EU Cyber Resilience Act, CRA Product Security and CE Marking SBOM and Vulnerability Management Template

Annex I Part II requires an SBOM in a commonly used and machine readable format covering at least the top level dependencies. The format may later be specified further by Commission implementing acts, but you do not need to wait to define the minimum fields you rely on operationally.

Keep the SBOM tied to a specific released version so you can answer exposure questions quickly.

Your vulnerability management template should capture far more than a ticket title. It should store awareness timing, exploit status, affected versions, component links, and the initial decision on whether Article 14 may be triggered.

This is the information that later feeds advisories, user notices, and authority responses.

The CRA expects vulnerabilities to be addressed without delay in relation to the risks posed. Your template should therefore capture the corrective action path and the evidence that the action was actually shipped.

Keep remediation records linked to release notes, package signing, and update distribution logs.

The CRA expects due diligence when integrating third party components and requires manufacturers to report component vulnerabilities to maintainers and share fixes where appropriate. Your template therefore needs explicit upstream and downstream coordination fields.

This is especially important when a component support period ends before your product support period ends.

A useful SBOM and vulnerability template should feed directly into Article 14 reporting and Article 31 technical documentation. If it does not, you will end up re typing the same facts under time pressure.

Build the template so every record can point to the declaration, technical file, advisory, and any Article 14 report identifiers.