This blog is the 7th of our Tales From the Trenches: CRA Lessons Learned blog series. Our objective in developing these blogs is to help manufacturers, software vendors, and connected-product providers understand practical implementation realities of CRA compliance programs. We will draw on lessons we have learned from working with our customers and in talking to industry leaders. Organizations are learning that sustainable compliance requires governance, visibility, accountability, and lifecycle management capabilities that extend well beyond traditional cybersecurity activities. Building a secure product is not enough to achieve CRA compliance.
Why the Cyber Resilience Act Is Breaking Down Organizational Silos
When many organizations first began preparing for the European Union’s Cyber Resilience Act (CRA), they naturally assumed responsibility would fall primarily on cybersecurity and engineering teams.
After all, the regulation focuses on cybersecurity requirements for products with digital elements. Vulnerability management, secure development, incident reporting, software supply chain management, and security updates all appear to be technology-focused activities.
The reality, however, is not that simple.
CRA compliance is not a cybersecurity project. It is an enterprise-wide operating model challenge.
No single department has all the information, authority, processes, or expertise required to satisfy CRA obligations. Product development teams understand product functionality. Security teams manage cyber risk. Legal departments interpret regulatory obligations. Quality teams oversee documentation and audits. Product managers define support commitments. Procurement teams manage supplier relationships. And executive leadership establishes governance and accountability.
The CRA requires coordination between all of these functions simultaneously. Many organizations are discovering that CRA compliance requires coordinating people, processes, and information across the enterprise in a way not previously envisioned.
Those organizations with successful CRA compliance programs are not simply improving cybersecurity. They are creating new cross-functional governance models capable of sustaining cybersecurity accountability throughout the entire product lifecycle.
Executive Insights
One of the most significant shifts introduced by the CRA is the expansion of cybersecurity accountability beyond the security organization.
Historically, cybersecurity responsibilities often remained relatively siloed. Engineering developed products. Security reviewed designs and conducted assessments. Legal reviewed contracts. Quality managed certifications and audits. Support handled customer issues.
Each team performed its own responsibilities with limited overlap. The CRA changes that dynamic.
Today, activities such as product classification, risk assessments, SBOM management, vulnerability reporting, customer communications, supplier governance, technical documentation, and conformity assessments require collaboration across multiple business functions. This creates a new executive challenge.
Success is no longer determined solely by the effectiveness of cybersecurity controls. Instead, it increasingly depends on organizational alignment.
Executives are finding themselves asking questions such as:
- Who owns CRA compliance?
- Who approves risk acceptance decisions?
- Who is responsible for vulnerability disclosures?
- How are supplier obligations managed?
- How are product support commitments documented?
- How is compliance evidence maintained?
- How are decisions communicated across departments?
Organizations that cannot answer these questions often discover that operational silos are one of the largest barriers to compliance. The CRA is forcing organizations to evolve from functional ownership models to shared accountability models.
Why CRA Requires Cross-Functional Collaboration
The CRA regulation spans far more than traditional cybersecurity activities. It requires support from across the entire organization.
Product Management Defines Scope
Product managers understand product portfolios, market commitments, product lifecycles, and customer requirements. Without product management involvement, organizations often struggle with product classification and support planning.
Engineering Owns Technical Implementation
Engineering teams provide visibility into product architectures, software components, security controls, and development processes. Engineering plays a central role in generating technical evidence required for compliance.
Security Provides Risk Management
Cybersecurity teams evaluate threats, vulnerabilities, and security controls. They also perform risk assessments and are responsible for incident response activities. However, they rarely possess all information necessary for compliance decisions.
Legal Interprets Regulatory Obligations
Legal teams help organizations understand regulatory requirements, reporting obligations, liability considerations, and contractual implications.
Procurement and Supplier Management Manage Dependencies
Suppliers increasingly play a critical role in CRA readiness. Therefore, procurement teams must help ensure organizations receive SBOMs, security documentation, vulnerability disclosures, and compliance evidence from suppliers.
Executive Leadership Drives Accountability
Without executive sponsorship, cross-functional initiatives often struggle to gain traction. Leadership alignment is frequently the difference between successful and stalled compliance programs.
Real-World Challenges
Companies who task their cybersecurity team with CRA readiness initiatives often run into challenges. These teams often start by focusing on vulnerability management and secure development practices. They can implement frameworks that address a subset of the CRA requirements. Security teams, however, quickly discover they lack access to product lifecycle information, supplier contracts, support commitments, and regulatory documentation required for achieving full CRA compliance. The lesson is that compliance efforts require broader stakeholder involvement.
Engineering-led compliance efforts also face challenges. Engineering led attempts to classify products for CRA applicability often struggles as different teams apply different assumptions and risk criteria. Creating a consistent and defensible classification process requires that organizations create a cross-functional review board involving engineering, legal, product management, and security.
Many companies also struggle with vulnerability reporting. Identifying affected products requires information from engineering, customer support, product management, legal, and security teams. No single department possessed all required information. This too highlights the need for stronger organizational coordination before a real incident occurred.
Best Practices for Enterprise-Wide CRA Governance
Organizations successfully navigating CRA readiness are implementing several common practices.
Establish a Cross-Functional CRA Steering Committee
Without coordination across teams, CRA programs are at high risk of failure. A cross-functional steering committee can alleviate this issue. This team should include representatives from product management, engineering, cybersecurity, legal, quality, compliance, and procurement. This ensures decisions reflect all relevant perspectives.
The team must also include sufficiently senior executives to enable resource and budget allocation required to drive real change in organizational operations.
Define Clear Roles and Responsibilities
Organizations should establish formal ownership for product classification, risk assessments, vulnerability reporting, documentation management, supplier governance, and customer communications. Failure to define clear responsibilities often leads to compliance gaps.
Create Standardized Workflows
Standardized processes improve consistency and scalability. For CRA compliance, this should include cyber risk review procedures, vulnerability escalation processes, compliance evidence collection, and supplier assessment workflows.
Centralize Compliance Information
Organizations should avoid storing compliance information in disconnected systems. CRA compliance processes require a centralized system to improve visibility, accountability, and audit readiness.
Align Governance with Product Lifecycles
Compliance responsibilities must extend from product conception through end-of-support. This should be reflected during initial planning stages for new products as lifecycle governance is a critical requirement under the CRA.
Common Pitfalls
Organizations repeatedly encounter several avoidable mistakes.
Treating CRA as a Security Project
Many companies initially approach CRA compliance as one-time project. CRA compliance is not a one-time project. It requires continuous management, defined processes, and repeatable workflows throughout the product lifecycle.
Assuming the Security Team can Manage CRA Compliance
Perhaps the most common error is assigning CRA responsibility exclusively to cybersecurity teams. Compliance requires broad organizational participation.
Failing to Establish Executive Sponsorship
Without executive support, cross-functional initiatives often lack authority and resources required to achieve CRA compliance.
Failing to Clearly Define Compliance Ownership
When responsibilities are not clearly defined, critical activities can fall through the cracks. Companies must clearly define responsibility for each CRA compliance activity.
Maintaining Siloed Information
Disconnected documentation systems create inefficiencies and increase audit risk.
Underestimating Supplier Dependencies
Organizations frequently overlook the role suppliers play in supporting compliance obligations.
Action Items for OEMs and Software Vendors
Organizations seeking to strengthen CRA governance should consider the following actions.
Immediate Priorities
- Identify all stakeholders involved in CRA compliance.
- Establish a cross-functional governance team.
- Define roles and responsibilities for compliance activities.
- Review product lifecycle governance processes.
- Assess supplier governance procedures.
- Establish executive level responsibility, including reporting to C-level executive, for compliance programs.
- Conduct cross-functional readiness exercises.
Organizations that address governance challenges early will be significantly better positioned to meet CRA requirements as enforcement deadlines approach.
How OmniTrust Certify Can Help
One of the fundamental challenges with CRA compliance is that the information needed to understand a product, assess its cyber risk, demonstrate conformity, and maintain evidence is often distributed across teams, suppliers, documents, and systems.
OmniTrust Certify provides a shared, living system of record for product cyber risk and regulatory conformity. It brings product management, engineering, cybersecurity, quality, legal, compliance, suppliers, and leadership together around the same product profile, risks, requirements, evidence, and compliance activities.
With OmniTrust Certify, organizations can:
- Create and maintain a living product profile from product documentation and technical evidence
- Create or ingest SBOMs from source code, firmware, binaries, or existing SBOMs
- Identify assets, components, interfaces, data flows, and security controls
- Perform cyber risk assessments and generate threat and mitigation analysis
- Assess products against CRA requirements and other applicable regulations and standards
- Turn identified gaps into assigned remediation activities with owners, due dates, and supporting evidence
- Maintain traceability across product information, risks, controls, regulatory requirements, and evidence
- Generate structured risk, compliance, and conformity records
- Continuously reassess as products, vulnerabilities, evidence, and regulatory requirements change
By creating a common product record and workflow across traditionally disconnected teams, Certify helps organizations move CRA compliance from a collection of periodic, siloed activities to a continuous and collaborative approach to product cybersecurity and regulatory conformity. Watch the video!
Summary
The most important lesson emerging from early CRA implementation efforts is that compliance is not simply about security controls. It is about coordination across the organization.
Companies that succeed will not necessarily be those with the largest security teams or the most advanced technologies. They will be the organizations capable of aligning people, processes, and information across the enterprise to create a culture of continuous cybersecurity accountability.
Under the Cyber Resilience Act, cybersecurity is no longer owned by one department. It is becoming a shared responsibility across the entire organization.
Subscribe to the Blog on our blog homepage for notifications on future blogs in this series which continues with “Blog #8: Your Suppliers May be Your Biggest Compliance Risk.”
