EU Cyber Resilience Act · Engineering review

CRA Technical Readiness Assessment for Connected Devices

Our IoT engineers assess your connected products against the CRA’s technical requirements and hand over a gap report, an SBOM baseline and a remediation roadmap — the technical evidence your legal counsel needs.

  • We work with your legal counsel
  • Firmware, cloud and app in scope
Gap report · Product line A Illustrative example
Requirement
StatusSeverity
Update integrityMD5 checksum, firmware fetched over HTTP
Not metHigh
Device credentialsDerived from the serial number
Not metHigh
Vulnerability handlingContact point exists, no disclosure policy
Partly metMedium
Transport encryptionTLS on all cloud channels
Met—
SBOMSupplier SBOM “on request”, none received
Not assessed—
In short

WebbyLab’s CRA Technical Readiness Assessment is an engineering review of connected products against the technical requirements of the EU Cyber Resilience Act (Regulation (EU) 2024/2847). It covers device firmware, update mechanisms, cloud and mobile apps, and the SBOM, and produces the technical evidence your legal counsel uses for the conformity process.

11 September 2026In force now

Manufacturers must report actively exploited vulnerabilities and severe incidents, with an early warning within 24 hours. This also applies to products that are already on the market.

11 December 2027Full requirements

Every unit placed on the EU market from this date must meet the CRA’s essential requirements in full, even if the model has been sold for years.

Source: European Commission

Is this you?

Who It’s For

Manufacturers and brands of connected devices for the EU market — HVAC and heat pumps, industrial equipment, smart home — including brands that sell OEM hardware under their own logo.

Legacy firmware without OTA

Units already in the field don’t have to be reworked. But every unit you sell after 11 December 2027 must meet the requirements in full, even if the model is years old. You need to know what has to change before then.

OEM or white-label hardware

Your supplier’s CRA answers are incomplete or contradict each other. You can’t show compliance your supplier can’t evidence.

A new product for the EU market

Anything placed on the market from 11 December 2027 must comply from day one. You want the security requirements designed in, not patched in before release.

Customers are already asking

A distributor or a key account wants evidence of CRA readiness, and you need a technical answer you can stand behind.

Scope

What the Assessment Covers

Seven technical areas that cover the essential requirements in Annex I of the CRA, plus an eighth for products built on OEM hardware.

Annex I, Part I

Device and firmware

Secure boot, exposed debug ports and interfaces, default and shared credentials, secure-by-default configuration and factory reset.

Annex I, Part I

Updates

OTA mechanism, update signing and integrity checks, rollback protection, and automatic security updates that are on by default and can be switched off by the user.

Annex I, Part I

Connectivity and device identity

Encryption on every channel, MQTT included, per-device credentials, and how devices authenticate to your cloud.

Annex I, Part I

Cloud and mobile app

The CRA covers cloud services and apps only where you develop them, or they are developed under your responsibility, and the product needs them to work. We assess that part — access control, data protection, attack surface — and mark what falls outside.

Annex I, Part I

Data protection and logging

Data minimisation, encryption of stored and transmitted data, logging of security-relevant events, and secure deletion of user data and settings.

Annex I, Part II

SBOM and dependencies

An inventory of components and third-party libraries, known vulnerabilities, and version drift across the fleet.

Annex I, Part II

Vulnerability handling and support

A coordinated vulnerability disclosure policy and a contact point for reports, the process to triage, fix and report vulnerabilities, security updates through the support period, and a declared end-of-support date.

For OEM products

Supplier evidence review

We cross-check supplier questionnaires, specifications and the device’s actual behaviour, and lead the technical dialogue with the supplier’s engineers on your behalf.

How deep we go

Included

  • Review of security-relevant source code
  • Architecture and design review
  • Analysis of firmware images and update packages
  • Review of configuration and technical documentation
  • Checks of actual device behaviour on a test unit

Not included

  • A full penetration test
  • Legal classification and the conformity procedure — that is your counsel’s part

Where deeper testing is worth doing, the roadmap says so.

Deliverables

What You Get

For each product line:

  1. Cybersecurity risk assessment

    The core CRA document: a threat model for your product and a matrix showing which Annex I requirements apply to it and why. Everything else in the report builds on it.

  2. Gap report

    Each applicable requirement marked as met, partly met, not met or not assessed, with severity and the evidence behind it.

  3. SBOM baseline

    A software bill of materials in SPDX or CycloneDX format, ready to maintain release by release.

  4. Architecture notes

    Technical notes on your update architecture and device identity: what works and what to change.

  5. Remediation roadmap

    Prioritised fixes with effort estimates, so you can plan the engineering work.

  6. Technical evidence pack

    The technical material that goes into your product’s technical documentation.

  7. Executive summary

    A short summary for management: where each product stands and what it will take.

For OEM and white-label products, also:

Supplier evidence matrix

Every supplier source checked against every requirement, with gaps and contradictions flagged.

Supplier request pack

The documents to obtain from your supplier — module and firmware versions, update signing and root of trust, secure boot, a sample SBOM, architecture and threat model, vulnerability handling policy, a plan to December 2027 — and the technical commitments for the supply contract: support period, 24-hour notice, fix timelines, an SBOM with every release. The contract terms themselves stay with your legal counsel.

The assessment is not a declaration of conformity or legal advice.

Process

How It Works

  1. 1 Scoping

    Scoping call, NDA and inputs

    We agree which products are in scope, what we can access and what we need from you.

  2. 2 Inventory

    Product inventory and SBOM

    We map product lines, firmware versions, components and dependencies, and build the SBOM baseline.

  3. 3 Analysis

    Firmware, device, cloud and app

    We review each area against the CRA’s technical requirements and record findings with evidence.

  4. 4 Handover

    Report and workshop

    We hand over the report and walk through it with your team and your legal counsel.

Case studies

Proven on Real Connected Products

The same engineering team builds and maintains firmware, OTA and cloud platforms for connected equipment.

SmartHeatSmartHeat

Remote monitoring for heat pump firmware

A heat pump manufacturer’s existing ESP32 firmware connected to a cloud platform for remote control, diagnostics and telemetry, without rebuilding it from scratch.

30%fewer on-site service visits
Read the case
PatonPaton

OTA updates for industrial welding equipment

ESP32 bridge firmware and a mobile app that deliver firmware updates to STM32 controllers in the field, built to withstand electromagnetic interference from welding.

OTAfirmware updates for equipment in the field
Read the case
MyBoxMyBox

Cloud platform for an EV charging fleet

Real-time MQTT connectivity, an OCPP-compatible architecture, a driver app and an operator admin panel, with a full monitoring stack.

OCPPcompatible fleet architecture
Read the case
ISO 9001 ISO 9001 Offices in London and Kyiv
Kostiantyn Oliynyk, Head of IoT at WebbyLab

Your expert

Kostiantyn Oliynyk

Head of IoT, WebbyLab

Kostiantyn was the first member of WebbyLab’s IoT department and grew it into a practice that covers embedded and hardware development alongside cloud and mobile software. His background is in telecommunication systems engineering.

FAQ

Frequently Asked Questions

No. It’s a technical engineering assessment that prepares the evidence for one. The conformity assessment, the EU declaration of conformity and CE marking stay with you and your legal counsel. The assessment is not a declaration of conformity or legal advice.

A list of the products in scope, firmware versions, source code or binaries, available technical documentation, test devices and a technical contact on your side. For OEM hardware, also the CRA answers and specifications you’ve received from the supplier. We send the exact list after the scoping call.

Preferably, yes: source code gives the most complete picture. If you don’t have it, we agree the scope for your case, and the report states clearly what was and wasn’t assessed.

Yes — the scope depends on your case. Depending on what we can access — source code, binaries, OEM documentation or only the device and its cloud connection — we agree the scope at the scoping call, and the report states clearly what was and wasn’t assessed. For OEM products we also review your supplier’s answers and specifications, flag gaps and contradictions, and can lead the technical dialogue with the supplier’s engineers.

Yes, where they fall under the CRA. The regulation covers cloud services and apps only if they are developed by you or under your responsibility and the product needs them to work. We assess that part alongside the firmware, and the report states what is out of scope.

Yes. We cover the engineering side and work alongside your legal counsel or compliance team; we don’t provide legal services.

You get the report, the SBOM and the roadmap, and we walk through them with your team and your counsel. You can then fix the issues in-house, with another partner or with us. No obligation to continue with us.

Get started

Book a 30-min scoping call

Tell us about your products. In 30 minutes we’ll agree the scope, what we need from you and a realistic timeline.








    Delete

    I give consent to the processing of my personal data given in the contact form above as well as receiving commercial and marketing communications under the

    © 2026 WebbyLab LLC. All rights reserved.