Executive Summary
The European Union’s Cyber Resilience Act (CRA) marks a paradigm shift in cybersecurity regulation, moving accountability for product security directly onto the manufacturers. For providers selling connected B2B products and services into the EU’s financial sector—a domain built on trust and resilience—the CRA is not merely a compliance hurdle; it is a fundamental test of their architecture and operational integrity. The mandate for products to be “secure by default,” manage vulnerabilities proactively, and ensure the integrity of their software supply chain requires a move beyond traditional, perimeter-based security models.
However, the EU CRA is also a revenue opportunity for the financial services technology providers which implement it the best. It makes their products more attractive in the market and decreases the risk of business continuity impacting breaches. Notably it means their customers have much less work to do to comply with DORA – enabling a competitive advantage for the financial service provider. The Digital Operational Resilience Act (DORA) governs the operational resilience of the financial institution and places operational obligations on the institution. Financial services providers who implement the EU CRA make it simpler for their customers to comply with DORA.
This guide provides a detailed analysis of the CRA’s essential requirements, tailored specifically to financial technology providers such as core banking vendors, payment processors, market data suppliers, and other B2B fintechs. For each key requirement derived from the CRA’s text, we present a three-tiered maturity model for compliance: Compliant (meeting the minimum legal standard), Strongly Compliant (adopting current best practices), and Strongest Compliance (implementing state-of-the-art, Zero Trust principles).
The central thesis is that achieving and maintaining CRA compliance necessitates a strategic shift from network-based controls (like VPNs and IP whitelisting) to an identity-led, cryptographically verified, and least-privilege approach to security. This whitepaper serves as a strategic guide for technology leaders to assess their current posture, identify gaps, and build a roadmap toward the strongest level of cyber resilience.
1. Introduction: The New Baseline for Trust in Financial Technology
The EU Cyber Resilience Act fundamentally redefines the obligations of any entity placing a “product with digital elements” on the EU market. For the financial services industry, where a single vulnerability can have systemic consequences, this regulation crystallizes a long-overdue market expectation: the technology that powers finance must be secure by design.
The CRA’s scope is broad, covering software, hardware, and their components. This means core banking platforms, payment terminals, market data feeds, risk management software, and even the APIs offered by fintechs are all subject to these new rules. This guide breaks down the CRA’s essential requirements from Annex I into seven actionable domains and provides a practical framework for compliance.
2. EU CRA requirement: Secure by Design & Default Configuration
The CRA mandates that products be designed, developed, and produced to ensure an appropriate level of cybersecurity. They must be placed on the market with a secure default configuration, including the ability to be reset to that state.
The principles of secure-by-design are central to standards like ETSI EN 303 645 (“Cyber Security for Consumer Internet of Things”) and IEC 62443 (“Security for industrial automation and control systems”).
- ETSI EN 303 645 includes foundational provisions like “no universal default passwords” and “minimise attack surfaces,” which are met by the ‘Compliant’ and ‘Strongly Compliant’ tiers.
- IEC 62443-4-1 details a secure product development lifecycle, requiring threat modeling and security-by-design principles throughout the product’s creation. Taking the “Strongest Compliance” approach—by architecting a product that is “dark” by default—inherently fulfills these requirements. It represents the ultimate implementation of attack surface minimization and demonstrates a mature secure development lifecycle where potential threats from exposed networks are eliminated at the design phase, not mitigated later with firewall rules.
| Compliance Level | Description of Method |
| Compliant | The product is shipped with secure configuration options available, but may require the customer to manually enable them. Default passwords are no longer used. Documentation provides a “hardening guide” for the customer to follow. Customer must manually configure firewall rules, roles, and disable insecure defaults (e.g., weak TLS versions). |
| Strongly Compliant | The product ships in a “secure by default” state. All non-essential ports are closed, security features are enabled, and the principle of least privilege is applied to default user roles. The customer must take explicit action to reduce the security level. Provider ships hardened default configurations and disables all insecure protocols by default. |
| Strongest Compliance | The product’s architecture inherently eliminates major attack surfaces. It requires no inbound firewall ports from the internet on the customer’s side and uses outbound-only connectivity. APIs are not unnecessarily exposed to the public internet. The product is “dark” by default, only accessible via a private, identity-based overlay network. Provider enforces immutable security controls (e.g., TLS 1.3 only, MFA enabled, least privilege RBAC) and disallows override without admin audit. This also meets these ETSI and IEC requirements: ETSI EN 303 645 includes foundational provisions like “no universal default passwords” and “minimise attack surfaces,” which are met by the ‘Compliant’ and ‘Strongly Compliant’ tiers.IEC 62443-4-1 deta |
3. EU CRA requirement: Vulnerability Management & Coordinated
Disclosure
The CRA requires manufacturers to identify and document vulnerabilities, including those in third-party components. They must have processes to address and remediate vulnerabilities without delay and must facilitate the sharing of this information.
| Compliance Level | Description of Method |
| Compliant | The provider has a published security contact (e.g., security@vendor.com) for reporting vulnerabilities. They perform internal vulnerability scans and maintain a Software Bill of Materials (SBOM) for internal use. |
| Strongly Compliant | The provider maintains a public, well-defined Vulnerability Disclosure Policy (VDP). They publish security advisories for patched vulnerabilities. They use automated tools to continuously monitor third-party components listed in their SBOM and have a clear process for patching them. |
| Strongest Compliance | The provider operates a public bug bounty program with financial rewards, attracting a wide range of security researchers. Their VDP is integrated with national CERTs. SBOMs are generated automatically for every build and can be made available to customers or regulators upon request. This requirement maps directly to ISO/IEC 30111 (“Information technology — Security techniques — Vulnerability handling processes”) and ISO/IEC 29147 (“Information technology — Security techniques — Vulnerability disclosure”). |
4. EU CRA Requirement: Secure Software Updates & Supply Chain Integrity
The CRA mandates that security updates must be provided in a timely manner and free of charge. The integrity and authenticity of updates must be ensured.
| Compliance Level | Description of Method |
| Compliant | Updates for on-premise software are made available for download from a web portal secured with standard TLS. |
| Strongly Compliant | The download portal requires user authentication. All software updates are digitally signed, and their cryptographic hashes (e.g., SHA-256) are published separately, allowing customers to manually verify the integrity of the downloaded package. |
| Strongest Compliance | Updates are delivered via a private, outbound-only connection from the customer’s deployed software to the vendor’s update service. The update mechanism itself is built on a framework like The Update Framework (TUF), which provides cryptographic verification of the channel and the software’s authenticity, protecting against rollback attacks and key compromise. SaaS providers secure their internal CI/CD pipeline with a Zero Trust model. The secure update requirement is also a key component of IEC 62443-4-2, which mandates that the system provide a mechanism to ensure the authenticity and integrity of software updates. |
5. EU CRA requirement: Secure Data Handling (in transit, at rest, in use)
The CRA requires that products ensure the confidentiality, integrity, and availability of data processed by them. This includes protection against unauthorized access.
| Compliance Level | Description of Method |
| Compliant | All external network traffic is encrypted using industry-standard TLS 1.2 or higher. Sensitive data stored at rest (e.g., in a database) is encrypted. |
| Strongly Compliant | All network traffic, both internal (service-to-service) and external, is encrypted using TLS. For critical API endpoints, Mutual TLS (mTLS) is offered as an option, where the client must also present a valid certificate to authenticate itself. Certificates are typically customer-provided and managed. |
| Strongest Compliance | mTLS is mandated for all persistent server-to-server connections (e.g., agent-to-cloud). The vendor provides a managed Public Key Infrastructure (PKI) to automatically issue, rotate, and revoke short-lived client certificates, removing the management burden from the customer. Data in use is protected where possible using confidential computing technologies (e.g., secure enclaves). This also meets IEC 62443-4-2 specific requirements for Communication Integrity and Confidentiality. |
6. EU CRA requirement: Access Control & Identity Management
Products must control access to data and functions through appropriate authentication and identity management mechanisms, adhering to the principle of least privilege.
| Compliance Level | Description of Method |
| Compliant | The product supports username/password authentication with strong password policies. A basic set of user roles (e.g., Admin, User) is provided. |
| Strongly Compliant | The product supports and encourages Multi-Factor Authentication (MFA). It provides granular Role-Based Access Control (RBAC) and integrates with enterprise identity providers via SAML or OIDC for Single Sign-On (SSO). API access is controlled via scoped OAuth 2.0 tokens. |
| Strongest Compliance | All access, both for human users and programmatic services, is based on short-lived cryptographic identities (e.g., SPIFFE/SPIRE). All privileged access (including for the vendor’s own remote support) is granted on a per-session, just-in-time (JIT) basis through a Zero Trust access broker, eliminating standing privileges and VPNs. This also meets requirements for “human user identification and authentication” and “authorization enforcement” – core components of IEC 62443-4-2. |
7. EU CRA requirement: Transparency & Documentation
Manufacturers must provide clear, comprehensible instructions and information to the user, including the product’s intended purpose, security properties, and instructions for secure use, maintenance, and disposal.
| Compliance Level | Description of Method |
| Compliant | Basic user and installation manuals are provided. A Software Bill of Materials (SBOM) is maintained internally. |
| Strongly Compliant | The provider offers a public-facing “Trust Center” website with security whitepapers, compliance certifications (e.g., SOC 2, ISO 27001), and clear documentation on security features. Documentation includes a “Shared Responsibility Model” for cloud services. |
| Strongest Compliance | The provider offers a dynamic, machine-readable SBOM via a dedicated API. Their Trust Center includes real-time or near-real-time status information on service health and security. Documentation is comprehensive, version-controlled, and includes detailed API references and architectural diagrams that explain the security model. While broad, this requirement for transparency aligns with the documentation components of IEC 62443-4-1 (which requires providing security documentation to the end-user) and emerging best practices around supply chain security. |
8. Conclusion: From Compliance Burden to Competitive Advantage
The EU Cyber Resilience Act should not be viewed as a mere checklist of technical requirements. It is a strategic mandate to embed security into the entire lifecycle of a product. For providers in the financial services sector, demonstrating the highest level of compliance is a powerful differentiator that builds profound trust with clients, as well as making it simpler for their clients to implement, while meeting DORA guidelines.
Moving beyond the baseline “Compliant” options toward the “Strongest Compliance” models—characterized by Zero Trust architecture, cryptographic identity, comprehensive transparency, and proactive vulnerability management—will separate the market leaders from the laggards and make it that much easier for their customers to be DORA compliant. By architecting for resilience from the ground up, vendors can transform the CRA from a regulatory burden into a catalyst for innovation and a cornerstone of their value proposition. The guide above also lists key ISO and IEC requirements which are met as the CRA states that harmonized reqs – like ISO and IEC -also need to be met.
