Evaluate CRA software as an evidence and workflow system rather than a checklist engine. It should preserve product and version context, link requirements to evidence, maintain approvals and history, support urgent vulnerability and reporting workflows, export controlled records and remain understandable to reviewers. Automation should reduce repetitive work without hiding legal or technical decisions behind black-box scoring.
Start With Product-Centric Records
The CRA applies through products with digital elements and manufacturer obligations attached to them. Software should therefore begin with stable product records, versions, intended purpose, remote processing, market status, support status and ownership rather than only organisation-level controls.
Preserve Scope and Classification Reasoning
A dropdown showing in scope, class I or class II is not enough. The platform should preserve the product facts, legal references, reviewer, uncertainty and decision history behind scope and classification so a later reviewer can understand why the status was selected.
Make the Cybersecurity Risk Assessment a Core Object
Article 13 places the product cybersecurity risk assessment at the centre of design and lifecycle decisions. Software should connect threats, attack scenarios, assets, risk treatment, Annex I applicability, controls, tests, residual risk and reassessment triggers rather than storing the assessment as an uploaded PDF only.
Support Requirement-to-Evidence Traceability
A useful system maps applicable Annex I requirements to design controls, process evidence, test reports and responsible owners. Not-applicable decisions should require reasoning. Reviewers should be able to move from a requirement to the evidence and from the evidence back to the affected product and version.
Connect SBOM and Component Records to Products
Component data should be version-aware and linked to the products that actually contain those components. Integrations can import SBOM data and vulnerability intelligence, but the platform should preserve the manufacturer's product-specific applicability and remediation decisions.
Include a Product Vulnerability Workflow
Vulnerability records should show affected products and versions, component context, risk, remediation, testing, update release, disclosure and support status. The system should escalate potential active exploitation for Article 14 review without assuming every vulnerability is reportable.
Support Time-Critical Article 14 Reporting
Reporting features should capture awareness time, affected products, available facts, internal approvals, SRP submission stages and deadlines. A useful system distinguishes the 24-hour early warning, 72-hour notification and final-report stages while allowing facts to be updated as the investigation develops.
Build Technical Documentation From Controlled Evidence
Instead of assembling the Annex VII file manually at the end, software should link product description, architecture, risk assessment, vulnerability processes, SBOM, standards, testing and declaration evidence throughout development. Export should preserve references and version context.
Track Conformity Route and External Dependencies
The platform should connect product classification to the selected Article 32 route, document why the route is available, track notified-body involvement where required and retain assessment findings and closure evidence. It should not present a green status as an automatic legal conformity decision.
Track Support Periods and Lifecycle Milestones
Store support-period reasoning, end dates, supported versions, vulnerability-handling ownership and end-of-support milestones. Alerts can surface upcoming deadlines, but the product team must still make and approve the underlying support-period determination.
Require Review, Approval and Audit History
Important scope, classification, risk, conformity and support decisions should show who drafted, reviewed and approved them, when they changed and what evidence supported the change. Role-based access and immutable history can be more valuable than another dashboard widget.
Provide Export and Data Portability
Manufacturers should be able to export product records, evidence mappings, risk decisions, technical-documentation material and audit history in usable formats. Avoid creating a compliance record that becomes inaccessible if the vendor changes pricing, is acquired or the organisation later migrates systems.
Keep Automation Explainable
Automation can suggest missing evidence, populate known product metadata, map components and calculate workflow deadlines. It should not silently decide legal scope, classification, risk acceptability or conformity. Any recommendation should remain reviewable and show the facts and rules on which it relies.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.