The European regulation Cyber Resilience Act (CRA) fundamentally changes the way product security is handled. What was previously addressed sporadically and in isolated projects is now becoming a binding requirement. Starting in September 2026, the first reporting obligations for security incidents will apply; by December 2027, companies must demonstrate full compliance with all provisions.
For industrial companies, this marks nothing less than a paradigm shift: product security is no longer optional but a regulatory prerequisite for market access in the European Union.
While many see the CRA primarily as a regulatory hurdle, at Consulteer InCyber we consider it a strategic opportunity. Properly implemented, security not only minimizes risks but can also become a true competitive advantage.
At a glance
CRA will be mandatory for all products with digital elements from 2026/2027
Without compliance → no market access, heavy fines, reputational risks
Security becomes a strategic prerequisite for competitiveness
Why the CRA is particularly relevant for Industrial Companies
The industry is especially impacted by this new regulation. Almost every product today includes digital elements - whether it’s a connected sensor, a machine controller, or software modules powering production processes. The CRA does not differentiate between sectors; it defines requirements for all products with digital functionality. This means that traditional industrial companies fall under the same rules as consumer electronics manufacturers or software vendors.
Why the CRA is particularly relevant for Industrial Companies
The industry is especially impacted by this new regulation. Almost every product today includes digital elements - whether it’s a connected sensor, a machine controller, or software modules powering production processes.
The CRA does not differentiate between sectors; it defines requirements for all products with digital functionality. This means that traditional industrial companies fall under the same rules as consumer electronics manufacturers or software vendors.
The consequences of non-compliance are severe: without adherence to CRA requirements, CE marking will no longer be possible. In plain terms: affected products may not be marketed in the EU. On top of that, hefty fines of up to €15 million or 2.5% of global annual revenue apply. Even more damaging is the risk of reputational harm. In an industry built on trust, stability, and reliability, a publicized security incident can weaken market position for years.
At Consulteer InCyber, our stance is clear: the CRA is not an isolated IT issue. It directly affects value chains, innovation cycles, and strategic business models. Security is becoming the foundation of competitiveness.
At a glance
Industrial products almost always include digital elements → CRA applies
Risks: market exclusion, fines, reputational damage
CRA is a business issue, not just an IT task
The CRA Requirements
The CRA defines a comprehensive set of requirements that manufacturers, importers, and dealers must implement.
In doing so, the regulation explicitly distinguishes between the different roles in the value chain, and depending on the role, the requirements vary significantly, both in terms of the scope of technical measures and the associated verification and documentation obligations.
Manufacturers
Carry the main burden. They must implement Security by Design to ensure products are secure from the ground up. This includes creating a Software Bill of Materials (SBOM), providing vulnerability management information, producing compliance reports, and ensuring security updates throughout the product lifecycle.
Integrators
Integrators assemble components into complete systems. They must ensure that all components meet CRA requirements, consolidate SBOMs, and process security notifications. If they make substantial modifications, they may assume the full responsibility of a manufacturer.
Operators
Operators are the end users responsible for safe operation. They must purchase CRA-compliant products, promptly apply security updates, and maintain incident management and ongoing compliance.
Connected to this is the requirement for vulnerability and incident management. Companies must be able to identify, assess, and report vulnerabilities systematically - to ENISA and national CSIRTs. These obligations begin as early as 2026, requiring short-term structures.
Another major challenge is the SBOM obligation, requiring a machine-readable, standardized, and supply-chain-wide list of software components. This is particularly complex in industrial supply chains.
Furthermore, the CRA mandates security updates throughout the entire support period - often 10+ years in industrial equipment.
All measures must be documented and verifiable. Depending on product criticality, self-certification may suffice, but many cases will require external certification.
For industrial companies: product security must be systematic, role-specific, and fully integrated into processes and technology.
At a glance
Security by Design mandatory from day one
Reporting obligations for vulnerabilities starting in 2026
SBOM for supply chain transparency
Updates & support throughout the lifecycle
Documentation & (self-)certification required
Roles differ:
Supplier = secure components
Integrator = secure systems
Owner = secure operation
Recommendations for Industry: How to approach CRA Compliance
To not only meet requirements but also create value, we recommend a three-pillar approach: organization, technology, culture.
Organization & Responsibility
Clarity is needed: product security is not only IT’s responsibility. It affects R&D, quality management, legal, and even sales. Companies should establish an interdisciplinary steering team to coordinate CRA compliance.
CRA requires long-term governance - beyond certification. That means: clear roles, defined processes, and adaptable structures.
Technology & Processes
Companies must translate CRA requirements into processes:
Professional SBOM management is a priority.
Building vulnerability and incident management capabilities.
Embedding Security by Design in development.
Investments in tools are important, but process integration is critical: security must be part of product development and QA.
Culture & DNA
The biggest shift: treating security as part of corporate DNA. Engineers and developers must view security as naturally as functionality or cost. Leaders should communicate security as a value proposition.
At Consulteer InCyber, we believe: true resilience comes not from checklists but from culture.
At a glance
Organization: governance, clear responsibilities
Technology: SBOM, incident management, Security by Design
Culture: security awareness as part of corporate DNA
Challenges for Industry
Implementing the CRA comes with specific hurdles for industrial companies.
Complex supply chains: A single product can consist of hundreds of components from different suppliers. If even one of these components fails to meet CRA standards, the entire product becomes non-compliant. Building transparency and collaboration across the supply chain is therefore critical.
Long product lifecycles: Industrial machinery often runs for 10, 15, or even 20 years. The obligation to provide continuous security updates poses not only a technical but also an organizational challenge. Companies must design long-term support models that are also economically viable.
Dependence on CE marking: Without CE compliance, products cannot be marketed in the EU. That means regulatory compliance is directly linked to revenue and market presence.
At Consulteer InCyber, we believe these challenges are solvable - but only through a holistic approach that addresses technology, organization, and culture equally.
At a glance
Organization: governance, clear responsibilities
Technology: SBOM, incident management, Security by Design
Culture: security awareness as corporate DNA
Considerations for Swiss industrial Companies
The Cyber Resilience Act (CRA) is a European Union regulation. It does not automatically apply to Swiss companies – yet in practice, they are often directly affected.
This is because many Swiss industrial companies are export-oriented. As soon as products with digital elements are delivered to the EU, compliance with the CRA is mandatory. For companies that remain in the domestic market, this may at first glance appear to be a purely European issue, but here too, it is becoming apparent that Switzerland will follow suit in terms of regulation.
Discussions are already underway in various political and economic forums on how Swiss law should be harmonized in order to ensure long-term market access to the EU.
Swiss companies face a double challenge: on the one hand, they must ensure CRA compliance for export products in a timely manner; on the other hand, it is likely that similar requirements will also be enshrined in Swiss law in the medium term.
Another point is the strong position of SMEs in Swiss industry. Many suppliers are medium-sized companies that have little experience with regulatory product safety to date. Pragmatic approaches are needed here: lean processes, scalable solutions, and partnership-based support along the supply chain.
Consulteer InCyber Perspective:
We view the CRA as an opportunity for Swiss companies to strengthen their competitive position in the EU. Early compliance builds trust with EU customers and positions Swiss Quality as a leader in cybersecurity as well.
At a glance
CRA applies to Swiss companies exporting to the EU
Switzerland likely to follow suit → early action pays twice
Challenge: SMEs in supply chains → need pragmatic solutions
Opportunity: strengthen “Swiss Quality” with cybersecurity leadership
The CRA from an SME Perspective: Pragmatism over Bureaucracy
Large corporations can establish dedicated security and compliance teams. Small and medium-sized enterprises (SMEs), however, face unique challenges. Many SMEs are suppliers in complex value chains and will soon need to prove CRA compliance - or risk being excluded from supplier lists.
Typical SME challenges include:
Limited resources: SMEs rarely have in-house security or legal teams
Customer dependency: OEMs or global partners often demand rapid compliance proof
Lack of processes: SBOM management, documentation, or incident reporting often not in place
Still, CRA compliance is achievable for SMEs - if done pragmatically:
Focus: Start with the most important products instead of tackling everything at once
Standardized tools: Use existing SBOM and vulnerability management tools instead of reinventing the wheel
Collaboration: Cooperate with partners, associations, or consulting firms to save time and costs
Culture over paperwork: Even small steps like security training or clear accountability can have a big impact
Consulteer InCyber Perspective
We support SMEs with scalable, lightweight solutions. Instead of overwhelming them, we design step-by-step roadmaps that conserve resources while ensuring CRA compliance. For SMEs, security should not be a growth barrier but a trust factor in supply chains.
At a glance
SMEs often lack compliance teams → need pragmatic solutions
Risk: exclusion from supply chains without CRA compliance
Approach: prioritize, use standard tools, seek cooperation
Opportunity: lean compliance builds trust with customers
Conclusion: Obligation & Opportunity at Once
The Cyber Resilience Act is far more than a legal formality. It forces companies to rethink their products and processes from the ground up. For industry, this means considerable effort at first. Yet at the same time, the CRA opens up the opportunity to use security as a competitive advantage.
Those who act now not only minimize risks but also position themselves as trusted providers in an increasingly digital market. Security becomes a quality feature that convinces customers, partners, and investors alike.
At Consulteer InCyber, we guide companies on this journey - bringing regulatory expertise, technological know-how, and deep industry understanding. Our goal: to co-develop solutions with our clients that are practical, future-proof, and embedded in the company’s DNA.
Next Steps
Companies should not wait but act immediately. A practical roadmap could look like this:
Impact analysis: Which products fall under the CRA?
Gap analysis: Which structures exist, where are the gaps?
Roadmap development: Which measures are short-term, which are long-term?
Implementation & integration: Processes, tools, responsibilities
Audit readiness: Ensure verifiable compliance - internally and externally
Consulteer InCyber supports you in all phases - from analysis to roadmap to audit readiness. Our aim is not only compliance but to make your organization sustainably resilient.
Sources
European Commission: Cyber Resilience Act - Proposal
German Federal Ministry for Economic Affairs and Climate Action (BMWK): Information on the CRA
ENISA - European Union Agency for Cybersecurity: CRA Overview and Guidance
European Parliament: CRA Regulation documents
Deloitte / PwC Reports (2023): Industrial impact assessments of the CRA
