Cyber Resilience Act: Your Action Plan - Part II: How to Break Down Your Compliance Strategy

This is the second article in our multi-part series: “Cyber Resilience Act: Your Action Plan”.

• Part I: What You Need to Know About and Why You Can’t Wait (read)
• Part II: How to Break Down Your Compliance Strategy (this article)

In our first article, we explored the obligations introduced by the Cyber Resilience Act (CRA) for software producers, key timelines, and the importance of early preparation, and how existing security practices align with the CRA’s requirements.

Now, in Part II, we move from understanding the regulation to putting that knowledge into action.

Your CRA Action Plan

At Chainloop, we believe that preparing for the Cyber Resilience Act (CRA) starts with a clear, phased strategy. Based on the regulation’s structure, intent, and timeline, here’s how we recommend breaking it down to guide your journey toward full compliance.

The first step in your action plan is to implement a vulnerability management process. This will help you identify active exploits that must be reported to authorities, such as ENISA — a critical requirement under the CRA for all products existing in the EU market by September 2026. Early identification and resolution of vulnerabilities will help ensure your products remain secure.

After setting up your vulnerability management process, the next phase is to progressively integrate secure-by-design practices into your development process. This will be an ongoing effort, as security must be continuously embedded at every stage of the product life cycle. These practices are central to the CRA and will ensure that security is built into your products from the start and evolves as your products do.

In addition to adopting these best practices, you’ll also need to meet specific concrete requirements, such as maintaining detailed technical documentation, affixing the CE marking to your products, and ensuring proper conformity assessments. These are vital steps for achieving compliance and demonstrating that your products are secure for consumers.

Here’s what your CRA compliance action plan might look like:

Phase I. Adopt Vulnerability Management Practices:

• Address vulnerabilities throughout the product lifecycle and provide timely security updates, demonstrating compliance with Annex I, Part II.
• Report actively exploited vulnerabilities and significant cybersecurity incidents to ENISA, as required by Article 14.

Phase II. Adopt Secure-by-Design Practices:

• Integrate security measures based on risk assessments in design, development, and production, and demonstrate compliance with the essential cybersecurity requirements in Annex I, Part I.

Phase III. Transparency:

• Clearly communicate cybersecurity features, update policies, and support periods to users, as required in Annex II.
• Prepare and keep technical documentation up to date during the product support period in accordance with Article 31 and Annex VII.
• Affix the CE marking to demonstrate conformity, as required by Article 19.
• Issue a written EU Declaration of Conformity for each product and retain it for 10 years or the support period, whichever is longer, as referenced in Article 20 and Annex VI.

By following this action plan, you’ll move toward CRA compliance, strengthen your security posture, and build greater trust with your users.

With an action plan in hand, the next step is figuring out how to execute it in practice. That’s where Chainloop comes in.

What’s Next

With a clear action plan mapped out, the real challenge lies in execution: turning strategy into day-to-day practice. That’s where Chainloop can help.

Our platform is designed to help you operationalize CRA requirements. Whether you need help tracking compliance progress, generating evidence for audits, or integrating CRA controls into your existing development workflows, Chainloop gives you the tools to make it happen.

Ready to get started? Explore our CRA Reference and Tracking Compliance Guide or book a personalized demo with our team to see how Chainloop can streamline your CRA efforts.

Stay tuned for the next articles in the series, where we’ll kick off a deep dive into each phase of your CRA action plan and explore how Chainloop enables the execution of your compliance strategy, from vulnerability management to transparency.

Questions or want to talk strategy? Contact us — we’re here to help.