Cyber workflowRED Article 3(3)(d/e/f)

RED cybersecurity compliance workflow

Build a release-ready evidence trail for radio equipment affected by Article 3(3)(d), (e), and (f) of Directive 2014/53/EU as activated by Commission Delegated Regulation (EU) 2022/30.

Use this workflow to classify the product, decide which cyber requirements apply, capture safeguards and test evidence, and document the conformity-assessment route before CE release.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

RED cyber compliance starts with a product-specific classification, not a generic security checklist. For each radio product, record whether Article 3(3)(d), (e), or (f) applies, why any derogation applies, which standards or notified-body route supports the claim, and where the evidence lives in the technical documentation.

Section 1

Classify the radio equipment against Article 3(3)(d), (e), and (f)

Start with the actual product architecture and user journey. Article 3(3)(d) is triggered by internet-connected radio equipment. Article 3(3)(e) depends on the listed equipment categories and whether the equipment can process personal data, traffic data, or location data. Article 3(3)(f) applies to internet-connected radio equipment that enables the holder or user to transfer money, monetary value, or virtual currency.

The classification memo should be short enough to review at release, but detailed enough to show how firmware, companion apps, cloud services, sensors, payment functions, and user roles were considered.

  • Record whether the product can communicate over the internet directly or through another device.
  • For Article 3(3)(e), check internet-connected equipment, childcare equipment, toys with radio functions, and wearable radio equipment against the relevant data-processing facts.
  • For Article 3(3)(f), identify any payment, stored-value, wallet, subscription, in-app purchase, or virtual-currency transfer function enabled through the equipment.
  • Document out-of-scope conclusions with the product facts and the exact legal source, not with labels such as low risk or not connected.
Sources for this answer
Directive 2014/53/EU on radio equipment
Primary RED text defining the Article 3(3)(d), (e), and (f) essential requirements.
Commission Delegated Regulation (EU) 2022/30 on RED cybersecurity
Delegated act specifying the categories and classes of radio equipment affected by Article 3(3)(d), (e), and (f).
Section 2

Check derogations and the application date before opening release gates

Before assigning controls, confirm whether another EU regime removes the product from one or more RED cyber requirements. Delegated Regulation (EU) 2022/30 excludes radio equipment covered by medical-device and in vitro diagnostic medical-device rules from Article 3(3)(d), (e), and (f). It also excludes equipment covered by the cited aviation, motor-vehicle, and electronic-road-toll legislation from Article 3(3)(e) and (f).

The application date was changed by Commission Delegated Regulation (EU) 2023/2444. Treat 1 August 2025 as the operative date for the delegated RED cyber requirements unless a product team is documenting voluntary early compliance.

  • Keep a derogation decision row for each candidate regime rather than burying the answer in meeting notes.
  • If only Article 3(3)(e) or (f) is excluded, continue the Article 3(3)(d) network-harm analysis where the product is internet-connected radio equipment.
  • Tie release gates, supplier attestations, and test-plan due dates to the 1 August 2025 application date.
  • Flag legal review when the product combines regulated medical, vehicle, aviation, tolling, payment, childcare, toy, wearable, or telecom-network functions.
Sources for this answer
Commission Delegated Regulation (EU) 2022/30 on RED cybersecurity
Source for the listed derogations from Article 3(3)(d), (e), and (f), and from Article 3(3)(e) and (f).
Commission Delegated Regulation (EU) 2023/2444 on RED cybersecurity application date
Amends Delegated Regulation (EU) 2022/30 so the RED cybersecurity requirements apply from 1 August 2025.
Section 3

Build the Article 3(3)(d/e/f) evidence matrix

The evidence matrix should connect each applicable RED cyber requirement to concrete product evidence. A reviewer should be able to trace from the legal trigger to the product feature, safeguard, verification result, residual issue, release owner, and technical-documentation location.

Do not use a single cybersecurity policy as the only evidence. RED evidence should include product-specific architecture, firmware and software behavior, data flows, authentication and access controls, update behavior, abuse cases, test results, supplier inputs, and conformity-assessment decisions.

  • For Article 3(3)(d), capture network-resilience evidence showing how the equipment avoids harming networks, misusing network resources, or causing unacceptable degradation of service.
  • For Article 3(3)(e), capture privacy and data-protection safeguards for personal data, traffic data, and location data, including default access, encryption, authentication, and unauthorized transmission risks where relevant.
  • For Article 3(3)(f), capture payment-fraud safeguards such as user authentication, transaction authorization, fraud-abuse testing, and limits around money, monetary value, or virtual-currency transfer functions.
  • Link each evidence row to a test report, design record, supplier declaration, software bill or version record, issue tracker item, risk decision, or technical-file section.
Sources for this answer
Commission Delegated Regulation (EU) 2022/30 on RED cybersecurity
Explains the network, personal-data and privacy, and fraud risks behind the activated RED essential requirements.
European Commission - cybersecurity of wireless devices and products
Commission announcement summarizing the network-resilience, privacy, and monetary-fraud objectives of the delegated act.
Recommended next step

Turn the RED cyber workflow into release evidence

Use Sorena to convert product facts, supplier inputs, standards decisions, and Article 3(3)(d/e/f) evidence into a reviewable RED cybersecurity pack.

Research workflow
Open Research Copilot

Answer RED scope, timing, and interpretation questions with cited outputs.

Explore next step
Talk to Sorena
Talk through implementation

Review your product classification, evidence matrix, standards route, and release gates.

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Section 4

Choose the standards, notified-body, and CE documentation route

After classification and evidence mapping, decide how the manufacturer will demonstrate conformity. Harmonised standards can support presumption of conformity when they are available and cited for the relevant requirement, but standards are not mandatory. Where the standards route does not support the claim, document the alternative conformity-assessment route and whether a notified body is needed.

Keep cyber evidence aligned with the broader RED technical documentation, EU declaration of conformity, CE marking decision, instructions, and post-release change controls. A firmware or cloud-service change can undermine the original evidence if the release process does not re-run the affected Article 3(3)(d/e/f) checks.

  • Record the exact harmonised standard, edition, OJEU citation status, requirement coverage, and test-lab output used for each claim.
  • Where no suitable harmonised standard is used, record the conformity-assessment module, notified-body involvement, certificate or opinion reference, and unresolved limitations.
  • Add a release hold if a cyber evidence row is missing, the product facts changed, a supplier component changed, or the standard cited no longer supports the claim.
  • After launch, re-run the workflow for security incidents, vulnerability fixes, material software updates, supplier substitutions, and authority or customer requests.
Sources for this answer
European Commission - harmonised standards overview
Commission source for harmonised standards and presumption-of-conformity context.
Commission Notice - Blue Guide on EU product rules (2022)
General EU product-law guidance for manufacturer responsibility, conformity assessment, CE marking, and technical documentation.
European Commission - cybersecurity of wireless devices and products
Commission source noting standards support and notified-body assessment as conformity routes for the new RED cyber requirements.
Primary sources

References and citations

Commission Notice - Blue Guide on EU product rules (2022)
eur-lex.europa.eu
Referenced sections
  • General EU product-law guidance for manufacturer responsibility, conformity assessment, CE marking, and technical documentation.
"The manufacturer is responsible for the conformity assessment."
Directive 2014/53/EU on radio equipment
eur-lex.europa.eu
Referenced sections
  • Primary RED text defining the Article 3(3)(d), (e), and (f) essential requirements.
"radio equipment does not harm the network or its functioning"
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