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Black Fox Security

02 / Compliance and certification

The Cyber Resilience Act, for products that ship with code inside

We help manufacturers read their products against the essential cybersecurity requirements, test what they ship, and set up the vulnerability handling the regulation expects for as long as the product is supported.

Overview

What the Cyber Resilience Act asks of you

The Cyber Resilience Act, Regulation (EU) 2024/2847, sets horizontal cybersecurity requirements for products with digital elements placed on the EU market: hardware and software that connect, directly or indirectly, to a device or a network. Products already covered by certain sector rules, such as medical devices or vehicles, are carved out.

The obligations fall mainly on manufacturers, with duties for importers and distributors too. Products must meet essential cybersecurity requirements by design, manufacturers must handle vulnerabilities throughout the support period, report actively exploited vulnerabilities and severe incidents, and show conformity through technical documentation, an EU declaration of conformity and the CE marking.

The obligations phase in over several years, and we work to them as they apply. Black Fox is not a notified body or a market surveillance authority. For most products the manufacturer assesses conformity itself; for some categories of important and critical products a notified body or a certification scheme is involved. We prepare you for either.

Who it is for

Manufacturers of connected hardware, software and firmware sold in the EU, including makers of IoT devices, desktop and mobile applications and virtual appliances. Also importers and distributors who need to know what to ask of the products they place on the market.

The work, from scoping to evidence.

What we do

  1. Applicability and classification

    We look at your product range and help you work out which products are in scope, your role for each one, and whether a product is likely to fall into an important or critical category.

  2. Essential requirements gap assessment

    A review of each product against the essential cybersecurity requirements, such as secure default configuration, protection of data, access control, attack surface reduction and secure updates.

  3. Product security testing

    Penetration tests and release security reviews of the product as shipped, including firmware, mobile, desktop and virtual appliance builds and the services they talk to.

  4. Vulnerability handling

    A process for receiving, triaging, fixing and disclosing vulnerabilities, a software bill of materials, and a route for the reports the regulation requires.

  5. Technical documentation

    Help with the cybersecurity risk assessment and the technical documentation that supports your declaration of conformity.

  6. Secure development

    Practical changes to how the product is built, reviewed and released, so the requirements are met by the pipeline and not by a scramble before launch.

How the engagement runs

  1. Kickoff

    We agree which products, versions and teams are in scope, and sign an NDA first if you need one.

  2. Product mapping

    We map each product's components, interfaces, dependencies and update path, and its likely classification.

  3. Gap assessment

    Documentation review, interviews with engineering and a technical look at the product, ending in a ranked gap report per product.

  4. Testing

    Security testing of the product as shipped, with business and technical reports and proofs of concept.

  5. Process and documentation

    We work with your teams on vulnerability handling, the SBOM, reporting routes and the technical documentation.

  6. Handover and follow-up

    Recommendations and a plan per product, then optional retesting of new releases as obligations apply.

What you receive

  • Product scope and classification overview
  • Gap assessment against the essential cybersecurity requirements
  • Penetration test or release security review report
  • Vulnerability handling and disclosure procedure
  • Input for the cybersecurity risk assessment and technical documentation
  • Prioritised action plan per product

Black Fox prepares and supports you, and does not issue certificates, attestation reports or official assessments itself. Where a certificate or report is the goal, we coordinate the audit with our long-standing certification partners or a body of your choice, so the work runs end to end in one engagement.

Questions

Are you a notified body?

No. Notified bodies are designated by member states to carry out third-party conformity assessment. We prepare your product and documentation, test it and help you respond to findings, whichever assessment route applies.

Does it apply to open-source software?

Free and open-source software that is not supplied in the course of a commercial activity is generally outside the main obligations, and the regulation has a lighter regime for open-source software stewards. If you sell a product that includes open-source components, the components are your responsibility as manufacturer.

When do the obligations apply?

They phase in. The reporting obligations apply before the rest of the requirements. Check the dates against the regulation and the guidance from the Commission. We plan the work so the parts that apply first are ready first.

Does a penetration test prove conformity?

No. Testing is evidence for some requirements, but conformity rests on the risk assessment, the design, the vulnerability handling and the documentation together. A test tells you where the product stands today.

Start with the product you ship next

Tell us what you build and how it reaches customers. We will show you where the essential requirements and your product part ways.

Request a meeting

Send us a request to arrange a meeting, so you can tell us about your project and we can introduce ourselves and our experience properly.

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