Unlocking CRA Compliance with Sustainable Open-Source Foundations

Last November, the EU’s Cyber Resilience Act (CRA) entered into force, kicking off a short transition phase that ends in 2027. From that point on, every vendor that puts a “product with digital elements” on the European market must be able to prove three requirements:

1. The product is secure by design.
2. Vulnerabilities are monitored and fixed throughout its lifetime.
3. A Software Bill of Materials (SBOM) documents what’s inside.

This is especially challenging for teams leveraging complex open-source stacks, since OSS components are exempt from the CRA until they are part of a commercial product (at which point the vendor is fully responsible for security). Also, meeting these new obligations requires more than policy — it demands infrastructure, mature processes, and deep technical expertise.

Unfortunately, the CRA is high-level in scope, requiring secure default configurations, encryption, and a minimum support lifespan — but comes short on prescribing how to implement them.

In this article, we break down the three critical CRA requirements and explain what each entails and why they’re challenging. We also discuss how using our CtrlOS platform (a NixOS-based embedded OS with long-term support) can help bridge the technical and organizational gap to CRA compliance by providing a stable, secure base with integrated vulnerability handling and SBOM tooling.

How to Achieve Secure-by-Design Software Under the Cyber Resilience Act

CRA requirement: Products must ship with secure default configurations, strong encryption where appropriate, and a defined support lifespan — but the law is silent on implementation details.

Why this hurts: Modern devices are built on large open-source stacks: Linux, middleware, containers, virtualization layers. Each is solving complex problems like hardware compatibility or robust isolation. Hardening that stack and keeping only what you need requires infrastructure, mature processes, and deep expertise.

CtrlOS advantage: We maintain and harden critical open-source components and bundle them in CtrlOS, an embedded NixOS variant. We ensure a minimal attack surface, by making it easy to build exactly what you need — without hidden dependencies. Each image you build is reproducible, giving your engineers the insight needed for deep analysis of issues — even years from now.

Meeting CRA CVE Management Requirements: Tools, Processes, and Challenges

CRA requirement: One of the central mechanisms in the CRA is to require a process for security updates and CVE management. Vendors are required to publish a point of contact for security researchers to report vulnerabilities in products. The CRA doesn’t stop there: It also requires vendors to have a process to handle the vulnerabilities and ship updates to consumers.

Why this is hard: Most teams lack the capacity to track vulnerabilities across hundreds of upstream projects, let alone back-port patches and push reliable updates. So, how can vendors navigate these new requirements — without giving up the benefits of open-source? Open-source is a key ingredient for digital sovereignty in Europe. It drives the modern software industry and enables an ecosystem of software companies to thrive in the EU market. We cannot just abandon open-source dependencies. As a product vendor, it would be extremely expensive to build the capacity and know-how required to be able to maintain each and every dependency yourself.

CtrlOS advantage: CtrlOS comes with five-year long-term support. Cyberus monitors upstream CVEs, back-ports fixes, and provides pre-built updates so your team can focus on application code instead of becoming a full-time security response unit.

Building CRA-Compliant Software with Accurate SBOM and Dependency Tracking

CRA requirement: Digital products today are built on Linux and other key open-source ingredients. But these are just the tip of the iceberg. Many components come with complex and large dependency trees, with hundreds of libraries beneath. In order to get this complex software supply chain under control, vendors are required to have a Software Bill of Materials or SBOM for short.

Why this is hard: One key problem is that vendors usually do not have the capacity to implement all required measures for CRA compliance for all their open-source software dependencies. These open-source components often solve complex technical issues (such as robust encryption, hardware compatibility) or implement security architecture components (such as isolation via containers or virtualization). Building and maintaining these kinds of software packages requires deep, specialized technical skills and know-how.

CtrlOS advantage: We integrate the excellent SBOM tooling from the Nix ecosystem and make it simple to keep track of everything that goes into your SBOM. We also provide commercial support and CVE management from our experts when things get complicated.

CtrlOS by Cyberus: Your Trusted Platform for CRA-Compliant Open-Source Products

Cyberus Technology is uniquely positioned to maintain and harden open-source components — from the Linux kernel to Cyberus Hypervisor.

That experience is distilled into CtrlOS, our NixOS-based embedded platform that ships with:

• Five-year long-term support (LTS) and security updates that stay ahead of CRA response deadlines.
• Reproducible, declarative builds so secure-by-design isn’t an extra step — it’s the default state of every image you release.
• Integrated SBOM tooling of the excellent Nix ecosystem.
• A dedicated security response team that monitors upstream CVEs, back-ports fixes, and helps your engineers stay focused on product features.

By adopting CtrlOS you begin with a platform already engineered for the CRA’s technical and organizational demands, turning the regulation’s mandate into a head start rather than a hurdle. We partner closely with device makers: from first technical workshops, to a closed beta, and finally to automated field-update rollout — so that open-source dependencies become a long-term competitive edge, not a liability.

Ready to Meet CRA Requirements with Open Source? Contact Cyberus Today.