What Companies Are Really Learning About the Cyber Resilience Act

Welcome to OmniTrust’s CRA Lessons Learned Series.

When the European Union’s Cyber Resilience Act (CRA) was first introduced, most organizations approached it like any other new regulation. The initial questions were predictable: Does it apply to us? Which products are in scope? What documentation will be required? How much work will compliance take?

As companies have moved from planning to implementation, a different reality has emerged.

The organizations making the most progress are no longer focused on understanding the regulation itself. They are focused on understanding how to operationalize it across entire product portfolios, engineering organizations, supply chains, and support lifecycles.

That’s where things get interesting.

Over the past year, OmniTrust has had the opportunity to work with manufacturers, software vendors, industrial companies, medical device firms, and connected-product providers that are actively preparing for CRA compliance. We’ve also spent countless hours speaking with industry experts, product security leaders, compliance professionals, engineering teams, and executives trying to answer the same fundamental question:

How do we turn CRA compliance from a regulatory requirement into an operational reality?

What we’ve discovered is that the biggest challenges are rarely the ones companies expected.

Organizations often begin by focusing on cybersecurity controls, secure development practices, or technical documentation. Those are certainly important. But many teams quickly discover that the harder challenges involve governance, accountability, evidence management, software supply-chain visibility, vulnerability response processes, support commitments, and cross-functional coordination.

In other words, building a secure product is important—but it is not enough.

The CRA is proving to be as much an operational challenge as it is a cybersecurity challenge.

Why We Created This Series

This blog marks the beginning of our CRA Lessons Learned series. The goal is simple: share practical observations, implementation lessons, and emerging best practices from organizations actively working through CRA readiness.

Rather than rehashing regulatory language or summarizing legislation, we want to focus on what companies are actually experiencing as they move from theory to execution.

Across industries, we’re seeing many of the same patterns emerge.

Product inventories are often incomplete. Software dependencies are not always well understood. Documentation is frequently scattered across multiple systems. Ownership of compliance activities can be unclear. Evidence collection becomes difficult to sustain over long product lifecycles. Teams discover that existing security programs, while valuable, do not automatically satisfy regulatory expectations.

These are not unusual situations. In fact, they are becoming remarkably common.

The good news is that organizations are also discovering practical ways to address them.

What Senior Leaders Are Learning

One of the most important lessons emerging from early implementation efforts is that CRA compliance cannot be delegated to a single department.

Security teams cannot solve it alone.

Engineering teams cannot solve it alone.

Legal teams cannot solve it alone.

The organizations making the fastest progress are treating CRA as a business transformation initiative rather than a standalone compliance project.

That means executive sponsorship, cross-functional governance, clearly defined accountability, and repeatable processes become just as important as technical controls.

The conversation quickly expands beyond cybersecurity and into product management, quality, operations, customer support, procurement, and supplier management.

The result is a shift in organizational thinking. Successful teams stop asking, “How do we complete a CRA assessment?” and start asking, “How do we continuously demonstrate compliance throughout the product lifecycle?”

Common Mistakes We Continue to See

Although every organization’s journey is different, several recurring themes appear again and again.

Some companies treat CRA as a legal exercise and wait for additional guidance before taking action. Others assume existing certifications or mature security programs will automatically satisfy CRA requirements. Many organizations rely heavily on spreadsheets and disconnected documentation repositories to manage evidence, only to discover that maintaining compliance over time becomes increasingly difficult.

Perhaps the most common misconception is viewing CRA as a one-time project.

The reality is that many of the regulation’s most significant obligations begin after a product reaches the market. Vulnerability management, security updates, incident reporting, software component governance, support commitments, and documentation maintenance all continue throughout the product lifecycle.

Compliance is not a finish line. It becomes an ongoing discipline.

Where Companies Should Start

For organizations just beginning their CRA journey, the first steps are often less complicated than they appear.

Start by understanding your product portfolio. Establish clear ownership. Classify products appropriately. Inventory software components and dependencies. Define vulnerability response procedures. Identify where evidence is created and where it is stored.

Most importantly, begin thinking about how these activities will be maintained over time.

The companies that are furthest ahead are not necessarily the ones with the largest security budgets. They are often the ones that have established repeatable governance processes and created a reliable system of record for managing product cybersecurity information throughout the lifecycle.

What We’ll Cover Next

In future articles, we’ll explore some of the most important lessons emerging from early implementation efforts.

We’ll examine why product classification is becoming one of the first major hurdles organizations encounter. We’ll look at the growing importance of software supply-chain governance and open-source software visibility. We’ll discuss how CRA is reshaping supplier relationships, why post-release obligations are proving more demanding than many expected, and why mature security programs do not automatically translate into regulatory readiness.

Most importantly, we’ll focus on practical lessons that product managers, engineering leaders, CISOs, compliance professionals, and executive teams can apply immediately.

The CRA is still evolving, but one thing is already clear: organizations that begin building operational capabilities today will be in a far stronger position than those waiting for perfect clarity tomorrow.

A Helping Hand Along the Way

One theme continues to surface in nearly every CRA discussion we have with customers: most teams can create the first assessment. The hard part is keeping it current.

As products evolve, software changes, vulnerabilities emerge, suppliers shift, and regulations mature, organizations need a way to maintain a living record of product cyber risk rather than relying on static documents and disconnected spreadsheets.

That’s why OmniTrust created Certify.  Certify helps organizations transform compliance from a point-in-time assessment into a continuous lifecycle process. As a system of record for product cyber risk, Certify enables teams to manage assessments, controls, evidence, SBOMs, vulnerabilities, and regulatory obligations in a single environment while maintaining the traceability and accountability required to support CRA readiness over time.  Because cyber risk for connected products is not a one-time project.  It’s a lifecycle process.

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