Understanding the EU Cyber Resilience Act
The EU Cyber Resilience Act (CRA) represents one of the most significant shifts in how the European Union governs the security of digital products. Set to take full effect in 2027, this regulation will require most software products sold or distributed in Europe to meet strict cybersecurity requirements; including the generation and maintenance of Software Bills of Materials (SBOMs), vulnerability disclosure processes, and post-market monitoring.
But here’s the uncomfortable truth: most articles, guides, and even official documentation seem to assume you have a 20-person AppSec team and a legal department on retainer. What if you’re running a small or mid-sized business with a handful of developers and no dedicated security staff?
This post is for you.
Let’s explore how small businesses can approach EU CRA compliance, what the real requirements look like, and how modern tools,especially those with strong automation capabilities,can help you meet them without drowning in overhead.
Why the CRA Matters for SMBs
Let’s start with the stakes.
If your company develops, imports, or distributes a software product (including embedded firmware or SaaS interfaces) in the EU market, you are likely within scope of the CRA.
Non-compliance could result in:
- Fines of up to €15 million or 2.5% of annual worldwide turnover
- Being blocked from the EU market entirely
- Liability exposure from downstream customers and partners
The idea that “regulations only matter for big companies” is a dangerous misconception.
Now, is there nuance in enforcement? Of course. But the bottom line is: if you’re shipping software to European customers, you need to plan for CRA compliance. You need to understand the CRA’s scope and how it affects software developers, vulnerability reporting timeline, and developer responsibilities under the CRA.
What the CRA Actually Requires: A Simplified View
Without simplifying the regulation to the point of uselessness, here’s a distilled breakdown of the core technical requirements relevant to software developers and SMBs:
1. SBOM Generation and Maintenance
You must document all components;open source and proprietary that your product relies on. This isn’t a one-time activity; it must be continuously updated as your software evolves.
📌 Read more: SBOM requirements under the Cyber Resilience Act
2. Vulnerability Handling and Disclosure
You must have a formal process for:
- Receiving vulnerability reports
- Triaging and patching confirmed issues
- Notifying ENISA within 24 hours of discovering an actively exploited vulnerability
3. Technical Documentation
You need to maintain documentation that proves your software was developed with secure practices; including secure development lifecycles (SDLC), testing, and code quality measures.
4. Secure by Default Configuration
Products must be shipped in a secure state. This includes disabling unnecessary services, requiring authentication, and ensuring secure update mechanisms.
5. Post-Market Monitoring
Once your product is out in the wild, you must continue monitoring for vulnerabilities and respond to newly discovered issues within the expected security support timelines.
For a complete implementation guide, see Preparing Your Development Team for CRA Compliance.
The SMB Challenge: Too Much, Too Fast
These requirements aren’t unreasonable; but they are overwhelming for teams that aren’t set up for formal compliance processes.
Small businesses typically face:
- No dedicated security staff: Developers wear the AppSec hat, often reluctantly.
- Limited budgets: Enterprise SAST/SCA/DAST tools are out of reach.
- Tool fatigue: Running 5–10 separate security tools is unsustainable.
- Audit anxiety: There’s no central record of what was tested or fixed.
The result? Compliance becomes a paperwork exercise, disconnected from actual security practices.
A Practical Path Forward
Let’s talk solutions. The goal here is to help you meet the CRA’s intent; not game it with theater, but build a pragmatic, real-world compliance posture.
Step 1: Automate SBOM Generation
Manually tracking dependencies is a non-starter. You need automation.
Tools like SCA (Software Composition Analysis) can:
- Scan your codebase for all third-party libraries and transitive dependencies
- Output SBOMs in CycloneDX or SPDX format
- Update dynamically as dependencies change
ScanDog, for example, generates SBOMs automatically as part of CI/CD, so you’re never out of date.
Step 2: Consolidate Your Scanning
Instead of juggling a dozen disconnected tools, consider a unified Application Security Posture Management (ASPM) platform that includes:
- SAST (Static Application Security Testing) for source code flaws
- DAST (Dynamic Application Security Testing) for runtime vulnerabilities
- SCA for open-source risk
- Container Scanning for image security
- Secret Detection for leaked credentials
- IaC Scanning for infrastructure misconfigurations
This not only improves efficiency but also gives you a single source of truth; essential for audit readiness.
📌 Learn more: What is ASPM?
Step 3: Build a Simple Vulnerability Handling Workflow
CRA doesn’t require you to use a specific tool or ticketing system. But you do need:
- A way to receive reports (e.g., a [email protected] alias, or a GitHub Security Advisory page)
- A triage and prioritization process (see: smart prioritization)
- A remediation workflow with timelines and SLAs
- Logging of what was done and when (hello, audit trail)
You can use tools like Jira, Linear, or even a well-maintained spreadsheet; but it must be consistent and documented.
Step 4: Embrace AI-Assisted Remediation
Fixing vulnerabilities used to require manual review and deep security expertise. But modern AI-powered tools can now:
- Suggest code-level fixes for detected issues
- Auto-generate pull requests with secure alternatives
- Prioritize vulnerabilities by actual exploitability, not just CVSS score
ScanDog’s AI Fix feature is a prime example: it doesn’t just flag problems; it shows you how to fix them, often in one click.
Step 5: Document Everything
You don’t need a 200-page Word document. But you do need:
- A security policy (even 1–2 pages is fine)
- Evidence that scanning runs regularly (CI logs, dashboards)
- Records of how you responded to past vulnerabilities
- Changelogs and version control (you probably have this already)
Pro tip: Export your vulnerability reports and SBOM snapshots regularly. You never know when an auditor might ask.
Don’t Panic; But Do Start Now
The CRA doesn’t go into full enforcement until 2027, but the smart move is to start building muscle memory now. Don’t wait until 6 months before the deadline.
Why?
- Tooling and processes take time to integrate
- Early adopters will have a competitive edge in EU markets
- Starting early means finding issues gradually, not all at once
What About Open Source?
One area of concern for SMBs: open source maintainers aren’t going to do your compliance for you. The CRA explicitly places responsibility on the manufacturer or importer;that’s you.
If you’re using open source, you need to:
- Maintain your own inventory (again, SCA helps here)
- Evaluate project health (is it actively maintained?)
- Monitor for newly disclosed CVEs affecting your dependencies
Check out our guide on Reachability Analysis and SCA for more context on how to filter out noise and focus on what matters.
Final Thoughts
The EU Cyber Resilience Act is not a checkbox exercise; it’s a cultural shift toward transparency and accountability in software. But it doesn’t have to crush small businesses.
With smart automation, consolidated tooling, and a mindset shift from “reactive firefighting” to “proactive governance,” SMBs can meet CRA requirements without burning out. Start with SBOMs. Consolidate your scanners. Automate everything you can. And build a paper trail that makes auditors smile.
You don’t need a 100-person security team. You need the right tools and a plan.
Additional CRA Resources
Explore our complete Cyber Resilience Act series to learn more about specific requirements and how to prepare your organization for compliance.
ScanDog is an AI-powered Application Security Posture Management (ASPM) platform that helps development teams build secure software faster. With advanced vulnerability prioritization, reachability analysis, and AI-assisted remediation, ScanDog cuts through the noise of false positives to focus on what truly matters.