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Practical guides for software companies, SaaS providers, product teams, hardware manufacturers and engineering leaders that need to build secure digital products and meet cybersecurity requirements such as the Cyber Resilience Act. We cover secure SDLC, product security, threat modeling, vulnerability management, SBOM, secure updates, DevSecOps, security testing, responsible disclosure and secure-by-design practices.

Threat Modeling: A Practical Guide for Product Teams

Threat modeling helps product teams identify security problems during design, before they reach code and production. Learn how to run a practical session, what questions to ask, how to use STRIDE, how to document results and how to turn threats into concrete tasks for the team.

Prepared by: CCyber Editorial Team

Short answer

Threat modeling is a practical method for analyzing a product, feature or architecture to understand what can go wrong from a security and privacy perspective. Product teams should start with four questions: what are we working on, what can go wrong, what are we going to do about it and did we do a good enough job? The outcome of a good session is not only a diagram, but a list of risks, decisions, security requirements, tests and implementation tasks.

Last updated

July 2026

Who this article is for

  • product teams
  • product owners and product managers
  • software houses
  • SaaS companies
  • CTOs and Heads of Engineering
  • software architects
  • developers
  • DevOps and DevSecOps teams
  • CISOs and application security leaders
  • testers and QA teams
  • companies preparing for CRA, Secure SDLC, ISO/IEC 27001, SOC 2 or customer requirements

Key takeaways

  1. Threat modeling works best early, during requirements, architecture or design of an important feature.
  2. A good session does not require a perfect diagram or expensive tool. It requires the right scope, the right team, a simple system model and concrete questions.
  3. The most important question is: what can go wrong and how will we reduce that risk in the product?
  4. STRIDE helps structure threat thinking: spoofing, tampering, repudiation, information disclosure, denial of service and elevation of privilege.
  5. The output should be backlog tasks, security requirements, tests, risk acceptance decisions and current documentation.

What is threat modeling?

Threat modeling is the analysis of a product, feature, process or architecture from the perspective of possible threats. The goal is to find security and privacy problems before they become embedded in code, configuration, integration or a business process.

In practice, threat modeling helps answer four questions:

  • what are we working on?
  • what can go wrong?
  • what are we going to do about it?
  • did we do a good enough job?

Well-run threat modeling is not an academic exercise. It is a workshop designed to improve design, reduce risk and create tasks the team can actually implement.

Why should product teams do threat modeling?

Product teams make decisions that directly affect security: how login works, who can access data, how the API behaves, where customer boundaries exist in SaaS, what integrations can access the system and how the product handles errors.

If security appears only during a penetration test before release, many architecture decisions are already hard to change. Threat modeling moves the discussion earlier, where fixes are cheaper and less painful.

Threat modeling helps:

  • identify risks during design
  • understand data flows
  • define trust boundaries
  • detect weak architecture assumptions
  • turn risks into security requirements
  • plan better security tests
  • prepare evidence for customers and audits
  • reduce costly fixes after deployment

When should threat modeling be done?

For a new product

The best moment is during concept, architecture or first version planning. At that stage, the team can still change the approach to data, authentication, integrations and permissions without high cost.

For a new high-risk feature

Not every small change requires a full session. Threat modeling is especially useful for features that have higher security impact.

Examples of high-risk features:

  • login and password reset
  • administrator panel
  • payments
  • public API
  • data export
  • customer system integrations
  • AI features or AI agents
  • role and permission management
  • multi-tenant SaaS features
  • personal or confidential data processing

During major architecture changes

Threat modeling is useful during cloud migration, identity provider changes, new API deployment, microservices adoption, data model changes or new integrations.

After an incident or serious vulnerability

If the company had an incident or found a serious vulnerability, threat modeling helps determine whether the problem was isolated or caused by weak design assumptions.

Before an important audit or regulatory implementation

Threat modeling can support preparation for CRA, NIS2, ISO/IEC 27001, SOC 2, customer requirements or product conformity assessment.

How to prepare a threat modeling session

Step 1: define the scope

The most common mistake is a scope that is too broad. A session called “let’s model the whole system” can quickly become chaotic and produce no actionable result. It is better to start with a specific feature, service, module or data flow.

Good scope examples:

  • login and session management
  • new API endpoint
  • payment integration
  • data export module
  • administrator panel
  • customer onboarding process
  • new SaaS module architecture
  • AI feature analyzing customer data

Evidence to prepare: short description of session scope and modeling objective.

Step 2: invite the right people

Threat modeling should not be a solo security exercise. The best results come when people who understand the product, architecture, data, users and business risk participate.

Typical session participants:

  • product owner or product manager
  • architect or senior developer
  • developers working on the feature
  • DevOps or deployment owner
  • security engineer or CISO
  • tester or QA specialist
  • compliance or data protection representative if the topic involves personal data or regulation

The goal is not a large group. The goal is the right group. A 5-7 person session often works better than a full department meeting.

Evidence to prepare: participant list, roles and owner of session outputs.

Step 3: prepare a simple system model

The model does not need to be perfect. It should help the team see how the system works. A data flow diagram, architecture diagram or process map is usually enough.

The model should show:

  • users and roles
  • external systems
  • application components
  • databases
  • APIs and integrations
  • queues, files and data stores
  • trust boundaries
  • sensitive data
  • authentication and authorization points
  • administrative channels

Evidence to prepare: system diagram or data flow diagram with trust boundaries.

Step 4: describe the data and its value

Not all data has the same risk level. The team should know which data is public, internal, confidential, personal, financial, medical, technical or covered by business secrecy.

Useful questions:

  • what data does the feature process?
  • where is the data stored?
  • who can access it?
  • is it encrypted?
  • is it sent to external systems?
  • can one customer’s data be confused with another customer’s data?
  • is the data logged?
  • does the data go into AI tools?

Evidence to prepare: data list, classification and processing locations.

Step 5: identify trust boundaries

A trust boundary is a place where data or a request crosses between areas with different levels of control. This is often where important risks appear.

Examples of trust boundaries:

  • internet user and application
  • application and API
  • API and database
  • company system and customer system
  • application and payment provider
  • production and test environment
  • user account and administrator account
  • AI agent and internal system

Evidence to prepare: diagram with trust boundaries and description of controls at those boundaries.

How to run threat modeling step by step

Step 1: answer “what are we working on?”

First, the team must understand the scope together. The product owner explains the feature, the architect shows the model, developers add details and security helps identify risk areas.

Define:

  • feature objective
  • users
  • data
  • components
  • integrations
  • trust boundaries
  • security assumptions

Step 2: answer “what can go wrong?”

At this stage, the team identifies threats. You can use STRIDE, an OWASP checklist, previous incidents, customer requirements, MITRE ATT&CK or simple brainstorming.

Example questions:

  • can someone impersonate another user?
  • can data be modified without permission?
  • can a user deny performing an action?
  • can data be disclosed to an unauthorized person?
  • can the feature be blocked or overloaded?
  • can a normal user gain administrator privileges?
  • can customer A see customer B’s data?
  • can an external integration abuse its access?
  • do logs contain sensitive data?
  • can an AI output cause an unsafe decision?

Step 3: use STRIDE as a structure

STRIDE helps organize the discussion. It is not the only method, but it is practical and works well with product teams.

STRIDE includes:

  • Spoofing
  • Tampering
  • Repudiation
  • Information Disclosure
  • Denial of Service
  • Elevation of Privilege

For each element of the model, ask which STRIDE categories are relevant. This does not have to be mechanical for every field. The goal is to find real threats, not to fill in a table.

Step 4: assess risk and priorities

Not every threat is equally important. After threats are identified, decide which require action now, which can be planned later and which can be consciously accepted.

When assessing risk, consider:

  • customer impact
  • data impact
  • service availability impact
  • ease of exploitation
  • likelihood
  • detectability
  • cost of remediation
  • regulatory or contractual requirements

In practice, a simple scale is enough: critical, high, medium, low. The important thing is that the team understands why a risk has a given priority.

Step 5: plan a response to threats

For every significant threat, define a response. The most common options are: mitigate the risk, remove the feature or risk source, transfer responsibility or consciously accept the risk.

Good mitigation actions should be concrete:

  • add object-level authorization
  • require MFA for administrators
  • limit API token permissions
  • add rate limiting
  • remove sensitive data from logs
  • encrypt data in the database
  • add authorization tests
  • separate customer data
  • change integration architecture
  • add an alert for unusual behavior

If the response does not lead to a task, requirement or test, it is probably too general.

Step 6: turn outputs into tasks

The biggest value appears when threat modeling outputs enter the team’s work. Risks should become backlog tasks, security requirements, tests, decisions or risk acceptances.

For every significant threat, define:

  • owner
  • priority
  • deadline
  • technical task
  • required test
  • evidence of completion
  • risk acceptance decision if the risk is not remediated

Step 7: check whether you did a good enough job

At the end of the session, the team should check whether the model makes sense and whether outputs are useful.

Control questions:

  • does the model reflect the real architecture?
  • are trust boundaries marked?
  • is sensitive data included?
  • do the most important threats have responses?
  • are actions implementable?
  • were backlog tasks created?
  • were security tests created?
  • has someone accepted risks that are not being fixed?

Practical 90-minute session agenda

0 to 10 minutes: objective and scope

  • what are we modeling?
  • why now?
  • what decisions do we want to make?
  • what is the expected output?

10 to 25 minutes: system model

  • components
  • users
  • roles
  • integrations
  • data
  • trust boundaries

25 to 55 minutes: threat identification

  • STRIDE
  • attack scenarios
  • previous incidents
  • business risks
  • customer and regulatory requirements

55 to 75 minutes: priorities and responses

  • impact assessment
  • risk priority
  • mitigations
  • technical tasks
  • tests
  • risk acceptances

75 to 90 minutes: summary and owners

  • list of top risks
  • backlog tasks
  • owners
  • deadlines
  • missing information
  • next review date

Threat modeling checklist for product teams

Scope

  • do we know which feature or system we are modeling?
  • is the scope not too broad?
  • do we know the business objective of the feature?
  • do we know who will use the feature?

System model

  • do we have a component diagram?
  • do we have data flows?
  • have we marked trust boundaries?
  • have we included external systems?
  • do we know where sensitive data is?

Authentication and access

  • can a user impersonate someone else?
  • is access checked server-side?
  • is there a risk of accessing another customer’s data?
  • do administrators have separate roles?
  • are tokens and sessions handled securely?

Data

  • is data classified?
  • is data encrypted in transit?
  • is data encrypted at rest where needed?
  • does data avoid leaking into logs?
  • is data deleted securely?

Integrations and API

  • does the integration have minimum necessary permissions?
  • does the API have rate limits?
  • does the API validate input?
  • do API errors avoid disclosing information?
  • is the external provider integration monitored?

Monitoring and response

  • are important security events logged?
  • do we have alerts for high-risk actions?
  • can we reconstruct who performed an action?
  • do we know how to detect feature abuse?
  • does the team know how to respond to an incident?

Threat modeling for SaaS: what to watch for

Multi-tenancy

In SaaS, customer data separation is critical. One of the most important questions is: can customer A accidentally or intentionally see customer B’s data?

Check:

  • tenant identifier in every request
  • object-level access control
  • data separation in the database
  • exports and reports
  • logs and diagnostic data
  • support administrator access

Administrator panel

The administrator panel is often high risk because it provides broad permissions. The model should check who can access it, how it is protected and what actions can be performed from it.

Check:

  • MFA for administrators
  • roles and permissions
  • administrator action logging
  • approval for high-risk actions
  • protection against session takeover

APIs and integrations

In SaaS, APIs are often the main attack surface. Authorization errors, no rate limits, overly broad tokens and unsafe integrations can lead to serious incidents.

AI and automation

If the product uses AI or agents that automate actions, threat modeling should include new risks: prompt injection, data disclosure from context, excessive agent permissions and overreliance on AI output.

What documents and evidence should be prepared?

Input documents

  • feature description
  • architecture diagram
  • data flow diagram
  • user and role list
  • data classification
  • integration description
  • customer or regulatory requirements

Session outputs

  • threat list
  • risk assessment
  • response decisions
  • security requirements
  • backlog tasks
  • security tests
  • accepted risks
  • owners and deadlines

Evidence for audit or customers

  • session date
  • participants
  • modeling scope
  • system diagram
  • risk and decision list
  • remediation tasks
  • implementation status
  • confirmation that the model was reviewed after changes

Common threat modeling mistakes

Mistake 1: doing threat modeling too late

If threat modeling happens after the feature is built, the team may discover problems that require major architecture changes. It is better to do it early.

Mistake 2: scope too broad

Trying to model the entire platform in one session usually leads to shallow analysis. It is better to model smaller parts more thoroughly.

Mistake 3: no business and product people

Security and developers may not know the full business context. Product owners help explain how the feature should work, what matters to customers and which risks are most important.

Mistake 4: focusing only on tools

Tools can help, but they do not replace thinking. Threat modeling is mainly about conversation, understanding the system and making decisions.

Mistake 5: no tasks after the session

If the session produces no tasks, requirements or tests, threat modeling does not affect the product. Outputs must enter the development process.

Mistake 6: no model updates

The product changes. The threat model should be updated after major architecture changes, new integrations, new data types and new high-risk features.

Mistake 7: searching for the perfect diagram

The diagram should support the conversation, not become a work of art. A simple diagram the team understands is better than a perfect model nobody uses.

30, 60 and 90-day threat modeling implementation plan

First 30 days

  • choose an owner for the threat modeling process
  • select one product or feature for a pilot
  • prepare a simple session template
  • prepare a data flow diagram template
  • train 1-2 people in STRIDE basics
  • run the first 90-minute session
  • turn outputs into backlog tasks

Days 31 to 60

  • repeat the session for another high-risk feature
  • add threat modeling to the definition of ready for high-risk features
  • connect outputs with security requirements
  • connect outputs with security tests
  • prepare a product risk register
  • define how risk acceptance works

Days 61 to 90

  • embed threat modeling into Secure SDLC
  • prepare a library of common threats for the product
  • create a checklist for product owners and developers
  • define process metrics
  • prepare an evidence pack for customers and audits
  • plan quarterly review of the most important models

How to measure threat modeling effectiveness

Process metrics

  • number of sessions completed
  • percentage of high-risk features covered by threat modeling
  • number of products with a current threat model
  • time from session to task creation
  • percentage of tasks completed on time

Quality metrics

  • number of meaningful threats found before development
  • number of security requirements resulting from modeling
  • number of security tests added after the session
  • number of risks accepted by a business owner
  • number of recurring design issues

Business metrics

  • fewer critical issues found just before release
  • faster answers to customer security questionnaires
  • better audit evidence
  • fewer expensive architecture changes after deployment

Business example

A SaaS company is planning a new customer data export feature through API. The feature will allow customers to download large reports and integrate with external analytics systems.

The product team organizes a 90-minute threat modeling session. The diagram shows the user, API, authorization service, database, job queue, file storage and external customer system.

During the session, the team identifies several risks: a customer may download another customer’s report, the API token may have overly broad permissions, the export may reveal data in logs, the feature may be abused to overload the system and the report link may remain valid for too long.

The session outputs go into the backlog: object-level access control, shorter link lifetime, rate limiting, removal of sensitive data from logs, authorization tests and monitoring of unusual exports.

As a result, the team finds problems before most of the code is written. A later penetration test confirms that the key risks were already reduced during design.

How can ccyber.io help?

ccyber.io helps product teams, software houses and SaaS companies run threat modeling in a practical, lightweight way connected with the team’s real work.

We can support your organization with:

  • threat modeling workshop for a product or feature
  • threat modeling for SaaS, API, AI and integrations
  • data flow diagram preparation
  • STRIDE session facilitation
  • turning risks into requirements and backlog tasks
  • checklists for product teams
  • embedding threat modeling into Secure SDLC
  • training for product owners, developers and architects
  • evidence preparation for customers, audits or CRA
  • review of existing threat models

The best first step is a pilot workshop for one high-risk feature. This lets the team quickly see the value of the method and implement a simple, repeatable process without unnecessary bureaucracy.

FAQ

Is threat modeling only for security teams?

No. The best threat modeling involves product owners, developers, architects, DevOps, testers and security. Security can facilitate, but product and technology context must come from the team.

Is a special tool required?

No. At the beginning, a diagram, whiteboard, document and simple template are enough. Tools can help later when the company wants more repeatability and scale.

How long should a good threat modeling session take?

For one high-risk feature, 60-90 minutes is often enough. For a larger system, it is better to run several smaller sessions than one very long meeting.

Is STRIDE mandatory?

No. STRIDE is a popular and practical structure, but it is not the only method. Teams can also use other approaches, checklists, attack scenarios, MITRE ATT&CK, OWASP ASVS or a custom method suited to the organization.

When should threat modeling be done?

It should be done before development of high-risk features, during architecture changes, new integrations, new data flows, AI features, administrator panels and APIs.

What should be the output of a session?

The output should include concrete threats, risk assessment, decisions, security requirements, backlog tasks, tests, owners and deadlines.

Does threat modeling help with CRA?

Yes. CRA requires product security across the lifecycle. Threat modeling helps prepare product risk assessment, security requirements, documentation and design evidence.

Does threat modeling replace penetration testing?

No. Threat modeling does not replace testing. It helps find problems earlier and plan tests better. The best approach combines threat modeling, code review, automated testing and manual testing.

Summary

Threat modeling is one of the most practical tools for product teams that want to build more secure software without waiting for a penetration test at the end of the project.

The key is a simple approach: define scope, understand the system, mark data and trust boundaries, identify threats, choose responses, turn outputs into tasks and return to the model when major changes happen.

Good threat modeling does not create documentation for its own sake. It creates better product decisions, better security requirements, better tests and lower risk for customers and the company.

Sources

Secure SDLC Checklist for SaaS Companies and Software Houses

Secure SDLC helps SaaS companies and software houses build security into the entire software development lifecycle: from requirements and architecture, through coding, testing and CI/CD, to release, monitoring, updates and vulnerability handling. Use this practical checklist to reduce risk, prepare evidence and meet customer and regulatory requirements.

Prepared by: CCyber Editorial Team

Short answer

Secure SDLC is a secure software development lifecycle, meaning an approach where security is present from requirements and architecture to deployment, monitoring, updates and vulnerability handling. SaaS companies and software houses should start with a checklist covering product security ownership, security requirements, threat modeling, coding standards, code reviews, SAST, DAST and SCA testing, SBOM, CI/CD security, secrets management, vulnerability management and evidence.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies
  • web and mobile application companies
  • product teams
  • CTOs, Heads of Engineering and technical leaders
  • DevOps and DevSecOps teams
  • developers and architects
  • CISOs and application security leaders
  • product owners and project managers
  • companies preparing for CRA, ISO/IEC 27001, SOC 2, NIS2 or customer requirements

Key takeaways

  1. Secure SDLC is not a one-time security test before release. It is a way of working across the full product lifecycle.
  2. The highest impact comes from introducing security early: requirements, architecture, threat modeling and secure coding standards.
  3. SaaS companies should pay particular attention to identity, access, customer data, APIs, cloud environments, CI/CD, dependencies and monitoring.
  4. Software houses should be able to show customers evidence: test results, code reviews, SBOM, vulnerability handling procedure, secrets policy and security reports.
  5. The best first step is a practical 30, 60 and 90-day checklist, rather than building an overly heavy process immediately.

What is Secure SDLC?

Secure SDLC means secure software development lifecycle. It means embedding security into every stage of product development: idea, requirements, architecture, development, testing, deployment, maintenance, updates and vulnerability handling.

In practice, Secure SDLC answers the following questions:

  • does the product have security requirements?
  • has the architecture been assessed for risk?
  • has the team performed threat modeling?
  • is code reviewed for security?
  • are dependencies and libraries controlled?
  • are secrets kept out of repositories?
  • is the CI/CD pipeline secured?
  • does the product have an SBOM?
  • are vulnerabilities handled after release?
  • does the company have evidence it can show to a customer or auditor?

Secure SDLC does not have to slow development down. Implemented well, it reduces chaos, limits late-stage rework and helps find problems earlier, when they are cheaper to fix.

Why is Secure SDLC especially important for SaaS companies and software houses?

SaaS companies and software houses build software that often processes customer data, integrates with external systems, uses cloud, APIs, open-source components and automated deployments. This creates a large attack surface.

Customers increasingly expect not only a statement that “we care about security”, but specific evidence:

  • has the application been tested?
  • are known vulnerabilities monitored?
  • is customer data separated?
  • is administrative access controlled?
  • is there a vulnerability disclosure process?
  • does the team perform code reviews?
  • is an SBOM available?
  • does the company have a secure update process?

Secure SDLC is also increasingly important from a regulatory perspective. The Cyber Resilience Act introduces cybersecurity requirements for products with digital elements, and customers covered by NIS2, DORA or ISO/IEC 27001 may transfer security requirements to technology suppliers.

Secure SDLC checklist: 16 steps for SaaS and software houses

Step 1: assign a product security owner

Product security cannot belong to nobody. The company should have an owner for application or product security. In a small company, this does not need to be a separate department, but responsibility must be clear.

The owner should coordinate:

  • security requirements
  • threat modeling
  • coding standards
  • security testing
  • vulnerability handling
  • communication with customers and auditors
  • product security evidence

Evidence to prepare: decision naming the product security owner, responsibility scope and supporting team list.

Step 2: create a register of products, repositories and components

You cannot secure a product that is not described clearly. SaaS companies and software houses should maintain a list of products, repositories, applications, APIs, services, libraries, components and environments.

The register should include:

  • product or application name
  • business owner
  • technical owner
  • code repositories
  • main technologies
  • environments: development, test, staging, production
  • external integrations
  • APIs
  • open-source components
  • data processed by the system
  • criticality classification

Evidence to prepare: product and repository register with owners and criticality classification.

Step 3: define security requirements

Security should not be an add-on to functionality. It should be part of requirements. Product owners, architects, developers and security should know what security requirements the product must meet.

Example requirements:

  • authentication and MFA for high-risk roles
  • authorization controls
  • customer data separation
  • encryption in transit and at rest
  • secure session handling
  • protection against common application vulnerabilities
  • security event logging
  • secure password reset
  • administrative access control
  • privacy and data retention requirements

Evidence to prepare: product security requirements linked to backlog, risk and tests.

Step 4: perform threat modeling for high-risk features

Threat modeling helps the team answer: what can go wrong and how can we prevent it? Not everything needs to be modeled immediately. Start with high-risk features.

Threat modeling is useful for:

  • login and account management
  • administrator panel
  • payments
  • APIs
  • data import and export
  • customer system integrations
  • features processing sensitive data
  • multi-tenant SaaS mechanisms
  • AI or automation features

The output should be concrete requirements, backlog tasks and tests.

Evidence to prepare: data flow diagram, threat list, control decisions and remediation tasks.

Step 5: implement a secure coding standard

A secure coding standard should be simple, practical and aligned with the technologies used by the team. It should not be a document nobody reads.

The standard should cover:

  • input validation
  • secure error handling
  • injection prevention
  • secure session management
  • authorization control
  • secure file operations
  • encryption and use of proven cryptographic libraries
  • avoiding secrets in code
  • secure event logging
  • safe use of third-party components

Evidence to prepare: coding standard, pull request checklists and team training confirmation.

Step 6: control secrets, keys and tokens

Passwords, API keys, tokens, certificates and other secrets should not end up in code repositories, tickets, documentation, chat tools or unprotected configuration files.

Minimum rules:

  • secrets are stored in a secrets vault
  • secrets are not committed to repositories
  • repositories are scanned for secrets
  • secrets are rotated after incidents or supplier changes
  • access to secrets is role-based
  • production secrets are not used in test environments

Evidence to prepare: secrets policy, vault configuration, scanning results and rotation register.

Step 7: manage dependencies and open-source components

Modern applications use many libraries and packages. This accelerates work, but introduces software supply chain risk.

The company should know:

  • which components are used
  • which versions they have
  • whether they have known vulnerabilities
  • whether they are still maintained
  • which licenses they use
  • whether they come from trusted sources
  • how quickly they can be updated

Evidence to prepare: dependency register, SCA results and procedure for updating vulnerable components.

Step 8: prepare SBOM for products

SBOM, or Software Bill of Materials, helps show what the product is made of. It is important for supply chain security, CRA, customer discussions and rapid response to new vulnerabilities.

A good SBOM should be:

  • generated automatically where possible
  • linked to a specific product version
  • updated when dependencies change
  • stored as release evidence
  • usable for vulnerability analysis

Evidence to prepare: SBOM for the main product and the SBOM update process.

Step 9: secure code repositories

The code repository is one of the most important assets of a technology company. Repository compromise can lead to source code leakage, secret exposure, code tampering or attacks on customers.

Minimum controls:

  • MFA for all developer accounts
  • special protection for repository administrator accounts
  • access reviews
  • protected main branches
  • required pull request reviews
  • blocking direct changes to production branches
  • secret scanning
  • access and change logs

Evidence to prepare: repository configuration, MFA status, branch protection rules and access review report.

Step 10: secure CI/CD and the build process

The CI/CD pipeline can become an attack path into the product. If an attacker compromises the build or deployment process, they may introduce malicious code into a legitimate product release.

Control:

  • who can change the pipeline
  • who can deploy to production
  • where CI/CD secrets are stored
  • whether builds are repeatable and identifiable
  • whether artifacts are signed
  • whether dependencies come from trusted sources
  • whether environments are separated
  • whether deployment logs are available for audit

Evidence to prepare: pipeline documentation, permission list, secrets configuration, deployment logs and production approval rules.

Step 11: integrate SAST, DAST and SCA into the process

Security testing should be part of the development process, not only a pre-release activity. For SaaS companies and software houses, the minimum baseline is a combination of several testing methods.

In practice:

  • SAST analyzes source code or intermediate code
  • DAST tests a running application
  • SCA checks dependencies and open-source components
  • secret scanning detects accidentally exposed passwords and keys
  • API testing checks interface security
  • configuration testing checks environments and cloud

Not every tool warning is critical. A triage process is needed to decide which findings are real and require remediation.

Evidence to prepare: SAST, DAST, SCA and secret scanning results, triage decisions and remediation status.

Step 12: test APIs and access control

In SaaS products, API is often the most important attack surface. Authorization, object access control, rate limits and customer data separation issues can lead to serious incidents.

API testing should cover:

  • authentication
  • authorization
  • access to another user’s or customer’s objects
  • rate limits
  • input validation
  • error handling
  • security event logging
  • secure token management

Evidence to prepare: API test plan, test results, vulnerabilities and remediation confirmation.

Step 13: secure environments and configuration

Configuration errors are one of the most common causes of incidents in cloud and SaaS services. Development, test and production environments should be separated and managed according to clear rules.

Check:

  • whether environments are separated
  • whether production data is not uncontrolled in test environments
  • whether configuration is versioned
  • whether infrastructure as code is reviewed
  • whether production access is limited
  • whether cloud misconfigurations are detected
  • whether production changes require approval

Evidence to prepare: environment standard, configuration review results and production access control report.

Step 14: log security events and monitor the product

The product should generate logs that help detect incidents, analyze events and prove what happened. No logs means no visibility.

Useful events to log:

  • logins and failed login attempts
  • permission changes
  • administrator actions
  • access to sensitive data
  • configuration changes
  • authorization failures
  • suspicious API usage
  • high-risk actions

Logs must be protected from tampering, available for analysis and retained according to company rules and customer requirements.

Evidence to prepare: list of logged events, log retention, alerts and monitoring report.

Step 15: prepare a vulnerability management process

Vulnerabilities do not end on release day. The company must have a process for receiving reports, assessing issues, fixing them, communicating and documenting them.

The process should include:

  • vulnerability reporting channel
  • triage procedure
  • severity assessment
  • remediation priorities
  • deadlines for critical issues
  • customer communication
  • retesting after remediation
  • vulnerability register

Evidence to prepare: vulnerability management procedure, vulnerability register, remediation status and retest reports.

Step 16: prepare security evidence for customers and audits

A good Secure SDLC checklist ends with evidence. Customers, auditors and regulators increasingly ask not only whether the company “does security”, but whether it can prove it.

Key evidence:

  • secure software development policy
  • product security requirements
  • threat modeling results
  • code review results
  • SAST, DAST and SCA results
  • SBOM
  • penetration test reports
  • vulnerability register
  • vulnerability disclosure procedure
  • remediation and retest evidence
  • deployment and production approval logs

Evidence to prepare: Secure SDLC evidence pack ready for customers, audits or conformity assessment.

30, 60 and 90-day Secure SDLC implementation plan

First 30 days

  • assign a product security owner
  • create a register of products, repositories and applications
  • review access to repositories and CI/CD
  • enable MFA for developers and administrators
  • define basic security requirements
  • enable secret scanning
  • start dependency scanning
  • select one product or application for a Secure SDLC pilot

Days 31 to 60

  • perform threat modeling for high-risk features
  • prepare a secure coding standard
  • add a security checklist to pull request reviews
  • enable basic SAST and SCA tests in CI/CD
  • prepare the first SBOM version
  • review environment configuration
  • prepare the vulnerability management process

Days 61 to 90

  • add DAST or API testing for the pilot application
  • define minimum product security logs
  • prepare a vulnerability disclosure procedure
  • run training for the development team
  • prepare an evidence pack for a customer or audit
  • define Secure SDLC metrics
  • prepare a plan to expand the process to additional products

Minimum Secure SDLC evidence pack

Governance documents

  • secure software development policy
  • roles and responsibilities
  • secure coding standard
  • secrets management rules
  • dependency management rules
  • vulnerability handling process

Technical evidence

  • product and repository register
  • SBOM
  • SAST results
  • DAST results
  • SCA results
  • secret scanning results
  • API testing reports
  • cloud configuration review reports

Process evidence

  • threat modeling
  • approved security requirements
  • code reviews
  • production deployment approvals
  • vulnerability register
  • remediation evidence
  • retests
  • post-incident reports

Common Secure SDLC implementation mistakes

Mistake 1: security testing only before production

If security appears only at the end, the team has little time for fixes and costs increase. Security should be part of requirements, design and daily work.

Mistake 2: too much process at the beginning

A small software house does not need to build a large corporate programme immediately. It is better to start with a minimum that works and gradually increase maturity.

Mistake 3: no owner

If nobody owns Secure SDLC, security tasks will be postponed. The owner does not need to do everything alone, but must coordinate the process.

Mistake 4: ignoring CI/CD

The modern delivery process is a critical security element. A compromised pipeline can be as dangerous as an application vulnerability.

Mistake 5: no control over dependencies

An application may be well written and still vulnerable because of a library, package or third-party component. That is why SCA and SBOM matter.

Mistake 6: no post-release vulnerability handling

A product’s life does not end on deployment day. Vulnerabilities will appear later, so the company needs a process for detection, assessment, remediation and communication.

Mistake 7: no evidence

The team may do many good things, but without evidence it is hard to show maturity to a customer, auditor or regulator.

How to measure Secure SDLC?

Process metrics

  • percentage of products with a security owner
  • percentage of products with security requirements
  • number of threat models completed
  • percentage of repositories with branch protection
  • percentage of pipelines covered by security tests

Vulnerability metrics

  • number of critical and high vulnerabilities
  • mean time to remediate vulnerabilities
  • number of recurring vulnerabilities
  • percentage of vulnerabilities remediated on time
  • number of vulnerable dependencies

Evidence metrics

  • number of products with SBOM
  • number of products with current security documentation
  • number of code reviews with security checklist
  • number of security testing reports
  • number of products with a vulnerability disclosure process

Business example

A SaaS company develops a platform for B2B customers. It has several development teams, fast deployments, many API integrations, a cloud environment and increasing customer security requirements.

Until now, security was based mainly on annual penetration testing. After each test, the team received a long list of vulnerabilities that had to be fixed under time pressure.

After implementing Secure SDLC basics, the company changes its approach. It introduces security requirements into the backlog, performs threat modeling for high-risk features, adds secret and dependency scanning to CI/CD, prepares an SBOM and creates a vulnerability handling process.

After 90 days, the company is not “perfectly secure”, but it has much better control. It knows which products are critical, which vulnerabilities are open, which dependencies are used and what evidence it can show to customers.

How can ccyber.io help?

ccyber.io helps SaaS companies and software houses implement Secure SDLC in a practical, lightweight way aligned with how development teams actually work.

We can support your organization with:

  • Secure SDLC maturity assessment
  • software development process gap analysis
  • threat modeling
  • product security requirements preparation
  • security checklist implementation for teams
  • CI/CD and repository review
  • SBOM and dependency management process preparation
  • vulnerability management process
  • evidence preparation for customers, audits or CRA
  • Secure SDLC training for developers, DevOps and product owners

The best first step is a short Secure SDLC assessment. It helps identify which parts of the process already work, where the biggest gaps are and what should be implemented in the first 30, 60 and 90 days.

FAQ

Is Secure SDLC only for large companies?

No. Small and medium-sized companies can also implement Secure SDLC, but they should start with simple practices: security requirements, code reviews, dependency scanning, secrets control and vulnerability handling.

Is a penetration test enough?

No. Penetration testing is important, but it does not replace a secure development process. Secure SDLC helps find and fix issues earlier, before they reach production.

Where should Secure SDLC start?

The best starting point is a product register, security owner, security requirements, repository control, secret and dependency scanning and a pilot on one product.

How is Secure SDLC different from DevSecOps?

Secure SDLC describes the full secure software development lifecycle. DevSecOps is a practical way of embedding security into DevOps work, automation, CI/CD, testing and deployment.

Does every SaaS company need an SBOM?

SBOM is increasingly useful, especially for companies selling software to B2B customers, preparing for CRA, serving regulated sectors or managing many open-source components.

Does Secure SDLC help with the Cyber Resilience Act?

Yes. Secure SDLC helps prepare processes and evidence needed for product security: risk assessment, security requirements, testing, vulnerability management, SBOM, documentation and updates.

How often should threat modeling be performed?

Threat modeling should be performed for new high-risk features, major architecture changes, new integrations, new data types and changes affecting access or permissions.

What tools are needed at the beginning?

At the beginning, tools for secret scanning, dependency scanning, code scanning, configuration scanning and application testing are usually enough, combined with a code review and vulnerability management process. Tools should support the process, not replace risk thinking.

Summary

Secure SDLC for SaaS companies and software houses should not be a heavy bureaucratic process. It should be a practical checklist of actions that help build safer products and respond faster to customer, audit and regulatory requirements.

The most important elements are security requirements, threat modeling, secure coding, secrets control, dependency management, SBOM, repository and CI/CD security, security testing, vulnerability management and evidence.

Companies that implement Secure SDLC early reduce technical risk, limit the cost of late fixes and build a sales advantage as more trustworthy software suppliers.

Sources

Cyber Resilience Act for Software Houses: What Should Be Prepared in 2026 and 2027?

The Cyber Resilience Act turns digital product cybersecurity from a best practice into a regulatory obligation. Software houses should prepare product risk assessment, secure development lifecycle, vulnerability management, technical documentation, SBOM, update process, incident reporting and a compliance roadmap for 2026 and 2027.

Prepared by: CCyber Editorial Team

Short answer

A software house should start preparing for the Cyber Resilience Act by checking whether the software it develops is a product with digital elements made available on the EU market and what role the company plays: manufacturer, subcontractor, component provider or service provider. In 2026, the key priorities are vulnerability handling and reporting processes, product cybersecurity risk assessment, secure software development lifecycle, technical documentation, SBOM, update rules and a compliance plan before the main CRA obligations apply in 2027.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies
  • web and mobile application vendors
  • companies developing software under their own brand
  • companies developing components, libraries, SDKs or APIs
  • IoT, embedded and hardware manufacturers with software
  • CTOs, Heads of Engineering and product security leaders
  • DevOps, DevSecOps and security teams
  • boards of technology companies
  • companies preparing for CRA, NIS2, ISO/IEC 27001 or customer requirements

Key takeaways

  1. CRA applies to products with digital elements, including software and hardware with a logical or physical connection to a device or network.
  2. A software house must first determine whether it is a manufacturer under CRA or a subcontractor developing software for another entity.
  3. From 11 September 2026, reporting obligations begin for actively exploited vulnerabilities and severe incidents affecting the security of the product.
  4. From 11 December 2027, most CRA requirements will apply, including obligations related to design, development, documentation, conformity assessment, CE marking and vulnerability handling.
  5. The best preparation is to implement secure software development, vulnerability management, SBOM, security testing, vulnerability disclosure and product documentation.

What is the Cyber Resilience Act?

The Cyber Resilience Act, or CRA, is an EU regulation introducing cybersecurity requirements for products with digital elements. Its goal is to increase the security of products available on the EU market and ensure that vulnerabilities are handled throughout the product support period.

In practice, CRA means that cybersecurity of a digital product cannot be added at the end of the project. It must be included in planning, design, development, testing, release, updates, vulnerability handling and user communication.

For software houses, CRA matters because many technology companies no longer sell only “software development services”. They build applications, components, platforms, SaaS products, integrations, libraries, modules, firmware, mobile applications, IoT systems or software made available on the market under their own brand or a customer’s brand.

Does CRA apply to software houses?

First determine the company’s role

The key question is not “do we develop software?”, but “do we make a product with digital elements available on the EU market under our own name or trademark?”.

A software house may act in different roles:

  • manufacturer of a digital product under its own brand
  • provider of a software component
  • subcontractor developing a product for a customer
  • provider of product maintenance and development services
  • SaaS provider
  • provider of a library, SDK, API or module
  • integrator combining components into the final product

If the company only develops software for a customer, and the customer places the product on the market under its own brand, manufacturer obligations may primarily apply to the customer. This does not mean that the software house can ignore CRA. The customer will likely transfer part of the requirements to the supplier through contracts, development processes, documentation, testing, vulnerability handling and security evidence.

Check whether the product is a product with digital elements

CRA covers products with digital elements, meaning software or hardware and related remote data processing solutions, if the product is made available on the EU market and its intended or reasonably foreseeable use includes connection to a device or network.

Examples that may require CRA analysis:

  • desktop application
  • mobile application
  • locally installed software
  • firmware
  • IoT device with software
  • component or library made available separately
  • operating system or administration tool
  • cloud solution linked to a digital product function
  • SaaS product if it is linked to a product with digital elements or meets conditions for being within CRA scope

The fact that a company develops software does not automatically mean that CRA applies. Each case should be assessed based on the business model, product availability, company role, product type and customer contracts.

Key dates: 2026 and 2027

11 June 2026

From this date, provisions concerning conformity assessment bodies apply. For a software house, this matters mainly if a product requires the involvement of a notified body or belongs to an important or critical product category.

11 September 2026

From this date, reporting obligations apply for actively exploited vulnerabilities and severe incidents affecting the security of products with digital elements.

In practice, the manufacturer should have a process for:

  • detecting vulnerabilities
  • receiving reports from researchers and customers
  • assessing whether a vulnerability is actively exploited
  • assessing whether an incident is severe
  • reporting through the SRP platform
  • communicating with CSIRT and ENISA
  • documenting decisions and deadlines

11 December 2027

From this date, most CRA requirements will apply. Products covered by CRA will need to meet cybersecurity requirements, undergo the appropriate conformity assessment, have technical documentation, an EU declaration of conformity, CE marking and a defined support period.

What should be prepared in 2026?

1. Product and responsibility map

A software house should start with a map of products and roles. Without this, it is difficult to determine which obligations apply directly to the company and which will result from customer contracts.

Check:

  • which products the company sells under its own brand
  • which products it develops for customers
  • which components it makes available separately
  • which products are available on the EU market
  • which products connect to a device or network
  • which products include open-source components
  • which products have security functions
  • which products may be important or critical

Evidence to prepare: product register, product owner, company role, market, product type, availability model and initial CRA classification.

2. Product cybersecurity risk assessment

CRA requires a risk-based approach. The manufacturer should assess the cybersecurity risks of the product and use the outcome of that assessment in design, development, delivery and maintenance.

The risk assessment should cover:

  • product architecture
  • data processed by the product
  • users and roles
  • administrative access
  • integrations
  • third-party components
  • attack surface
  • possible impact of compromise
  • risks to users and customers
  • support and update period

Evidence to prepare: product risk assessment report and list of security requirements resulting from the assessment.

3. Secure software development lifecycle

A software house should organize the development process so that security is part of daily work, not a one-off test before release.

A secure development lifecycle should include:

  • security requirements during analysis
  • threat modeling for high-risk features
  • secure coding standards
  • security-focused code review
  • automated security tests in CI/CD
  • dependency management
  • application and API testing
  • secrets and key control
  • secure releases
  • post-release vulnerability monitoring

Evidence to prepare: secure software development process description, procedures, checklists and test results.

4. Vulnerability management process

CRA strengthens manufacturer obligations for vulnerability handling. The company needs a process to detect, analyze, prioritize, fix and communicate vulnerabilities.

The process should define:

  • where vulnerability reports are received
  • who analyzes them
  • how vulnerability severity is assessed
  • how remediation priority is set
  • who decides on security updates
  • how users are informed
  • when a vulnerability must be reported under CRA
  • how actions are documented

Evidence to prepare: vulnerability management procedure, vulnerability register, remediation status and reporting decisions.

5. Coordinated vulnerability disclosure process

The company should allow customers, security researchers and users to report vulnerabilities in a controlled way. In practice, this means preparing a clear contact channel, handling rules and internal responsibilities.

Prepare:

  • email address for vulnerability reports
  • security.txt page
  • coordinated vulnerability disclosure policy
  • report acknowledgement process
  • internal issue handling system
  • communication rules with researchers
  • process for publishing security update information

Evidence to prepare: vulnerability disclosure policy, contact channel, report register and handling metrics.

6. SBOM and component control

SBOM, or Software Bill of Materials, helps determine which libraries, packages and components make up the product. It is important for vulnerability management, software supply chain security and rapid response to new vulnerabilities in components.

A software house should know:

  • which components are used in the product
  • which versions they have
  • which licenses they use
  • whether they contain known vulnerabilities
  • whether they are maintained
  • whether they have critical dependencies
  • how quickly the impact of a new vulnerability can be assessed

Evidence to prepare: product SBOM, SBOM update process and link with vulnerability management.

7. Product technical documentation

Technical documentation is one of the most important elements of CRA preparation. It should show that the product meets cybersecurity requirements and that the company can prove it.

Documentation may include:

  • product description
  • architecture
  • threat model
  • cybersecurity risk assessment
  • security requirements
  • implemented controls
  • test results
  • update process
  • vulnerability management process
  • support period
  • user information
  • EU declaration of conformity, if applicable

Evidence to prepare: complete product technical documentation aligned with CRA requirements and ready to be shown to market surveillance authorities.

8. Vulnerability and incident reporting process

From 11 September 2026, manufacturers will have to report actively exploited vulnerabilities and severe incidents affecting the security of products with digital elements.

The company should have a process that answers:

  • who assesses whether a vulnerability is actively exploited?
  • who assesses whether an incident is severe?
  • who is responsible for reporting?
  • where is technical information collected?
  • how are the 24-hour, 72-hour and final report deadlines tracked?
  • who communicates with customers?
  • who approves communications?

Evidence to prepare: CRA reporting procedure, roles, note templates, escalation path and reporting register.

What should be prepared in 2027?

1. Full product readiness for CRA requirements

In 2027, the company should move from planning to full readiness. The product should have implemented security requirements, an update process, technical documentation and test evidence.

Key readiness elements:

  • product risk assessment
  • implemented security requirements
  • security testing
  • vulnerability handling
  • SBOM
  • technical documentation
  • user instructions
  • support period
  • update process
  • reporting process

2. Conformity assessment

Before placing the product on the market, the manufacturer should perform the appropriate conformity assessment. For many products, self-assessment may be possible, but some important or critical product categories may require a stricter route, including involvement of a notified body.

The software house should check:

  • which category the product belongs to
  • whether self-assessment is possible
  • whether harmonized standards should be applied
  • whether a notified body is required
  • what evidence must be prepared
  • who approves the declaration of conformity

3. Declaration of conformity and CE marking

For products covered by CRA, the manufacturer should prepare an EU declaration of conformity and affix CE marking if the product meets the requirements. This requires earlier preparation of documentation, testing, risk assessment and evidence of conformity.

4. Operational readiness after product release

CRA does not end on release day. The manufacturer must handle vulnerabilities and updates during the support period. This requires people, process, tools and budget.

In 2027, the company should have ready:

  • team responsible for product security
  • security update process
  • component vulnerability monitoring
  • vulnerability reporting channel
  • user communication procedure
  • vulnerability and incident register
  • response and remediation metrics

30, 60 and 90-day preparation plan

First 30 days

  • appoint a CRA preparation owner
  • list products and components
  • define the company’s role for each product
  • check which products may be covered by CRA
  • identify high-risk products
  • check whether a vulnerability handling process exists
  • check whether SBOM is generated for the product
  • plan a CRA gap analysis

Days 31 to 60

  • perform risk assessment for key products
  • prepare the security requirements map
  • launch the coordinated vulnerability disclosure process
  • start building technical documentation
  • review dependencies and third-party components
  • define the security update process
  • review customer contract requirements
  • determine whether the product requires special conformity assessment

Days 61 to 90

  • implement security testing in the development process
  • prepare a product risk report template
  • prepare a technical documentation template
  • prepare the CRA reporting procedure
  • test the vulnerability handling process
  • prepare the 2027 action plan
  • train product, development and support teams
  • prepare a board report

CRA checklist for software houses

Scope and role

  • do we have a list of digital products?
  • do we know which products are made available on the EU market?
  • do we know where we are the manufacturer and where we are a subcontractor?
  • do we know obligations resulting from customer contracts?
  • do we know which products may be important or critical?

Secure development

  • do we have product security requirements?
  • do we perform threat modeling?
  • do we perform code reviews?
  • do we test applications and APIs?
  • do we check secrets in code?
  • do we monitor dependency vulnerabilities?
  • is security part of the CI/CD process?

Vulnerabilities and updates

  • do we have a process for receiving vulnerability reports?
  • do we have a vulnerability register?
  • do we know how to prioritize vulnerabilities?
  • do we have a security update process?
  • do users receive information about updates?
  • do we know the product support period?

Documentation and evidence

  • do we have a product risk assessment?
  • do we have technical documentation?
  • do we have an SBOM?
  • do we have security test results?
  • do we have evidence of meeting security requirements?
  • do we have user instructions?
  • do we have a conformity assessment process?

Common CRA mistakes made by software houses

Mistake 1: waiting until 2027

Most obligations apply in 2027, but reporting obligations begin earlier. In addition, preparing processes, documentation and tests can take many months.

Mistake 2: treating CRA as a legal topic only

CRA has legal consequences, but the challenge is also technical and organizational. Lawyers can help interpret the regulation, but product, technical and security teams must implement processes.

Mistake 3: unclear role in a customer project

If a software house develops a product for a customer, it must be clear who is responsible for risk assessment, technical documentation, testing, SBOM, vulnerability handling and product conformity.

Mistake 4: no SBOM and no dependency control

Modern digital products use many external libraries and components. Without an SBOM, it is difficult to quickly assess whether a new vulnerability affects the product.

Mistake 5: security testing only at the end of the project

If security testing appears only before release, fixing issues is more expensive and harder. Security should be part of the entire product lifecycle.

Mistake 6: no post-release process

The product must be maintained after release. Updates, reports, vulnerability monitoring, user communication and documentation are required.

Mistake 7: no evidence

Even if the team follows good practices, it must be able to show them. Lack of documentation, registers and test results weakens readiness for conformity assessment, customer discussions and controls.

What documents and evidence should be prepared?

Product documents

  • product description
  • product architecture
  • list of security features
  • threat model
  • cybersecurity risk assessment
  • security requirements
  • support period
  • user instructions

Development process documents

  • secure software development policy
  • code review procedure
  • security testing procedure
  • dependency management procedure
  • secrets management procedure
  • release and update process
  • risk acceptance process

Vulnerability handling documents

  • coordinated vulnerability disclosure policy
  • vulnerability register
  • triage procedure
  • escalation procedure
  • user communication procedure
  • CRA reporting procedure
  • security advisory templates

Technical evidence

  • SBOM
  • dependency scan results
  • application test results
  • API test results
  • code review results
  • penetration test reports
  • evidence of vulnerability remediation
  • security update history

Business example

A software house develops a SaaS platform for B2B customers. The product includes a web application, API, customer integrations, mobile application and a component installed in the customer environment. Until now, the company focused on features and delivery time, while security was checked mainly through periodic penetration tests.

After an initial CRA analysis, the company discovers that it needs to organize much more than a security test. It needs a product register, risk assessment, threat modeling, SBOM, vulnerability handling process, reporting procedure, technical documentation and update rules.

The biggest change is not buying a new tool. The biggest change is moving from “testing before release” to “security is part of the entire product lifecycle”.

Within 90 days, the company can prepare the foundation: product map, risk assessment, vulnerability reporting process, SBOM for the main product, basic technical documentation and an action plan for 2027.

How can ccyber.io help?

ccyber.io helps software houses and product companies prepare for the Cyber Resilience Act in a practical, technical and business-focused way. We do not limit the work to regulatory interpretation. We help translate CRA into processes, documentation, testing and evidence.

We can support your organization with:

  • CRA readiness assessment
  • digital product gap analysis
  • product and manufacturer role mapping
  • product cybersecurity risk assessment
  • threat modeling
  • secure software development lifecycle implementation
  • vulnerability handling process preparation
  • SBOM and dependency control preparation
  • technical documentation review
  • training for development and product teams
  • 2026 and 2027 preparation plan

The best first step is a short CRA readiness workshop. It helps determine which products may be covered by CRA, what role the company plays, what evidence already exists and what actions should be completed before the 2026 and 2027 deadlines.

FAQ

Does CRA apply to software houses?

It may apply. If a software house places a product with digital elements on the EU market under its own brand, it may act as a manufacturer. If it develops a product for a customer, requirements may be transferred contractually by the customer.

Does CRA apply to SaaS?

It depends on the product model and service delivery. CRA may cover related remote data processing solutions if they are necessary for the function of a product with digital elements. Each SaaS case should be assessed individually.

Does CRA apply to open-source software?

CRA has a special approach to free and open-source software. Non-commercial open-source distribution is treated differently from a product made available on the market as part of commercial activity. If a company monetizes an open-source product or places it on the market, scope analysis is needed.

What should be done by 11 September 2026?

The key priority is to prepare the process for reporting actively exploited vulnerabilities and severe incidents affecting product security. The company should define roles, deadlines, reporting channels and decision documentation.

What should be prepared by 11 December 2027?

The company should prepare full readiness for the main CRA requirements: product risk assessment, secure development lifecycle, vulnerability handling, technical documentation, conformity assessment, declaration of conformity, CE marking, support period and user information.

Is SBOM mandatory?

CRA increases the importance of component visibility and vulnerability management. In practice, SBOM is one of the most important tools for demonstrating control over components, dependencies and software supply chain risk.

Is a penetration test enough?

No. Penetration testing is important, but not sufficient. CRA requires an approach covering the full product lifecycle: risk assessment, design, development, testing, documentation, updates, vulnerability handling and post-release support.

Where should CRA preparation start?

The best starting point is product and role mapping, CRA scope analysis, gap assessment and a 2026-2027 action plan. Then the company should organize secure development, vulnerabilities, SBOM and documentation.

Summary

The Cyber Resilience Act changes how technology companies should think about product security. Security is no longer only a best practice, sales advantage or requirement from a large customer. It becomes part of conformity, documentation, risk assessment and manufacturer accountability.

Software houses should use 2026 to prepare the foundation: product mapping, vulnerability handling process, risk assessment, secure development lifecycle, SBOM, technical documentation and reporting procedures.

In 2027, the organization should move to full readiness: conformity assessment, evidence of meeting requirements, user information, support period, declaration of conformity and post-release product security maintenance.

Sources

We write about regulations such as NIS2, DORA, CRA and ISO 27001, cybersecurity for SMEs and critical infrastructure, as well as cyber hygiene, emerging threats and building security awareness within organisations.

Every article delivers practical knowledge - no jargon, just concrete steps you can act on to effectively protect your data, people and business continuity.