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Decoding the EU Cyber Resilience Act: Part 1

Part 1: How EO 14028 and NIST CSF 2.0 Converge on Software Supply-Chain Transparency



1. From Guidelines to Global Mandate

Over the last four years, the world has shifted from voluntary cybersecurity guidance to legally enforceable accountability. SolarWinds, Log4Shell and XZ Utils exposed just how opaque modern software supply chains had become. In response, governments on both sides of the Atlantic codified transparency and secure-by-design principles into policy.

Three frameworks now define that shift:

  • Executive Order 14028 (United States)

  • NIST Cybersecurity Framework 2.0

  • EU Cyber Resilience Act (CRA)


Build Your First CRA-Ready SBOM. Free for 5 repos with Trace-AI (no credit card needed).


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2. The Regulatory Triad — Three Frameworks, One Mission

2.1 EO 14028: Security as Federal Policy

Issued in 2021, EO 14028 mandates secure-development practices and SBOM submission for any software sold to U.S. federal agencies. It requires vendors to:

  • Provide machine-readable SBOMs (SPDX or CycloneDX)

  • Self-attest to secure coding standards aligned with NIST SP 800-218 (SSDF)

  • Maintain a public vulnerability-disclosure policy

While not a direct law for the private sector, its procurement power has forced compliance downstream to critical sectors like defence, finance, and healthcare.


2.2 NIST CSF 2.0: Governance Meets Transparency

Released in 2024, CSF 2.0 introduces a sixth core function, Govern (GV), to ensure executive oversight and third-party accountability.

  • GV.SC (Supply-Chain Risk Management): formalises vendor oversight and software integrity.

  • ID.SC (Identify): continuous catalogue of software and dependencies.

  • DE.CM (Detect): active monitoring of drift and compromise.

CSF 2.0 remains voluntary but is increasingly baked into contractual obligations and insurance assessments.


2.3 EU CRA: From Best Practice to Law

Adopted in 2024 and enforceable from December 2027, the CRA turns voluntary principles into binding obligations for any product with digital elements sold in the EU.

  • Covers software, firmware and connected hardware.

  • Requires 24-hour vulnerability reporting to ENISA.

  • Demands “secure-by-design” development and lifecycle support.

  • Penalties reach €15 million or 2.5% of global turnover, whichever is higher.


3. Where They Intersect

Control Area

EO 14028 (U.S.)

NIST CSF 2.0 (U.S.)

EU CRA (Europe)

SBOM Transparency

Mandatory for federal vendors

Recommended for all organisations

Mandatory for all digital products

Secure Development

Self-attestation under SSDF

Strongly advised within PR.IP

Enforced secure-by-design principles

Vulnerability Disclosure

Required to CISA

Encouraged in GV.SC and RS.CO

Required to ENISA within 24 hours

Enforcement Mechanism

Procurement policy leverage

Voluntary adoption

Legal and financial penalties

4. CRA Timeline and Scope


EU CRA Timeline
EU CRA Timeline

  • 2022: Proposal introduced by European Commission.

  • 2024: Formal adoption as Regulation (EU) 2024/2847.

  • Sept 2026: Vulnerability-reporting obligations begin.

  • Dec 2027: Full compliance required for market access and CE marking.

Its scope extends to “all integrated components”, covering firmware modules, embedded systems and connected devices.


5. Four Pillars CISOs Should Prioritise

  1. SBOM Transparency: Produce and maintain machine-readable SBOMs throughout the lifecycle (SPDX/CycloneDX).

  2. Secure-by-Design Development: Embed security from requirements through deployment; support patchability and updates.

  3. Vulnerability Handling: Implement 24-hour reporting pipelines to ENISA and clear user notification processes.

  4. Conformity Assessment & CE Mark: Document evidence of risk management and undergo third-party assessment for high-risk products


Download Your Free CRA Compliance Checklist (PDF) to keep your team aligned before 2027.


6. Why CRA Matters Beyond Europe

Even organisations with no EU entity will feel its impact. European buyers already request CRA-aligned attestations in procurement cycles. Similar principles are also outlined in UK NCSC guidance and U.S. federal contracts. For global SaaS providers, adhering to CRA standards now means fewer custom compliance clauses later and a simpler path to cross-border sales.


7. How Zerberus Bridges the Gap

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  • Trace-AI: metadata-driven risk scoring that goes beyond CVE lists to detect typosquatting, abandonment and supply-chain anomalies.

  • ZSBOM: lightweight & opensource CLI for (metadata-driven) SBOM generation — complementary to CRA’s machine-readable requirement.

  • Compl-AI™: automated evidence collection and attestation engine for secure-development proof aligned with ISO 27001 and CSF 2.0.

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The Zerberus platform turns compliance busy-work into actionable risk insights, reducing manual audit time by up to 60%.


8. Key Takeaways

  • The CRA elevates cyber resilience from principle to law.

  • SBOMs are the new passport for software trade.

  • Early alignment with EO 14028 and NIST CSF 2.0 simplifies CRA readiness.

Automating evidence collection turns compliance into a competitive advantage.


10. FAQ

  1. What is the EU Cyber Resilience Act? 

    1. A binding EU regulation requiring cybersecurity-by-design for software, hardware and connected devices sold within the European market.

  2. When does CRA enforcement begin? 

    1. Full compliance is mandatory from December 2027, with vulnerability reporting obligations beginning in September 2026.

  3. Who must comply? 

    1. Manufacturers, importers and distributors of products with digital elements that enter the EU market, including SaaS and firmware vendors.

  4. How do SBOMs fit into CRA requirements? 

    1. The CRA mandates that an up-to-date, machine-readable SBOM is a core part of your technical documentation, ready for audit by market authorities at any time.

  5. How can Zerberus help with CRA compliance? 

    1. Trace-AI and Compl-AI™ automate SBOM generation, risk scoring and attestation evidence, aligning with CRA, EO 14028 and NIST CSF 2.0 in one platform.


11. References & Further Reading


9. Next Steps — Future-Proof Your Supply Chain

CRA enforcement arrives in 2027, but procurement teams are asking for proof today.

Start small, demonstrate traceability and build trust incrementally.

Get Started: Generate your first CRA-ready SBOM with Trace-AI — Free for 5 repositories (no credit card needed).

Explore next: Part II – Open Source and Firmware Under the CRA




 
 
 

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