report.

Citations
Cyber Resilience Act

Annex VIII Part IV point 4 sets the purpose of Module H surveillance, site-access duties, required records, and periodic audits.

CRA Notified Bodies

How do Module B+C and Module H differ for manufacturers?

Module B+C is product-type oriented: a notified body examines the type and vulnerability-handling processes, then the manufacturer controls production conformity to the approved type.

Module H is system oriented: the notified body assesses and surveils the manufacturer's quality system covering design, development, production, final inspection, testing, and vulnerability handling for the covered product categories. The Commission FAQ notes that Module H can be useful for manufacturers with numerous product types or frequent updates because it can streamline assessment of new or substantially modified products within the approved system.

Citations
Cyber Resilience Act

Annex VIII Parts II, III, and IV show the product-type structure of Module B+C and the quality-system structure of Module H.

CRA Notified Bodies

Does the notified body's number appear next to the CE marking?

Only for the CRA Module H route. Article 30 says the CE marking is followed by the notified body's identification number where that body is involved in conformity assessment based on full quality assurance.

For Module B+C, the CRA requires the manufacturer to keep the EU-type examination certificate and use Module C production control, but Article 30's notified-body-number rule is tied to Module H.

Citations
Cyber Resilience Act

Article 30(4) ties the notified-body identification number after the CE marking to full quality assurance based on Module H.

CRA Notified Bodies

What independence rules apply to CRA notified bodies?

A CRA notified body must be independent of the organisation and product it assesses. It and its relevant management and assessment personnel must not be the designer, developer, manufacturer, supplier, importer, distributor, installer, purchaser, owner, user, maintainer, or authorised representative of the products being assessed.

The CRA also bars activities that conflict with independence of judgement or integrity, especially consultancy services. A body connected to an industry association can still qualify only if independence and absence of conflicts of interest are demonstrated.

Citations
Cyber Resilience Act

Article 39(3) to (5) set third-party independence, conflict-of-interest, consultancy, and association-membership conditions.

CRA Notified Bodies

What competence and process capabilities must a CRA notified body have?

For every CRA procedure and product kind or category in its notified scope, the body must have personnel, procedures, means, equipment, and facilities needed to perform the assessment tasks. Its procedures must be transparent and reproducible and must distinguish notified-body tasks from other activities.

Assessment personnel must have appropriate training, knowledge of the applicable CRA requirements, harmonised standards and common specifications, and the ability to draw up certificates, records, and reports showing that assessments were carried out.

Citations
Cyber Resilience Act

Article 39(6) and (7) define the personnel, procedures, equipment, facilities, training, and reporting capabilities required for notified scope.

CRA Notified Bodies

Can a notified body use subcontractors or subsidiaries?

Yes, but the notified body remains responsible. It must ensure the subcontractor or subsidiary meets Article 39 requirements, inform the notifying authority, keep qualification and work records available to the notifying authority, and obtain the manufacturer's agreement before subcontracting activities or using a subsidiary.

Subcontracting does not expand the notified body's scope. The manufacturer's check should still start with the notified body's own CRA notification and the activities it is authorised to perform.

Citations
Cyber Resilience Act

Article 41 allows subcontracting and subsidiaries only with Article 39 compliance, notifying-authority information, manufacturer agreement, and retained responsibility.

CRA Notified Bodies

What happens if a notified body finds non-compliance?

Before issuing a certificate, the notified body must require corrective measures and must not issue the certificate if non-compliance remains. After a certificate has been issued, it must require corrective measures and, if necessary, suspend or withdraw the certificate.

If corrective measures are not taken or do not have the required effect, the notified body must restrict, suspend, or withdraw the certificate as appropriate. Member States must also ensure that an appeal procedure against notified-body decisions is available.

Citations
Cyber Resilience Act

Article 47(4) to (6) cover corrective measures and certificate refusal, restriction, suspension, or withdrawal; Article 48 requires appeal procedures.

CRA Notified Bodies

What information must CRA notified bodies share?

Notified bodies must inform their notifying authority about certificate refusals, restrictions, suspensions, or withdrawals; circumstances affecting the scope or conditions of notification; and certain information requests from market surveillance authorities. On request, they must also provide information about conformity assessment activities, including cross-border activities and subcontracting.

They must also share relevant information with other notified bodies carrying out similar CRA conformity assessment activities for the same products: negative results must be shared, and positive results must be shared on request. Annex VIII adds specific information-sharing duties for EU-type examination certificates and Module H quality-system approvals.

Citations
Cyber Resilience Act

Article 49 and Annex VIII Part II point 9 and Part IV point 7 set information-sharing duties toward authorities and other notified bodies.

CRA Notified Bodies

What happens if a CRA notified body no longer meets the requirements?

The notifying authority must restrict, suspend, or withdraw the notification depending on the seriousness of the failure, and it must inform the Commission and the other Member States.

If notification is restricted, suspended, withdrawn, or the body ceases activity, the notifying Member State must ensure the body's files are handled by another notified body or kept available for the responsible notifying and market-surveillance authorities.

Citations
Cyber Resilience Act

Article 45 sets restriction, suspension, withdrawal, notification, and file-handling rules when a body no longer meets requirements.

CRA Notified Bodies

Can the Commission challenge a notified body's competence?

Yes. The Commission must investigate where it doubts, or where doubt is brought to its attention about, a notified body's competence or continued fulfilment of CRA requirements and responsibilities.

If the Commission concludes that the body does not meet or no longer meets the notification requirements, it asks the notifying Member State to take corrective measures, including de-notification if necessary.

Citations
Cyber Resilience Act

Article 46 gives the Commission a competence-challenge process and allows requests for corrective measures including de-notification.

CRA Notified Bodies

Can AI Act notified bodies also assess CRA cybersecurity requirements?

Sometimes. For high-risk AI systems that also fall within the CRA, notified bodies competent under the AI Act may control conformity with CRA Annex I requirements if their compliance with CRA Article 39 has been assessed in the AI Act notification procedure.

This is not a general shortcut for all CRA products. The Article 12 rule is tied to high-risk AI systems and the CRA conditions specified there.

Citations
Cyber Resilience Act

Article 12(2) addresses high-risk AI systems and when AI Act notified bodies may assess CRA Annex I cybersecurity requirements.

CRA Notified Bodies

If a body is notified under another EU law, does it automatically count under the CRA?

No. The CRA expects bodies accredited and notified under other Union frameworks with similar requirements to be newly assessed and notified under the CRA, although synergies can be used where requirements overlap.

For manufacturers, this means a certificate, audit relationship, or notified-body number under another EU act is not enough. The CRA listing and scope must support the CRA procedure being relied on.

Citations
Cyber Resilience Act

Recital 100 and Article 43 support new CRA assessment and notification, with possible synergies for overlapping requirements.

CRA Open-Source Software

What counts as free and open-source software under the CRA?

Under the CRA, free and open-source software means software whose source code is openly shared and which is made available under a licence that provides the rights to make it freely accessible, usable, modifiable, and redistributable.

Citations
CRA Open-Source Software

Does the CRA apply to all open-source software?

No.

For the economic operators covered by the CRA, only free and open-source software made available on the market, meaning supplied for distribution or use on the Union market in the course of a commercial activity, falls under the full CRA product regime.

Citations
CRA Open-Source Software

Does the open-source label itself keep software outside the CRA?

No.

Open-source status does not by itself decide the issue. The key CRA question is whether the software is supplied on the Union market in the course of a commercial activity.

Citations
CRA Open-Source Software

What does "commercial activity" mean for open-source software under the CRA?

The CRA does not reduce it to a single formal test.

Recital 15 gives practical indicators. Commercial activity may be characterised not only by charging a price for the software itself, but also by charging for technical support where that does not merely recover actual costs, by an intention to monetise, by using the software to monetise other services, by requiring personal-data processing as a condition of use for reasons other than security, compatibility, or interoperability, or by accepting donations exceeding the costs associated with the software's design, development, and provision.

Citations
CRA Open-Source Software

If the software is open source but sold for a price, is it in scope?

Yes, in principle.

If the software is supplied on the Union market in the course of a commercial activity, open-source status does not prevent it from being treated as a product with digital elements under the CRA.

Citations
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