EU Cyber Resilience Act (CRA) Compliance Guide: Part II

How to Secure Open Source, Firmware and SBOM Workflows

1. Introduction – From Community Code to Compliance by Design

In Part I, we unpacked how EO 14028, NIST CSF 2.0, and the EU Cyber Resilience Act (CRA) align to make software supply-chain transparency mandatory. Now, Part II moves from theory to action - focusing on open-source software, firmware, and SBOM workflows that form the heart of modern product security.

The CRA transforms what used to be voluntary hygiene into a legal baseline. Every organisation that builds, integrates, or monetises digital products must prove that open-source and firmware components are secure, traceable, and continuously maintained. This guide breaks down how to adapt your processes, automate compliance, and meet CRA obligations before enforcement in December 2027.

2. CRA’s Impact on Open Source Security

The CRA introduces the role of Open-Source Software Steward, signalling a shift in responsibility for community-driven code. For the first time, EU law clarifies that anyone monetising or distributing open-source components inherits the duty to maintain security transparency.

Community projects (non-commercial) remain out of scope but benefit indirectly from improved downstream scrutiny.
Commercial adopters become accountable for documenting vulnerabilities, producing SBOMs, and validating updates.
Shared responsibility replaces the old assumption that “someone upstream will fix it.”

This codifies a culture of stewardship. As Red Hat’s security team notes, the CRA is not a burden on maintainers; it’s a catalyst for collaboration between enterprises and the open-source communities they rely on.

3. Firmware and Hardware – Closing the Hidden Risk Layer

The CRA extends compliance far beneath the application layer. By explicitly including “all integrated components”, it pulls firmware and hardware into scope. That means BIOS, embedded controllers, FPGAs, and chip-level code must all meet secure-by-design expectations.

Manufacturers and integrators must:

Maintain inventories of firmware binaries and vulnerabilities.
Disclose actively exploited flaws to ENISA within 24 hours.
Verify that third-party silicon and driver vendors release timely patches.
Prove due diligence for every integrated digital element.

This bridges the gap between IT and OT security - demanding continuous visibility from source code to circuit board.

4. The SBOM Imperative – Making Transparency Operational

Under Article 10 of the CRA, Software Bills of Materials (SBOMs) are mandatory for any product with digital elements. They must:

Cover all top-level and transitive dependencies, including firmware.
Be produced in SPDX or CycloneDX machine-readable formats.
Stay up to date through the product’s lifecycle.
Be accessible to market authorities and auditors.

Function	CRA Requirement	Example Automation Alignment
SBOM Generation	Article 10(2)	Trace-AI / ZSBOM
Vulnerability Disclosure	Article 11	Compl-AI™ / Policy Engine
Continuous Monitoring	Annex I	Trace-AI Predictive Scoring

Anchore, Snyk, and Eclypsium all emphasise visibility as the foundation of compliance. Zerberus enhances this by merging SBOM data with real-time metadata analytics — surfacing typosquatting, package abandonment, and other hidden risks missed by conventional scanners.

5. Secure-by-Design – Embedding Compliance in Your Workflow

CRA’s Annex I mandates security by design and by default. For CISOs and DevSecOps leaders, this means automating security across every build stage, not auditing after release.

Practical actions include:

Automate SBOM creation and vulnerability scanning within CI/CD.
Enforce CRA-aligned policies via OPA or equivalent gatekeeping tools.
Embed patch validation and secure update delivery.
Log and evidence remediation for conformity audits.

Zerberus Implementation Example:

Trace-AI: Pre-deployment risk scoring and dependency anomaly detection.
ZSBOM: Metadata-only SBOM generation with zero source exposure.
Compl-AI™: Attestation evidence engine providing audit-ready documentation mapped to CRA Annex I controls.

6. Six Steps to CRA Readiness

Identify & Classify: Map all CRA-in-scope software, firmware, and OSS dependencies.
Establish Baselines: Implement Annex I control frameworks early.
Automate SBOMs: Integrate Trace-AI or ZSBOM in CI/CD pipelines.
Centralise Disclosure: Manage vulnerability reports via Compl-AI™ workflows.
Prove Conformity: Maintain CE marking evidence and SBOM archives.
Continuously Monitor: Apply predictive scoring to anticipate control drift.

cyber resilience act compliance requirements

7. Turning Compliance into Competitive Advantage

CRA-readiness is becoming a procurement differentiator. Buyers in energy, healthcare, and SaaS sectors already ask for CRA-aligned attestations. Companies demonstrating verified SBOMs and automated disclosure win faster trust and shorter sales cycles.

Transparency is now a sales accelerator. By automating CRA evidence collection, Zerberus turns regulatory obligations into a measurable asset, proving compliance as a signal of engineering maturity.

8. Key Takeaways

CRA formalises open-source and firmware security obligations across the EU market.
SBOMs are now the backbone of software and hardware transparency.
Automation is essential for continuous compliance and audit readiness.
Zerberus Trace-AI, ZSBOM, and Compl-AI™ provide end-to-end CRA alignment.

9. FAQ

How does CRA affect open-source projects?
1. Projects that are monetised or distributed in commercial products fall under CRA security and SBOM obligations.
Does non-commercial OSS fall under the Act?
1. Generally no, though downstream adopters must ensure security for embedded open-source code.
Are firmware developers legally liable under CRA?
1. Yes. Firmware manufacturers must patch, disclose, and report vulnerabilities within 24 hours to ENISA.
What SBOM formats are accepted?
1. SPDX and CycloneDX machine-readable formats are explicitly recognised.
How can Zerberus automate CRA evidence collection?
1. Trace-AI, ZSBOM, and Compl-AI™ automate SBOM creation, vulnerability scoring, and attestation evidence — building a continuous compliance framework.