The Cyber Resilience Act (CRA) introduces a unified set of cybersecurity requirements that apply to all Products with Digital Elements (PDE) placed on the EU market. One of the most demanding obligations for manufacturers, software teams and IoT vendors is the creation and continuous maintenance of Technical Documentation.
This guide explains in detail what the CRA requires under Annex II (technical documentation for conformity) and Annex VII (post-market documentation and vulnerability handling records). Most companies underestimate the scale and depth of this obligation. This document covers everything you must prepare before 2027 to avoid market disruption, non-compliance penalties and product recalls.
For templates and checklists, see our CRA Readiness Checklist.
1. What Is CRA Technical Documentation?
Under the Cyber Resilience Act, Technical Documentation is the complete package of evidence, security controls, lifecycle processes and product information required to demonstrate conformity with the Essential Cybersecurity Requirements in Annex I. It must:
- Be created before placing the product on the market
- Be kept updated throughout the lifecycle of the product
- Be available to authorities upon request
- Include design, implementation, testing, and vulnerability handling evidence
- Be sufficient for authorities or notified bodies to assess conformity
Failure to produce this documentation can prevent a product from being sold in the EU, even if it meets all technical requirements.
2. Why CRA Technical Documentation Matters
The CRA is designed to eliminate inconsistent and insufficient cybersecurity documentation across the EU. Historically, manufacturers submitted uneven evidence, lacked security lifecycle records, or kept undocumented processes. Under CRA, documentation plays three critical roles:
- Demonstrates compliance with Annex I requirements
- Enables audits and investigations by market surveillance authorities
- Supports vulnerability management and incident reporting
Authorities consider documentation to be the foundation of cybersecurity assurance. Inadequate documentation can itself be a violation.
3. What Documentation Is Required Under Annex II?
Annex II defines the core Technical Documentation for conformity assessment. Manufacturers must produce a complete set of documents describing how the product meets the Essential Cybersecurity Requirements.
The documentation must include:
3.1 Product Description and Intended Use
- Product type, model, version
- Intended use cases and operational environment
- Connectivity features (wired, wireless, protocols)
- Dependencies on cloud services or external systems
3.2 Architecture and System Design
- High-level software architecture
- Module breakdown
- Firmware architecture
- Network architecture diagrams
- Data flow diagrams (DFDs)
- Third-party components and open-source libraries
3.3 Security Controls and Annex I Requirements Mapping
Manufacturers must demonstrate how each cybersecurity requirement in Annex I is fulfilled, including:
- Secure boot and integrity mechanisms
- Authentication and authorization controls
- Protection against injection, memory corruption and exploitation
- Network security measures
- Security of update mechanisms
- Cryptographic functions
- Secure storage of sensitive data
A full requirements matrix is recommended: See CRA Requirements Mapping.
3.4 Update and Patch Management Documentation
- Software update architecture
- Firmware update mechanisms
- Secure update validation (signing, authenticity, rollback prevention)
- Lifecycle support policy (how long updates are guaranteed)
3.5 Vulnerability Handling Documentation
- Internal vulnerability intake process
- Assessment and prioritization methods
- Remediation workflows and timelines
- Incident reporting to authorities (within mandated deadlines)
3.6 Testing and Validation Evidence
Manufacturers must provide proof of security testing:
- Penetration testing summaries
- Static and dynamic code analysis results
- Fuzzing results (if applicable)
- Third-party testing (if used)
3.7 SBOM (Software Bill of Materials)
The SBOM is mandatory for products containing software. It must include:
- Component name, version, supplier
- Known vulnerabilities
- Licensing information
- Dependency relationships
4. What Documentation Is Required Under Annex VII?
Annex VII focuses on post-market monitoring and vulnerability handling documentation.
This covers all evidence a manufacturer accumulates after the product is placed on the market, including security updates and incident reporting records.
4.1 Post-Market Monitoring Plan
- Security monitoring strategy
- Sources of threat intelligence
- Automated monitoring tools and manual processes
- How security alerts are prioritized
4.2 Vulnerability Database / Register
- List of vulnerabilities discovered post-release
- Discovery date, reporting date, remediation date
- Impact assessment
- Interaction with ENISA or CSIRTs (if required)
4.3 Incident Reporting Documentation
For exploited vulnerabilities or severe cybersecurity incidents, manufacturers must keep:
- Incident timeline
- Evidence of exploitation
- Mitigation actions performed
- Notices sent to authorities
- User notifications (if applicable)
4.4 Update & Patch History
- Version history of firmware/software
- Security patches released
- Reason for updates
- Validation steps performed
5. CRA Technical Documentation Checklist
This checklist summarizes the full scope:
- Product description and intended use
- Architecture diagrams
- Security design documents
- Annex I requirements mapping
- Threat modelling (recommended)
- Update and patch management plan
- Secure development lifecycle documentation
- Vulnerability handling processes
- Security testing evidence
- SBOM with full dependency mapping
- Risk assessment report
- Conformity assessment documentation
- Post-market monitoring plan (Annex VII)
- Incident report logs
- Update history and remediation records
Download the full templates here: Cyber Resilience Act Resources
6. Who Must Produce Technical Documentation?
Technical documentation is required from all manufacturers of CRA-regulated products. However, importers and distributors also have obligations:
6.1 Manufacturers
They must create and maintain the full documentation package.
6.2 Importers
Must verify the existence and completeness of the documentation before placing the product on the EU market.
6.3 Distributors
Must ensure no known non-compliance exists and must cooperate with authorities.
7. The Difference Between Default Class and Critical Class Documentation
Both classes require full Annex II documentation, but Critical Class products require additional scrutiny:
- Stricter conformity assessment
- Possible third-party evaluation
- More detailed evidence for security controls
- Longer retention of post-market documentation
Critical Class includes:
- Security products
- Routers, gateways, connectivity infrastructure
- Industrial systems supporting essential services
For classification rules, see: CRA Applicability & Classification Guide.
8. How to Structure Your CRA Documentation (Recommended Template)
The following structure is commonly used in conformity assessment under other EU frameworks (e.g., RED, MDR, Machinery Regulation). It adapts perfectly to CRA:
Part 1 — Product Overview
Part 2 — Engineering Documentation
Part 3 — Cybersecurity Requirements Mapping
Part 4 — Secure Development Lifecycle
Part 5 — Testing & Validation Summary
Part 6 — Conformity Assessment Evidence
Part 7 — Post-Market Monitoring Plan
Part 8 — Annexes (SBOM, test logs, vulnerability registers)
9. Common Mistakes Companies Make When Preparing Documentation
- Starting documentation too late
- Not mapping Annex I requirements explicitly
- No SBOM or incomplete SBOM
- Lack of vulnerability handling procedures
- No evidence of secure update validation
- Overlooking third-party components and supply-chain security
- No post-market monitoring strategy
- No logging of security testing results
These gaps are among the most common causes of non-compliance findings.
10. Should You Automate CRA Technical Documentation?
Most manufacturers will struggle to maintain documentation manually. Automated CRA documentation tools — such as Regulus — solve three key problems:
- Mapping Annex I requirements correctly
- Keeping documentation updated during the lifecycle
- Linking vulnerabilities, updates and evidence in one place
Try a starter automation here: CRA Applicability Checker
11. External Resources
- European Commission – CRA Announcement
- ENISA – EU Cybersecurity Agency
- NIST Secure Software Development Framework
Conclusion
Technical Documentation is one of the most significant obligations introduced by the CRA. It requires continuous security evidence, lifecycle monitoring, vulnerability management and explicit mapping of cybersecurity requirements.
Companies that begin preparing early will be better positioned for compliance, market access and product reliability in the 2025–2027 window.
Explore templates and checklists here: Cyber Resilience Act Resources
