Navigating the Cyber Resilience Act with Agility
Urs Fässler
The CRA mandates stringent cybersecurity requirements for digital products, ranging from vulnerability management and regular updates to security-by-design principles. Manufacturers are tasked with ensuring that their products remain secure throughout their lifecycle, providing ongoing updates, and managing vulnerabilities proactively. The agile development approach, characterized by iterative cycles, cross-functional collaboration, and continuous integration, is ideally suited to meet these requirements. Agile practices enable teams to quickly adapt to new regulatory demands, implement security measures efficiently, and deliver high-quality, secure software. This article outlines the key aspects of agile development that align with CRA compliance and demonstrates how organizations can leverage agility to meet their obligations under the CRA. For more information on how to transition your team to agile practices and ensure compliance with the CRA, feel free to reach out to me at urs.fassler@iqilio.ch.
Understanding the Cyber Resilience Act
The CRA is a landmark regulation designed to ensure that digital products are secure by design, undergo continuous vulnerability management, and remain updated throughout their lifecycle. Key elements of the CRA include:
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Risk-based product classification: Products are categorized based on their risk level, which determines the necessary cybersecurity measures.
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Security-by-design principles: Security must be considered from the very beginning of product development.
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Vulnerability scanning and management: Continuous monitoring for vulnerabilities and remediation efforts are required.
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Security Patches: Manufacturers must provide security updates for the support period, typically five years, or the product’s expected use time if shorter.
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Penalties for non-compliance: Non-compliance can result in fines up to €15 million or 2.5% of global revenue.
Manufacturers are expected to proactively manage cybersecurity, implement secure-by-default configurations, and minimize attack surfaces. Compliance requires ongoing security updates, clear documentation, and a timely response to security incidents.
Key Compliance Requirements
For Vulnerability Handling Requirements, manufacturers of products with digital elements shall:
- Vulnerability Identification and Management
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Manufacturers must identify and document vulnerabilities in their products by creating a software bill of materials. They must address these vulnerabilities promptly with security updates, ideally separate from functionality updates. Regular security tests and reviews are required to maintain the product’s resilience against threats.
- Security Updates and Disclosure
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Manufacturers should ensure secure and timely distribution of security updates, including automatic updates when feasible. After releasing a security update, they must share information on the vulnerability, its impact, and how users can resolve it. Public disclosure may be delayed if needed for security reasons. Security updates must be free and include advisory messages to guide users.
- Vulnerability Reporting and Coordination
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Manufacturers must enforce a coordinated vulnerability disclosure policy to ensure that all stakeholders, including users, are informed about security issues in a structured and consistent manner. They should also take steps to facilitate the reporting of vulnerabilities by providing users with a clear point of contact to report any discovered issues. This includes vulnerabilities found in third-party components contained within the product.
The technical implementation to fulfill the Cyber Resilience Act (CRA) can vary significantly depending on the specific cybersecurity risk assessment for each product. These implementations are driven by the nature of the product, its environment, and the identified risks. The key requirements that manufacturers must consider to achieve compliance are:
- Security Management
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Products must be sold without known exploitable vulnerabilities. Security updates should be provided, including automatic updates enabled by default, with an easy opt-out and the option to delay installation. Products must also have secure default settings unless otherwise agreed for custom solutions, and should include an option to reset to original settings. Additionally, products should be designed to minimize attack surfaces, particularly through external interfaces, reducing the risk of exploitation.
- Data and Privacy Protection
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Products must protect the confidentiality of stored and transmitted data, using encryption and other modern security methods to safeguard information. Only necessary data should be processed, adhering to data minimization principles. Users must have the ability to securely and permanently delete all data and settings, and data transfers to other systems should be done securely. Additionally, the integrity of data, commands, and configurations must be protected against unauthorized modification, with mechanisms to detect and report any corruptions.
- Access Control and Monitoring
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Products must ensure protection from unauthorized access through appropriate control mechanisms, such as authentication and identity or access management systems, and report any unauthorized access attempts. They should also record and monitor internal activity, including access to or modification of data, services, or functions, with an opt-out option for users who prefer not to be monitored.
- Resilience and Incident Mitigation
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Products must protect the availability of essential and basic functions, even after an incident, by implementing resilience measures and defenses against denial-of-service attacks. They should also minimize any negative impact on the availability of services provided by other connected devices or networks. Additionally, products must be designed and developed with mechanisms that reduce the impact of an incident, using appropriate mitigation techniques to limit exploitation and damage.
Agile Software Development
Agile practices in software development focus on discovering requirements and improving solutions through the collaboration of self-organizing, cross-functional teams. These teams prioritize the needs of their customers or end users. To ensure the software delivers value, it is released early and continuously, allowing customers to confirm the development is progressing in the right direction. Simultaneously, the development team verifies their understanding of the customer’s needs.
This iterative process also allows for flexibility. When either the customer or the development team identifies that the requirements are not aligned with the customer’s needs, adjustments can be made. This flexibility is crucial because software development is often about exploring new possibilities, not following a rigid production line. Agile environments embrace this reality.
Iteration and incremental progress are the core of agility. By breaking work into manageable units, teams can gather regular feedback from customers. Each iteration, typically brief and time-boxed, is reviewed with the customer, after which the next steps are planned. This feedback loop fosters a dynamic atmosphere where ideas can be tested and objectives fine-tuned.
Ultimately, agility ensures that the product remains valuable to the customer by confirming the right direction and delivering usable software. The team reflects at regular intervals, usually at the end of an iteration, on how to become more effective. Topics are not predefined but can include reducing unnecessary work, increasing automation, improving collaboration with customers, enhancing technical excellence, resolving interpersonal conflicts, and more.
Agile to Fulfill CRA Requirements
An agile organization is well-prepared to achieve compliance with the CRA. The agile process is inherently designed to adapt quickly to new circumstances, such as emerging business opportunities or newly imposed regulations. Moreover, many agile practices already align with the core components required for CRA compliance:
- Ownership
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In an agile environment, a single team is fully responsible for the development and lifecycle of the product. This responsibility empowers the team to make decisions, take control of the process, and deliver a high-quality, end-to-end solution. The sense of ownership extends beyond just development; the team is accountable for maintenance, updates, and long-term success. This ownership fosters better collaboration, not only within the team but also with external stakeholders, as the team is invested in meeting both business goals and customer expectations.
For CRA compliance, this level of ownership ensures that the team is committed to maintaining the product’s security throughout its lifecycle, addressing vulnerabilities proactively, and keeping the product compliant with evolving regulations. By taking responsibility for security updates and continuous improvement, the team ensures that the product remains secure and resilient, fully aligning with the CRA’s requirements.
- Collaboration
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Agile teams are inherently cross-functional and interdisciplinary, with members who understand each other’s strengths and work closely across different disciplines to create high-quality products. This collaborative environment enables developers to gain a deeper understanding of both the business and customer needs through continuous interaction, allowing teams to focus on solving the real problem. By regularly discussing and addressing issues collectively, agile teams enhance their problem-solving skills and build stronger, more effective solutions.
When it comes to CRA compliance, this collaborative mindset is especially valuable, as it allows teams to involve security specialists alongside development and operations early in the process. By engaging all relevant stakeholders, security considerations are integrated from the very beginning, ensuring that products are secure by design and meet CRA’s requirements for security throughout the lifecycle.
- Automation
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Agile teams automate repetitive tasks such as testing, code analysis, and security checks to increase efficiency and reduce the possibility of human error. This automation is built into the development pipeline, enabling teams to focus on higher-level problem-solving.
For CRA compliance, automation plays a key role in maintaining security standards. Automated security scans and vulnerability assessments can be integrated into the pipeline, allowing agile teams to detect issues early and implement fixes faster. This helps ensure the product adheres to CRA’s security-by-design and continuous vulnerability management principles.
- Continuous Integration
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Agile teams implement Continuous Integration (CI), where developers frequently merge code changes into a shared repository. Each change is automatically tested to ensure it integrates smoothly with the existing codebase.
CI supports CRA compliance by allowing teams to rapidly deploy security fixes and patches as soon as vulnerabilities are discovered. Since each change is verified through automated tests, security updates can be confidently pushed to production, ensuring timely responses to threats.
- Continuous Delivery
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In agile environments, Continuous Delivery (CD) automates the release of software updates, ensuring that new versions are deployed frequently and with minimal effort. This enables teams to release software as soon as it passes the necessary tests.
For CRA compliance, CD ensures that security updates and patches are delivered quickly, meeting the requirement for timely updates. Automation reduces the risk of delays and human error in releasing critical security fixes, ensuring products stay compliant and secure over their entire lifecycle.
- Testing
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Automated testing is a cornerstone of agile development, with unit tests, integration tests, and regression tests forming part of daily workflows. This ensures new features and changes don’t break existing functionality and are delivered quickly and reliably.
This automated approach helps with CRA compliance by allowing security patches and updates to be tested and integrated seamlessly. With automated tests in place, agile teams can ensure that new security features don’t introduce regressions or new vulnerabilities, keeping the product stable and secure.
- Quality
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By adopting practices like code reviews, pair programming, and writing clean, maintainable code, teams can ensure high-quality software. This minimizes defects and makes it easier to introduce changes and security improvements over time.
For CRA compliance, high-quality code is essential as it reduces the likelihood of security vulnerabilities. Since fewer bugs and issues arise, teams can focus on addressing known security threats quickly, ensuring that the product meets the CRA’s strict requirements for security throughout its lifecycle.
- Documentation
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In agile environments, documentation is updated continuously as part of the development process. Agile teams ensure that technical, process, and user documentation reflects the current state of the software, making it easier to maintain and distribute.
For CRA compliance, up-to-date documentation is essential for demonstrating adherence to security protocols. Agile teams’ approach to continuous documentation ensures that the necessary technical details, configurations, and user-facing guidance are always current and aligned with regulatory requirements.
Conclusion
The Cyber Resilience Act introduces stringent requirements for product security, but agile development practices offer a clear path to compliance. Through ownership, collaboration, automation, CI/CD, agile teams can ensure their products meet CRA standards while remaining flexible and responsive to evolving security needs. As regulatory environments become more complex, adopting agile methods will not only ensure compliance but also foster innovation and resilience in product development.

Ready to navigate the Cyber Resilience Act? As a technical agile coach, I empower your team to steer through the uncharted challenges of CRA compliance.
Contact me at urs.fassler@iqilio.ch to discuss how we can ensure your products are secure and compliant.