How the EU Cyber Resilience Act Will Reshape the Embedded Device Market in 2025–2027

The EU Cyber Resilience Act (CRA) is not just another regulatory document—it’s a turning point for every company that designs, builds, or sells embedded and connected products in Europe. As the law moves toward full enforcement in 2025–2027, it will reshape how embedded systems are developed, maintained, and certified. This article explains what’s changing, why it matters, and how engineering teams can prepare.

What Is the Cyber Resilience Act and Why It Exists

The CRA is the European Union’s first horizontal legislation focused entirely on cybersecurity for digital products. Unlike past directives, it sets mandatory cybersecurity requirements for connected devices sold in the EU, including industrial controllers, routers, edge AI modules, EV infrastructure systems, smart home devices, and more.

The CRA aims to reduce the growing number of security incidents caused by poor design, outdated firmware, and missing protections in embedded software. It pushes manufacturers toward:

Secure-by-design product development
Continuous vulnerability monitoring and patching
Clear documentation of software components (SBOMs)
Transparent incident reporting and lifecycle support

Who Will Be Affected by the CRA

The scope of the law includes all “products with digital elements.” For the embedded systems industry, that covers:

Industrial and energy automation systems
Automotive ECUs, HMI units, and telematics platforms
Telecom switches, routers, and IoT gateways
Consumer electronics and smart home devices
Edge AI and vision systems
Medical devices and connected wearables

Even if the product is manufactured outside the EU but sold in Europe, the manufacturer or importer becomes responsible for CRA compliance.

What Compliance Really Means for Engineering Teams

The CRA introduces not just legal obligations but a shift in how embedded systems are designed. From the earliest stages of hardware and firmware development, engineers will need to consider:

Secure boot, secure update mechanisms, and encryption as default
Lifecycle support planning for security patches
SBOM creation and maintenance tools
Attack surface minimization and proactive threat modeling

It also affects the selection of processors, operating systems, and third-party libraries. Components that lack long-term support or have a poor vulnerability record may become non-compliant by default.

From Performance-First to Security-First Development

Historically, many embedded devices prioritized speed, efficiency, and real-time behavior. Security was often an afterthought or limited to the network level. With the CRA, this mindset must change.

Secure firmware, hardened configurations, and tested fallback procedures will become just as important as real-time performance. Development workflows will need to integrate:

Static and dynamic code analysis
Continuous security testing
Traceable logging and audit mechanisms
Integration with compliance platforms

In effect, security will move upstream in the product lifecycle—from post-release concern to design-time requirement.

What Happens If a Company Ignores CRA

Non-compliance with the Cyber Resilience Act is not a light matter. Penalties include:

Fines of up to €15 million or 2.5% of global annual turnover
Withdrawal of products from the EU market
Public warnings and listing as a non-compliant manufacturer
Legal liability in case of damage from exploited vulnerabilities

For vendors and OEMs, this is not only a regulatory risk—it’s a reputational one. A single uncovered vulnerability in a shipping product may trigger investigation across the whole portfolio.

Challenges for Legacy and ODM-Based Products

Many vendors rely on white-label designs, ODM suppliers, or legacy platforms that haven’t been updated in years. Under CRA, this becomes a major liability. In these cases, companies face two options:

Retire or re-engineer legacy products with no clear path to compliance
Build new platforms from scratch with secure-by-design principles

The same applies to ODMs: their platforms must now come with security guarantees, documentation, and support workflows—otherwise, clients will have to look elsewhere.

Opportunities for Early Movers

Despite the complexity, CRA compliance is also an opportunity to lead the market. Companies that offer:

Pre-certified, secure embedded platforms
Secure firmware over-the-air (OTA) systems
CRA-aligned edge computing modules
Compliance documentation as part of the delivery package

will become preferred partners for European OEMs, especially in regulated markets like automotive, energy, and industrial automation.

Vendors who act now can establish market trust, reduce future refactoring costs, and win projects before competitors adapt.

What We See in the Market at Promwad

At Promwad, we’re already seeing the shift. Clients building telecom, energy, and automotive platforms are requesting:

Hardened Linux systems with verified update mechanisms
Support for cryptographic authentication and secure bootloaders
Integration of SBOM tools and vulnerability scanners into CI/CD pipelines
Firmware workflows mapped to IEC 62443 and ISO 21434 frameworks

In most cases, these requests are driven by either internal compliance teams or partners preparing for CRA rollout.

How to Get Ready: A Practical Checklist

For product teams building embedded systems today, preparation should start with:

Risk analysis and security assessment of current product lines
Component evaluation for CRA compatibility (OS, MCU, libraries)
Security architecture design at the system and firmware level
Adoption of SBOM tools and secure development toolchains
Integration of update management for over-the-air patching
Documentation workflows for compliance reporting and audits

Working with a partner that understands embedded security—not just general software—will speed up this transition.

Looking Ahead: CRA in 2025–2027

While the law will roll out in stages, most obligations will become enforceable between mid-2025 and late 2026. By 2027, non-compliant products may be entirely blocked from EU markets.

Engineering leaders should treat 2025 as the final year for redesign, not the start. Vendors who wait until enforcement begins will face production delays, legal exposure, and urgent redesign work under pressure.

The CRA is not going away—it’s the new baseline.

Final Thoughts

The Cyber Resilience Act changes the game for embedded systems. It demands new engineering habits, better architecture planning, and a long-term view of security and compliance. For companies building smart, connected devices, the next 18–24 months will define whether they lead—or scramble to catch up.

By acting now, vendors can turn regulation into differentiation, compliance into trust, and engineering discipline into long-term growth.