The European Union’s Cyber Resilience Act (CRA) represents a seismic shift in how software and hardware products are regulated. For small startups, the path to compliance is often a sprint—intense but relatively straightforward. For large enterprises, however, it is a marathon run through a minefield.
Enterprises face a unique set of hurdles when adapting to these new regulations. You are not just securing a single app; you are likely managing a sprawling ecosystem of legacy systems, a labyrinth of internal departments, and a supply chain that spans the globe. The CRA demands that products with digital elements be secure by design and supported throughout their lifecycle. For a global organization, retrofitting these principles into existing operations is a massive undertaking.
Here is a look at the specific challenges enterprises face with the CRA and the strategic solutions required to overcome them.
The Weight of Legacy Infrastructure
One of the most significant barriers for established enterprises is the sheer volume of legacy technology. Unlike a digital-native company built on modern microservices, an enterprise might have core products running on codebases that are decades old.
The CRA applies to products currently on the market. This means that software developed five or ten years ago—before “secure by design” was a regulatory mandate—must now meet strict cybersecurity requirements.
Retooling these legacy systems is costly and risky. In many cases, the original developers are long gone, and documentation is sparse. Yet, under the CRA, you are responsible for the vulnerability management of every component in that system. Ignoring legacy products is not an option if you intend to keep selling them in the EU.
Breaking Down Organizational Silos
Compliance is rarely a technical problem alone; it is an organizational one. In large enterprises, the responsibility for product security often falls into the cracks between departments.
The CRA requires a unified approach. Vulnerability disclosure timelines are tight, and the requirement to report actively exploited vulnerabilities to ENISA (the EU Agency for Cybersecurity) within 24 hours demands seamless communication. If your legal team takes three days to approve a notification that engineering flagged on a Monday, you are already non-compliant.
The Supply Chain Sprawl
Enterprises do not build software in a vacuum. You rely on thousands of third-party libraries, open-source components, and vendor-provided modules. The CRA places the burden of security squarely on the manufacturer of the final product.
If a vulnerability exists in a third-party library deeply embedded in your software, it is your problem to fix. For an enterprise with hundreds of products, gaining visibility into this supply chain is a monumental data challenge. You cannot secure what you cannot see, and manual tracking of dependencies is impossible at this scale.
Strategic Solutions for Enterprise Compliance
Despite the complexity, compliance is achievable. It requires moving away from ad-hoc security measures and adopting a systemic, automated approach to cyber resilience.
1. Adopt a Unified Compliance Framework
Don’t reinvent the wheel. Align your CRA strategy with existing international standards such as ISO/IEC 27001 or the NIST Cybersecurity Framework (CSF). These frameworks provide a structured language that can help bridge the gap between technical teams and executive leadership.
By mapping CRA requirements to a broader framework, you can standardize processes across different business units. This ensures that when a new product is developed in one division, it follows the same security lifecycle as a product in another, reducing the administrative burden of proving conformity.
2. Leverage Automation and SBOMs
Manual security reviews cannot scale to meet enterprise needs. Automation is the only viable path forward. This starts with the Software Bill of Materials (SBOM).
An SBOM acts as an ingredients list for your software. You must implement tools that automatically generate and update SBOMs for every build. When a new vulnerability (CVE) is announced for a specific library, your automated systems should instantly identify which of your products are affected.
Furthermore, integrate automated vulnerability scanning into your CI/CD pipelines. This ensures that developers catch security issues before code is ever merged, shifting security “left” and reducing the cost of remediation.
3. Conduct Regular Audits and Tabletop Exercises
Procedures look great on paper but often fail in practice. Regular internal audits are essential to ensure that your vulnerability handling processes are actually working.
Go beyond the audit checklist by conducting tabletop exercises. Simulate a critical vulnerability disclosure or a supply chain breach. Test whether your engineering team can identify the issue, patch it, and whether your legal and comms teams can handle the reporting requirements within the CRA’s strict timeframes. These exercises will expose the silos and communication breakdowns that need fixing before a real crisis hits.
4. Isolate or Sunset High-Risk Legacy Assets
For legacy systems that are too costly to bring into full compliance, you may need to make hard decisions. Conduct a risk assessment for your older portfolio.
If a product generates low revenue but carries high compliance risk, it might be time to sunset it. If the product is critical, investigate ways to isolate it architecturally to minimize the attack surface, or invest in a “strangler fig” pattern to gradually replace legacy components with modern, compliant microservices.
Moving Forward
The Cyber Resilience Act is forcing enterprises to mature their software development lifecycles. While the initial lift is heavy, the long-term result is a more robust, secure, and trustworthy product portfolio.
This transition requires clear guidance and a deep understanding of the regulatory nuances. For a detailed breakdown of the requirements and how they impact your organization, reviewing this comprehensive guide onCyber Resilience Act compliance is an excellent next step. You can also find official information and updates on theEuropean Commission’s Cyber Resilience Act policy page.
Start by auditing your current posture. The cost of compliance is significant, but the cost of non-compliance—ranging from massive fines to market exclusion—is far higher.
