The EU Cyber Resilience Act introduces a new era of cybersecurity for digital products within the European Union. For software developers, this landmark legislation translates into a clear mandate: embed security into every stage of the software development lifecycle.

This guide provides a practical, step-by-step roadmap to help developers navigate the Act’s requirements and build secure-by-design software.

Phase 1: Understanding the Cyber Resilience Act and Its Implications

• Deep Dive into the Legislation: Familiarize yourself with the full text of the Cyber Resilience Act. Focus on understanding the core principles, key requirements, and the classification system for digital products.
• Determine Product Classification: Assess your software’s functionality, intended use, and potential impact to determine its classification under the Act (Standard Class, Class I, or Class II).2 This classification will dictate the specific conformity assessment procedures and security requirements applicable to your software.
• Inventory Existing Security Practices: Conduct a thorough review of your current cybersecurity practices and policies. Identify areas of strength and areas that require improvement to align with the Act’s requirements.

Phase 2: Building a Secure Software Development Lifecycle (SDLC)

• Integrate Security from the Outset: Embed security considerations into the earliest stages of the SDLC, from requirements gathering and design to coding, testing, and deployment. Security should not be an afterthought but a fundamental element of the development process.
• Adopt Secure Coding Practices: Train developers on secure coding principles and techniques. Encourage the use of static and dynamic code analysis tools to identify and remediate vulnerabilities early in the development cycle.
• Prioritize Vulnerability Testing: Implement a robust vulnerability testing program, including penetration testing, fuzz testing, and code reviews. Regularly scan for known vulnerabilities using automated tools and vulnerability databases.
• Establish a Vulnerability Management Process: Develop a clear process for handling identified vulnerabilities, including timely patching, communication with stakeholders, and documentation of remediation steps.

Phase 3: Fulfilling Documentation and Reporting Obligations

• Document Cybersecurity Risks: Meticulously document all identified cybersecurity risks associated with your software. This documentation should include a description of each risk, its potential impact, and the mitigation measures implemented.
• Develop a Software Bill of Materials (SBOM): Create an SBOM that provides a detailed inventory of all software components, libraries, and dependencies used in your product. An SBOM enhances transparency and enables efficient vulnerability management.
• Establish Incident Reporting Procedures: Define clear procedures for reporting security incidents and exploited vulnerabilities to ENISA and affected users within the 24-hour timeframe mandated by the Act.

Phase 4: Preparing for Conformity Assessment

• Select an Appropriate Conformity Assessment Route: Depending on the classification of your software, choose the appropriate conformity assessment procedure: self-assessment for Standard Class products or third-party assessment for Class II products.
• Gather Evidence of Compliance: Compile comprehensive documentation to demonstrate your compliance with the Act’s requirements. This evidence may include security policies, test results, vulnerability remediation records, and incident response reports.
• Engage with a Notified Body (if applicable): For Class II products, engage with a notified body authorized to conduct conformity assessments under the Cyber Resilience Act. The notified body will evaluate your software’s security posture and issue a conformity certificate if the requirements are met.

Phase 5: Continuous Monitoring and Improvement

• Implement Continuous Security Monitoring: Integrate security monitoring tools and processes to detect and respond to emerging threats and vulnerabilities throughout the product lifecycle.
• Stay Informed About Emerging Threats: Actively monitor security advisories, vulnerability databases, and industry best practices to stay ahead of evolving threats.
• Embrace a Culture of Continuous Improvement: Continuously evaluate and refine your cybersecurity practices to address new threats, adapt to changing regulations, and maintain a robust security posture.
• Partnering for Success: Companies like i46 offer specialized consultancy and platforms designed to support software developers in achieving compliance with the Cyber Resilience Act. 
• Automated Security Analysis: Conducting comprehensive vulnerability assessments of software, including binary firmware analysis.
• Real-Time Monitoring: Providing continuous monitoring for security vulnerabilities and incidents, enabling timely response and reporting.
• Expert Consulting: Offering guidance on implementing secure development practices, interpreting the Act’s requirements, and preparing for conformity assessment.

Software developers can streamline their compliance with the EU Cyber Resilience Act by partnering with solutions like i46. For instance, i46 can automate the generation of required documentation, such as the Software Bill of Materials (SBOM).