Compliance Engineering under the EU Cyber Resilience Act: Timelines, Obligations, and SBOM-Driven Product Security

Abstract

Background: The EU Cyber Resilience Act (CRA, Regulation (EU) 2024/2847) entered into force on 10 December 2024, and 2025 was its preparation year: the Commission's delegated acts took shape, harmonized-standardization work began, and manufacturers confronted the obligations timetable — vulnerability and incident reporting from 11 September 2026 (24-hour early warning, 72-hour notification), full application including CE-marking consequences on 11 December 2027, and open-source steward duties from the same date. Objective: We translate the CRA's legal obligations into an engineering program: what a manufacturer of products with digital elements must build, in what order, to be compliant by construction rather than by remediation. Methods: Documentary analysis of the CRA's obligations and official Commission guidance; mapping of obligations to security-engineering practices (SSDF, SBOM, SLSA-class process evidence); and construction of an SBOM-driven vulnerability-management pipeline aligned with the Act's reporting duties. Results: The CRA converts product security from a best practice into a lifecycle obligation : secure-by-default configuration, risk assessment, security-update handling across a support period of at least five years, and 24/72-hour reporting of actively exploited vulnerabilities and severe incidents. The SBOM is the load-bearing artifact — it is what makes feed correlation, triage, and notification computable at product scale. The engineering-critical path runs through 2026: reporting obligations arrive a full fifteen months before full application, so the reporting pipeline must exist before the conformity machinery does. Conclusions: Organizations should treat 2025-2026 as the compliance-engineering window: build the SBOM pipeline, stand up the reporting process, and align development practice with the harmonized standards — because the CRA makes security a property of the market, enforced through product-safety law.