This blog is the sixth 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 It’s Critical to Act Now, Not Wait

Since the European Union’s Cyber Resilience Act (CRA) was adopted, one question has surfaced repeatedly in executive meetings, compliance reviews, and cybersecurity planning discussions:

“Should we wait until the standards are finalized before making major investments?”

At first glance, the question appears reasonable.

The CRA introduces significant new obligations for manufacturers and software vendors. As a result, CRA compliance programs are a major investment. Starting now, while harmonized standards continue to evolve creates risk. Waiting for clarity on the standards, rather than trying to hit a moving target, seems prudent. After all, industry guidance is still being refined. Conformity assessment approaches are developing. Regulatory interpretations will undoubtedly mature over time.

Faced with uncertainty, many organizations are tempted to delay action until requirements are clearly understood. With the timeline for compliance shrinking, this is not a viable approach. Especially as final fully-harmonized standards may not be released until late 2027.

Waiting for perfect clarity is not a strategy. It is a risk.

Despite the fact that standards are not fully finalized, there is some good news. Much of the heavy lifting associated with CRA compliance is not impacted by regulatory ambiguity. Some of the critical tasks that must be performed can start now. These include:

  • Creating product inventories
  • Creating software supply chains visibility programs
  • Defining vulnerability management programs
  • Creating compliance evidence and artifacts
  • Establishing supplier relationships oversight
  • Establishing cross-functional accountability

Regardless of when standards are finalized, these foundational activities remain essential.

Companies cannot wait for every unanswered question to be resolved and still hope to meet CRA timelines. It is critical to start building the operational capabilities that will be necessary regardless of how specific requirements ultimately evolve.

Executive Insights

Many executives understandably seek certainty before making significant investments. Historically, organizations often waited for final regulations, implementation guidance, or industry consensus before launching major compliance initiatives.

This is simply not possible with the CRA for two reasons. The first reason is that implementing a CRA compliance is a major initiative, and the time required for organizations to implement CRA compliance programs extends past the timeline for regulatory clarification. The second reason is that the CRA vulnerability and incident reporting requirements begins on September 11 of 2026, and full regulatory clarification will likely be published in late 2027.

Building product inventories, implementing governance frameworks, establishing software supply chain visibility, improving supplier oversight, and creating lifecycle compliance processes can require months or even years. Organizations that postpone these efforts until every detail of the standard is finalized will almost certainly have insufficient time to implement the operational changes required.

More importantly, many CRA readiness activities are largely independent of unresolved regulatory details. Regardless of how harmonized standards evolve, organizations will still need:

  • Product visibility
  • Security governance
  • Vulnerability management
  • Evidence management
  • Supplier accountability
  • Lifecycle support processes
  • Cross-functional coordination

These capabilities are becoming foundational business requirements. As a result, forward-looking executives are shifting the conversation from:

“What don’t we know yet?”

to

“What can we confidently start doing today?”

That shift separates organizations making steady progress towards CRA compliance from those trapped in analysis paralysis.

Why Waiting Creates More Risk Than Action

Several factors make waiting particularly dangerous under the CRA.

Organizational Change Takes Time

Implementing new technologies is often easier than changing organizational behavior. Establishing governance structures, assigning ownership, creating workflows, and aligning departments can require significant time and effort. Organizations frequently underestimate the time required to make these changes. A delayed start can easily result in missing CRA compliance deadlines.

Compliance Is Not a Technology Project

Many organizations assume compliance can be achieved quickly once standards are finalized. While this may have been true with other, less comprehensive standards, it is not true with the CRA.

CRA readiness often requires operational transformation across the company and requires involvement from engineering, security, product management, legal, quality, procurement, and executive leadership

Building the capabilities required for CRA compliance simply cannot be accomplished overnight.

Product Portfolios Are More Complex Than Expected

Organizations routinely discover that inventorying products, classifying offerings, and identifying software dependencies requires significantly more effort than anticipated. In addition, they often discover that the number of supported products and product versions is much higher than initially expected.

Waiting reduces the time available for CRA preparation and any required engineering updates.

Regulators Rarely Reward Inaction

Regulatory expectations often evolve, but organizations are typically expected to demonstrate reasonable efforts toward compliance readiness. Documented progress is more defensible than delayed action.

Real-World Examples

Many companies have postponed major CRA initiatives while waiting for additional guidance regarding standards and conformity assessment expectations.  When they finally launched their CRA readiness program they often discovered they lacked complete product inventories, software visibility, supplier assessments, and governance processes.

As a result of delays in starting, these organizations face compressed timelines and significantly higher implementation costs. They also run the risk that remediation efforts will extend well beyond CRA enforcement deadlines. The problem is not regulatory uncertainty; it is a problem of delayed preparation.

In other cases, vendors decided to begin building product inventories, SBOM management processes, and compliance governance structures despite uncertainty regarding future standards. As guidance evolves, the companies can adjust their implementation approach without needing to rebuild foundational processes. Early investment created flexibility rather than waste.

Best Practices for Managing Regulatory Uncertainty

Organizations successfully navigating CRA readiness are following several common principles.

Focus on Capabilities, Not Interpretations

Rather than debating every regulatory detail, organizations should concentrate on capabilities that will remain valuable regardless of future guidance. This includes implementing processes to manage product inventories, SBOM generation and management, vulnerability response, evidence collection, and supplier governance.

Adopt a Risk-Based Approach

Not every decision requires perfect certainty. Organizations should document assumptions, evaluate risks, and proceed using reasonable interpretations.

Establish Governance Early

Governance structures often require significant organizational alignment. Creating accountability frameworks now provides long-term benefits.

Document Decisions and Assumptions

Organizations should record regulatory interpretations, any assumptions made, risk assessments, and decision rationales.  Documentation creates defensibility in case of audits and makes adaptation easier as requirements evolve.

Design for Adaptability

Compliance programs should be flexible enough to accommodate future guidance without requiring complete redesign.

Common Pitfalls

Several mistakes frequently emerge among organizations delaying CRA readiness efforts.

Waiting for All Details of the Standard to Be Finalized

Perfect clarity rarely arrives all at once, and organizations that wait for complete certainty will fall behind.

Confusing Uncertainty with Inaction

Regulatory ambiguity does not eliminate the need for preparation. Many readiness activities can begin immediately.

Treating Compliance as a Future Problem

Organizations frequently underestimate the scale of organizational change required and think they can defer compliance programs until closer to enforcement deadlines.

Failing to Engage Suppliers Early

Supplier readiness often develops more slowly than expected. Early engagement creates valuable lead time.

Ignoring Governance Until Later

Governance frameworks become increasingly difficult to implement under compressed timelines.

Action Items for OEMs and Software Vendors

Organizations seeking to accelerate CRA readiness should consider the following actions.

Immediate Priorities

  1. Build a comprehensive product inventory.
  2. Assess current cybersecurity governance capabilities.
  3. Review software supply chain visibility.
  4. Evaluate SBOM management practices.
  5. Conduct a CRA gap assessment.
  6. Identify critical suppliers and dependencies.
  7. Establish cross-functional governance teams.
  8. Document key assumptions and compliance decisions.

Organizations that begin today will have significantly more flexibility as standards and guidance continue to evolve.

How OmniTrust Certify Can Help

Balancing immediate action with ongoing regulatory evolution is a challenge.  Many organizations struggle to determine how to move forward while requirements continue to mature.

While OmniTrust Certify cannot help in deciding when to start CRA compliance programs, it is a valuable tool to assist with managing compliance requirements once organization do get started.

Certify provides a living system of record for product cyber risk and regulatory conformity, helping manufacturers and software vendors establish CRA readiness and maintain it as products, vulnerabilities, evidence, and regulatory requirements evolve.

Rather than treating CRA compliance as a one-time assessment, Certify brings product intelligence, cyber risk, regulatory obligations, evidence, and lifecycle decisions into one collaborative platform.

With OmniTrust Certify, organizations can:

  • Build a living Product/System Profile from technical documentation, architectures, software, firmware, and SBOMs
  • Generate baseline Cyber Risk Assessments (TARAs)
  • Apply the EU Cyber Resilience Act regulatory lens to identify obligations and compliance gaps
  • Map risks, controls, remediation, and evidence
  • Use Human-in-the-Loop validation and approvals across engineering, security, quality, legal, and compliance
  • Reassess when products, architectures, SBOMs, vulnerabilities, incidents, or regulations change
  • Maintain a persistent history of risk, regulatory decisions, evidence, and lifecycle changes
  • Generate audit-ready assessments, reports, and regulatory evidence packs

Most teams can create the first assessment. The hard part is keeping it current.

Certify turns CRA readiness from a point-in-time exercise into continuous cyber risk and regulatory lifecycle governance—helping organizations assess, govern, reassess, act, and prove their cybersecurity posture throughout the product lifecycle.

And when risks require technical controls, Certify connects governance to the broader OmniTrust Trust Lifecycle Management platform, creating a path from identifying risk to implementing and enforcing the controls needed to maintain trust.

Summary

The organizations that are best positioned to meet CRA compliance deadlines are not the ones that wait for perfect clarity. They are the organizations that starting early in building strong foundations, establishing effective governance, documented their decisions, and continuously improved as new guidance emerged.

Under the Cyber Resilience Act, progress is a strategy. Waiting is not.

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