Cyber Resilience Act Compliance for Machinery Manufacturers
Your machine has digital elements. Your CE marking now requires cybersecurity evidence. CRA Evidence helps machine builders comply with both the Cyber Resilience Act and the EU Machinery Regulation, from a single platform.
The Dual-Compliance Reality
From 20 January 2027, the EU Machinery Regulation (EU) 2023/1230 requires cybersecurity evidence in your technical file (Annex III §1.1.9 "protection against corruption"). From 11 December 2027, the CRA mandates full lifecycle product security. Both apply to machines with PLCs, HMIs, embedded controllers, or network connectivity.
CRA Recital 53 is explicit: products covered by other EU regulations with cybersecurity requirements must also comply with the CRA. CRA compliance evidence can satisfy those requirements, if structured correctly.
How CRA Evidence Helps Machine Builders
| Your Compliance Need | How CRA Evidence Helps | Regulatory Basis |
|---|---|---|
| Track software in your machines | SBOM + HBOM management | CRA Annex I + MR technical file |
| Analyze embedded firmware | Upload firmware SBOM and scan for CVEs | CRA vulnerability management + MR §1.1.9 |
| Assess cybersecurity risks | STRIDE risk assessment with hardware assets | CRA Art. 13(2) + MR §1.1.9 |
| Report vulnerabilities to ENISA | 24h/72h/14d notification workflow | CRA Art. 14 (starts Sep 2026) |
| Generate CE marking evidence | EU DoC generator + technical file export | CRA Art. 22-23 + MR conformity |
| Provide product transparency | Digital Product Passport with QR codes | CRA + Ecodesign |
| Manage supply chain components | Importer/distributor verification | CRA Art. 19-20 |
Products Covered
CNC machines, cobots, packaging machinery, safety PLCs, industrial robots, HMIs, variable frequency drives with network interfaces, AGVs/AMRs, injection moulding machines, woodworking machines with digital controls, connected machinery with remote monitoring or telemetry. Essentially any machine with software or network connectivity.
Key Deadlines
11 September 2026: ENISA vulnerability reporting begins. Manufacturers of machinery with digital elements must report actively exploited vulnerabilities within 24 hours.
20 January 2027: EU Machinery Regulation full application. Cybersecurity evidence required in technical files under Annex III §1.1.9.
11 December 2027: CRA full enforcement. All products with digital elements must comply with essential cybersecurity requirements.
The Emerging Standard: prEN 50742
prEN 50742 is the draft European standard for protection against corruption in machinery, providing technical specifications for Machinery Regulation §1.1.9. It defines two compliance paths: a standalone approach, and integration with IEC 62443 for manufacturers already working within that industrial cybersecurity framework. Once published as a harmonised standard, conformity with prEN 50742 will create a presumption of conformity with the Machinery Regulation cybersecurity requirements. Publication is expected late 2026.
What We Cover and What We Don't
CRA Evidence covers the cybersecurity compliance aspects of the Machinery Regulation: SBOMs, HBOMs, vulnerability tracking, risk assessment, ENISA reporting, CE marking documentation, and Digital Product Passports.
For mechanical safety, electrical safety, noise, vibrations, and other non-cyber requirements under the Machinery Regulation, consult your existing compliance process. CRA Evidence addresses the cybersecurity intersection, not the full Machinery Regulation scope.
Official Sources
- EU Machinery Regulation (EU) 2023/1230, EUR-Lex. Official Journal, adopted 14 June 2023, applies from 20 January 2027
- Machinery, European Commission. DG GROW guidance and implementation resources
- Cyber Resilience Act (EU) 2024/2847, EUR-Lex. Full enforcement from 11 December 2027
Ready to Start Your CRA Compliance Journey?
September 2026 is closer than it looks. Start documenting your machinery's cybersecurity evidence today.