How to Automate EU Cyber Resilience Act Compliance in Your CI/CD

Ramkumar Sundarakalatharan
Sep 20
5 min read

Updated: Oct 21

Meet EU CRA SBOM Requirements and Prepare for the UK Cyber Security and Resilience Bill, Without Slowing Engineers

Why This Matters Now

The EU Cyber Resilience Act compliance bar is rising for anyone shipping software. UK organisations face comparable duties under the Cyber Security and Resilience Bill. If you deliver via CI/CD, you will need machine-readable SBOMs, lifecycle vulnerability handling, and audit-ready evidence that does not throttle delivery. This guide shows how Trace‑AI automates the legal baseline and adds exploit-aware signals. This allows engineers to focus on real risk. It also sets out practical steps for automated SBOM and prioritising actively exploited issues. This aligns day-to-day pipelines with regulatory expectations for CI/CD supply chain security in the UK and EU.

EU Cyber Resilience Act Compliance, in Plain English

What the EU CRA Requires

Secure by design and by default across the product lifecycle, including vulnerability handling and security updates.
An SBOM in a machine-readable format as part of technical documentation, covering at least top-level dependencies.
Reporting obligations for actively exploited vulnerabilities and severe incidents start earlier than the full application date.
Penalties for non-compliance can reach €15 million or 2.5% of worldwide turnover.

What the UK CSRB Proposes

Extends regulation to more digital service providers, including managed service providers and certain data centres.
Enables regulators to designate critical suppliers where disruption would have a significant impact.
Strengthens supply chain risk duties and incident reporting expectations.

What This Means for CI/CD

You need a trustworthy component inventory by build, with machine-readable SBOMs.
You need a way to prioritise items that are being exploited, not only listed identifiers.
You need evidence you can export for auditors, customers, and procurement, without spreadsheet work.

CI/CD Supply Chain Security in the UK: Where Pipelines Feel the Pressure

Inventory Drift: Package trees and transitive dependencies change frequently. Without automation, SBOMs go stale quickly.
Signal Versus Noise: Treating every CVE equally overwhelms engineers. The regulatory emphasis on actively exploited issues calls for better prioritisation.
Evidence on Demand: Buyers and due diligence teams now expect clear artefacts that can be validated, not screenshots.

Automated SBOM in CI/CD: What Trace‑AI Does Out of the Box

1) Build Time SBOMs

Automatically generates SBOMs in machine-readable formats at build time. This captures at least top-level dependencies, ensuring your technical documentation keeps pace with releases.

See Build Time SBOMs on the product page → Trace-AI.

2) Lifecycle Tracking

Maintains a history of components across versions. This enables vulnerability handling, update planning, and deprecation decisions.

3) Known Exploited Emphasis

Surfaces packages linked to actively exploited vulnerabilities. This allows engineering and security teams to focus on what regulators and customers worry about first.

4) Audit-Ready Exports

One-click export of SBOM snapshots and pipeline decisions supports CRA documentation and UK regulator expectations. It provides alignment support, not a certification.

Beyond the Minimum: Exploit-Aware Signals That Reduce Real Risk

These are not mandated SBOM fields. They are practical signals that strengthen outcomes.

Typosquatting and Maintainer Anomaly Detection

Flags lookalike package names and sudden ownership or permission changes that often precede dependency hijacks.

Package Abandonment Monitoring

Down ranks trust in stale dependencies with no maintainer activity or broken repositories. These are easier takeover targets and slower to receive fixes.

Together, these signals help CI/CD policies prioritise exploitable conditions, not only theoretical vulnerabilities.

UK Relevant Incidents to Learn From

Jaguar Land Rover

In late August and early September 2025, JLR experienced a major cyber incident that halted manufacturing and retail operations. Public reporting confirms the production shutdown extended to at least 24 September 2025. JLR later stated that some data was affected, while investigations into the precise intrusion path continued. Claims of responsibility were reported as claims, not formal attribution. The disruption affected suppliers and retailers dependent on JLR systems and reportedly paused output of roughly 1,000 vehicles per day during the shutdown window.

Retail Cluster: Marks & Spencer, Co‑op, Harrods

In April and May 2025, a series of disruptive cyberattacks hit major UK retailers. The National Crime Agency announced arrests of four individuals in July 2025 in connection with the investigation. Reporting points to social engineering and credential abuse patterns. Package-level dependency compromise has not been publicly confirmed for these retailers. The operational impacts included prolonged online and in-store service disruption and significant business interruption costs.

Why This Matters for Software Supply Chain Teams

Even when the initial vector is human-centred, dependency inventories, build systems, and third-party integrations often sit in the blast radius. Strong segmentation, attestation, and policy gates help prevent an intrusion from propagating through build and release machinery.

A Tactical Cautionary Tale

“Monday 11:42”: A Realistic UK SaaS Scenario

A hotfix bumps a colour utility dependency. The build resolves to a version that was compromised earlier that morning in a global package ecosystem campaign.
A post-install script attempts to collect tokens from the CI runner and the developer machine.
Webhooks push secrets to an attacker-controlled endpoint.
Compromised tokens are used to create persistence in CI settings and to publish tainted forks in internal registries.
Release provenance breaks. Customer rollout is paused while Legal and Comms triage impact.

Why Teams Miss It

SBOMs exist but are stale; there is no deny list gate for known bad versions or suspicious maintainer changes, and secrets rotation is not triggered automatically when a policy fails.

What Would Change with an Exploit-Aware SBOM Layer

Build Policy Gates

Block builds that pull known compromised versions.
Alert on maintainer or repository anomalies and sudden permission changes for popular packages.
Enforce attestations for build steps and quarantine artefacts that fail verification until human review.

Exploit-Aware Triage

Prioritise dependencies linked to actively exploited campaigns.
Automatically propose safe pins and generate pull requests to roll back or replace risky components. For automated remediation flows, see Remed‑AI → Remed-AI.

Secrets and Runner Hygiene

Auto revoke and rotate tokens on any policy gate failure.
Mark runners as tainted and require clean, short-lived, least privilege runners for subsequent releases.

Audit Pack on Demand

Export the SBOM snapshot, policy decisions, attestation logs, and remediation trail to support CRA documentation and UK regulator expectations. This can be shareable as part of procurement due diligence and customer assurance.

Getting Started

You do not need to boil the ocean. Start with one pipeline and apply three controls:

Generate a machine-readable SBOM on every build.
Add a deny rule gate for known compromised versions and maintainer anomalies.
Turn on automatic token rotation when a gate fails.

You can expand to provenance attestations and inventory-wide reporting in the next sprint. To discuss a tailored rollout, book a demo → Book a Demo.

You can download our free 2 Sprint Checklist here.