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How to Prepare a Digital Product for Security Testing and Certification?

Preparing a digital product for security testing and certification requires more than giving testers access to an application. A company should organize product scope, architecture, test environment, technical documentation, SBOM, threat model, vulnerability process, Secure SDLC evidence and regulatory requirements, especially under the Cyber Resilience Act.

Prepared by: CCyber Editorial Team

Short answer

A secure preparation process for testing and certification should cover the full product scope, architecture, test environment, documentation, tester access, test data, component list, SBOM, threat model, security requirements and vulnerability handling process. Security testing verifies the product’s technical resilience. Certification or conformity assessment also requires process evidence: product risk, Secure SDLC, updates, technical documentation, test results, risk decisions and post-release vulnerability handling.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies
  • digital product manufacturers
  • web, mobile and desktop application vendors
  • IoT, hardware and embedded systems manufacturers
  • companies developing components, libraries, APIs and modules
  • CTOs, Heads of Engineering and technical leaders
  • product owners and product managers
  • DevOps and DevSecOps teams
  • product security teams
  • CISOs and application security leaders
  • companies preparing for CRA, EUCC, penetration testing, conformity assessment or B2B customer requirements

Key takeaways

  1. Security testing and certification are different. A test shows vulnerabilities and technical risks, while certification or conformity assessment requires a broader evidence package.
  2. Before testing, the scope must be clear: product, version, environment, API, roles, data, integrations, exclusions and testing rules.
  3. Before certification or conformity assessment, the company must prepare documentation: architecture, threat model, risk assessment, SBOM, test results, vulnerability process, updates and Secure SDLC evidence.
  4. Under CRA, most products may use manufacturer self-assessment, but some important or critical products may require the involvement of a notified body.
  5. The best first step is a test-readiness assessment: a short review showing what is missing before testing, audit, certification or conformity assessment.

What does preparing a product for security testing mean?

Preparing a product for security testing means organizing everything testers need to perform a reliable test without wasting time guessing how the product works.

In practice, this means:

  • defining the test scope
  • preparing the test environment
  • providing technical documentation
  • preparing accounts and user roles
  • providing test data
  • describing APIs and integrations
  • defining safety rules for testing
  • assigning contact persons
  • preparing an escalation path for critical vulnerabilities
  • planning time for fixes and retesting

A well-prepared test produces better results because testers can focus on product risks instead of searching for access, documentation and basic information.

What does preparing a product for certification mean?

Preparing for certification or formal conformity assessment means preparing the product, process and evidence for verification against a defined set of requirements. Depending on the goal, this may involve CRA conformity assessment, cybersecurity certification, customer requirements, supplier audit or an industry standard.

Certification usually requires more than a penetration test. It may require showing:

  • product scope
  • risk assessment
  • architecture
  • security requirements
  • threat model
  • secure development evidence
  • security test results
  • SBOM
  • vulnerability handling process
  • security update process
  • technical documentation
  • remediation and retest evidence

Simply put: security testing checks the product in practice, while certification or conformity assessment also checks whether the company has process, evidence and product accountability.

Security testing vs certification: what is the difference?

Security testing

Security testing is a technical verification of a product, application, API, infrastructure or component. Its goal is to find vulnerabilities, misconfigurations, logic flaws and risks that could be exploited by an attacker.

Typical test output:

  • vulnerability report
  • risk description
  • technical evidence
  • remediation recommendations
  • priorities
  • retest after fixes

Certification or conformity assessment

Certification or conformity assessment verifies a product against requirements from a specific scheme, regulation, standard or security profile. It may include technical testing, but usually also covers documentation, process, roles, evidence and formal decisions.

Typical output:

  • assessment of requirement fulfillment
  • technical documentation
  • evidence list
  • declaration of conformity, if applicable
  • certificate, if applicable
  • improvement findings
  • ongoing obligations to maintain conformity after release

Conformity assessment under CRA

Under the CRA, a manufacturer of a product with digital elements must demonstrate that cybersecurity requirements are met. For many products, manufacturer self-assessment will be possible. For some important or critical products, a notified body or stricter procedure may be required.

This is why the company should not assume that “certification” always means the same thing. First determine the product, regulation, scheme, category and assurance level that apply.

Where should preparation start?

Step 1: define the purpose of testing or certification

First, answer why the product is being tested or certified. Preparing for an API penetration test is different from preparing for CRA conformity assessment, EUCC certification or a large customer’s security questionnaire.

Example goals:

  • penetration test before release
  • API test before customer access
  • mobile application test before publication
  • CRA preparation
  • product technical documentation preparation
  • product conformity assessment
  • cybersecurity certification
  • evidence for B2B customer
  • tender requirements
  • insurer or auditor requirements

Evidence to prepare: short description of the purpose, expected outcome and recipient of the report or certification.

Step 2: define the product scope

Scope is one of the most important preparation elements. Unclear scope leads to weak testing, misunderstandings and problems interpreting results.

The scope should include:

  • product name
  • product version
  • modules included in the test
  • modules excluded from the test
  • APIs
  • web applications
  • mobile applications
  • components installed in the customer environment
  • cloud environments
  • external integrations
  • user roles
  • data types processed by the product

Evidence to prepare: test or conformity assessment scope document with systems, versions and exclusions.

Step 3: prepare architecture and data flows

Testers and auditors must understand how the product works. Without architecture, testing will be more superficial and certification may get stuck because documentation is missing.

Prepare:

  • architecture diagram
  • data flow diagram
  • component description
  • API description
  • integration description
  • roles and permissions description
  • sensitive data description
  • trust boundaries
  • environment description: test, staging, production

Evidence to prepare: current architecture and data flow diagram.

Step 4: prepare the test environment

The test environment should be as close to production as possible, but without risk to real customers, data and business processes.

The environment should have:

  • stable product version
  • controlled test data
  • test accounts with different roles
  • test integrations or safe integration mocks
  • ability to restore state after testing
  • event logging
  • availability monitoring
  • clear rules for what testers must not do

Production should not be used for testing without very clear rules, approvals, limits and risk assessment.

Evidence to prepare: test environment description, access data, testing rules and state restoration plan.

Step 5: prepare test data

Test data should support realistic testing, but should not expose real customer or employee data.

Prepare:

  • users with different roles
  • test customers
  • sample data
  • multi-tenant SaaS scenarios
  • data for import and export
  • invalid and boundary data
  • test API tokens
  • test integrations

Evidence to prepare: test data set and confirmation that it contains no production or confidential data.

Step 6: prepare accounts, roles and access for testers

Testers should have access to roles that reflect real product use. If the test covers authorization, accounts with different permission levels are needed.

Prepare:

  • normal user account
  • customer administrator account
  • platform administrator account
  • read-only account, if applicable
  • API account
  • limited-access user account
  • second customer account for data separation tests

Evidence to prepare: test account list, permission scope and access expiration date.

Step 7: prepare a threat model

A threat model helps focus testing on the most important risks. It does not need to be perfect, but it should show what the team considers the product’s most important threats.

The model should include:

  • main assets
  • threat actors
  • abuse scenarios
  • trust boundaries
  • customer data risks
  • API risks
  • integration risks
  • administration and support risks
  • security control decisions

Evidence to prepare: threat model or list of the most important risk scenarios.

Step 8: prepare SBOM and component list

If the product will be assessed under CRA or B2B customer requirements, component visibility is very important. SBOM helps check dependencies, vulnerabilities, licenses and the impact of new vulnerabilities on the product.

Prepare:

  • SBOM for the tested product version
  • direct dependency list
  • transitive dependency list, if available
  • container images
  • open-source components
  • commercial components
  • components provided by customers or suppliers

Evidence to prepare: SBOM linked to a specific product version.

Step 9: perform an internal pre-test review

Before external testing, remove obvious issues. This prevents test budget from being used on problems the company could have detected internally.

The internal review should cover:

  • dependency scanning
  • secret scanning
  • basic SAST
  • basic DAST
  • API tests
  • cloud configuration review
  • permission review
  • security event logging review

Evidence to prepare: list of issues fixed before testing and status of open risks.

Step 10: define testing rules

Security testing needs clear rules. Testers should know what is allowed, what is prohibited, when to test, who to contact and how to report critical vulnerabilities.

The rules should define:

  • test scope
  • test window
  • tester IP addresses
  • allowed techniques
  • prohibited techniques
  • load testing limits
  • production testing rules, if applicable
  • critical vulnerability escalation path
  • contact persons
  • data protection and confidentiality rules

Evidence to prepare: testing rules approved by product and security owners.

Step 11: prepare a results handling process

A test does not end with the report. The key is what the company does with findings: how vulnerabilities are assessed, who fixes them, when retesting happens and what evidence is kept.

The process should include:

  • post-report meeting
  • vulnerability triage
  • remediation priorities
  • task owners
  • remediation deadlines
  • retesting
  • vulnerability register update
  • accepted risk decisions
  • customer communication, if needed

Evidence to prepare: test results handling procedure and remediation register.

Step 12: prepare an evidence pack for certification or conformity assessment

If the goal is certification, conformity assessment or CRA preparation, the company should prepare a broader evidence pack than the test report.

The pack may include:

  • product description
  • product scope
  • architecture
  • risk assessment
  • threat model
  • security requirements
  • test results
  • SBOM
  • vulnerability handling process
  • security update process
  • user instructions
  • support period
  • remediation evidence
  • risk decisions

Evidence to prepare: structured product evidence folder ready for a customer, audit, assessment body or authority.

Which security tests should be considered?

Web application testing

Checks the web application from the perspective of a user, attacker and business logic. It covers authentication, authorization, sessions, forms, files, errors, configuration and data access.

API testing

This is especially important for SaaS products, mobile applications and B2B integrations. It should verify object authorization, roles, tokens, rate limits, input validation and abuse of business flows.

Mobile application testing

This should cover the application, API communication, on-device data storage, token protection, configuration, reverse engineering and mobile platform-specific risks.

Infrastructure and cloud testing

Checks environment configuration, network, access, privileged accounts, logging, data storage, cloud service configuration and deployment security.

CI/CD and supply chain testing

Checks repositories, pipelines, secrets, artifacts, dependencies, signing, permissions and the possibility of injecting malicious code or components.

IoT or embedded system testing

Should cover firmware, updates, communication, hardware interfaces, default configuration, keys, protocols, mobile application and backend.

Certification readiness testing

This can be a preliminary readiness assessment. The goal is not only to find vulnerabilities, but to check whether the product and documentation are ready for a formal process.

CRA preparation: what must be ready?

Product scope and classification

  • is the product a product with digital elements?
  • is it made available on the EU market?
  • is the company a manufacturer, importer, distributor or subcontractor?
  • does the product fall into the default, important or critical category?
  • is self-assessment enough or is a notified body required?

Product risk assessment

  • architecture
  • data
  • users
  • administrative access
  • integrations
  • third-party components
  • vulnerabilities
  • possible compromise impact

Technical documentation

  • product description
  • architecture
  • risk assessment
  • security requirements
  • implemented controls
  • test results
  • SBOM
  • vulnerability process
  • update process
  • user instructions
  • support period

Process evidence

  • Secure SDLC
  • threat modeling
  • code reviews
  • security testing
  • vulnerability management
  • update history
  • risk decisions
  • user communication

Preparing for cybersecurity certification

First choose the right scheme

Not every certification fits every product. A SaaS product, mobile application, router, firewall, cryptographic module, IoT device and hardware component may require very different approaches.

Before starting, check:

  • what the certification goal is
  • whether certification is voluntary or required
  • whether the customer requires a specific scheme
  • whether the product fits the scope of the scheme
  • which assurance level is needed
  • whether a laboratory or certification body is required
  • which documents must be prepared
  • how long the process may take

EUCC and Common Criteria

EUCC is an EU certification scheme based on Common Criteria. It can apply to ICT products such as technological components, hardware and software. It is more formal than a normal penetration test and requires security requirements, documentation and assessment by appropriate entities.

Not every software house will need EUCC immediately. However, it is worth understanding this direction if the product has security functions, is used in regulated sectors, will be sold to large customers or may fall into a category requiring a higher assurance level.

Certification vs certification readiness

Many companies should start not with certification itself, but with readiness assessment. This shows whether the product has sufficient documentation, testing, processes, evidence and version control.

Readiness assessment helps avoid starting a formal process too early and discovering gaps that could have been prepared earlier.

Security testing preparation checklist

Scope

  • do we have a product description?
  • do we know the product version?
  • do we know which modules are included?
  • do we know exclusions?
  • do we know user roles?
  • do we know data and integrations?

Environment

  • is the test environment stable?
  • is it separated from production?
  • is test data ready?
  • are test accounts ready?
  • is logging enabled?
  • do we have a plan to restore state after testing?

Documentation

  • do we have an architecture diagram?
  • do we have API documentation?
  • do we have role descriptions?
  • do we have a threat model?
  • do we have a component list?
  • do we have security requirements?

Organization

  • are contact persons assigned?
  • are dates agreed?
  • are testing rules agreed?
  • is critical vulnerability escalation agreed?
  • is remediation time planned?
  • is retesting planned?

Certification or conformity assessment preparation checklist

Product and regulation

  • is the product covered by CRA?
  • is the product made available on the EU market?
  • has the company role been defined?
  • has the product category been defined?
  • is self-assessment sufficient?
  • is a notified body or certification scheme needed?

Security evidence

  • do we have a risk assessment?
  • do we have a threat model?
  • do we have test results?
  • do we have an SBOM?
  • do we have a vulnerability register?
  • do we have remediation evidence?

Processes

  • do we have Secure SDLC?
  • do we have a vulnerability handling process?
  • do we have a secure update process?
  • do we have a customer communication process?
  • do we have a CRA reporting process?
  • do we have version and release control?

Technical documentation

  • is documentation current?
  • does it describe the product and architecture?
  • does it show implemented controls?
  • does it include test results?
  • does it include the support period?
  • does it include user instructions?

Common mistakes

Mistake 1: testing without clear scope

Unclear scope leads to disputes, testing gaps and a report that is difficult to use. The scope must identify product, version, modules, accounts, APIs, integrations and exclusions.

Mistake 2: test environment differs from production

If the test environment differs significantly from production, the test results may be less valuable. Differences should be described and consciously accepted.

Mistake 3: no test data and roles

Without realistic accounts, roles and data, testers cannot properly verify authorization, data separation, business flows and multi-tenancy in SaaS.

Mistake 4: treating testing as certification

A test report is not automatically a certificate. It can be technical evidence, but certification or conformity assessment usually requires broader documentation and process.

Mistake 5: no process for handling findings

If there is no triage, owners, remediation deadlines and retesting after the test, the report does not translate into real security improvement.

Mistake 6: no technical documentation

For conformity assessment and certification, missing documentation is one of the biggest problems. A product may be technically good, but difficult to formally confirm.

Mistake 7: late CRA preparation

CRA requires process, documentation and evidence. This cannot be prepared in the last week before assessment. It is best to start with readiness assessment and an action plan.

30, 60 and 90-day action plan

First 30 days

  • define the purpose of testing or certification
  • create a product and version register
  • select a pilot product
  • describe the test scope
  • prepare an architecture diagram
  • prepare the test environment
  • prepare test accounts and data
  • collect existing test results and documentation

Days 31 to 60

  • perform threat modeling
  • prepare SBOM
  • run internal dependency and secret scanning
  • perform a basic API and access control review
  • remove obvious issues before external testing
  • prepare testing rules
  • prepare a test findings handling process

Days 61 to 90

  • perform security testing
  • triage vulnerabilities
  • fix priority vulnerabilities
  • perform retesting
  • complete technical documentation
  • prepare an evidence pack for the customer, audit or CRA
  • define the plan for formal certification or conformity assessment if needed

What documents and evidence should be prepared?

Product documents

  • product description
  • version list
  • feature scope
  • architecture
  • data flow diagram
  • API list
  • integration list
  • roles and permissions list

Security documents

  • product risk assessment
  • threat model
  • security requirements
  • SBOM
  • SAST, DAST and SCA results
  • penetration test report
  • API testing report
  • vulnerability register

Process documents

  • Secure SDLC policy
  • vulnerability handling process
  • security update process
  • vulnerability disclosure process
  • product release process
  • customer communication process
  • CRA reporting procedure

Operational evidence

  • vulnerability remediation evidence
  • retest results
  • risk acceptance decisions
  • security update history
  • release approval logs
  • test access confirmation
  • security advisories

How to measure product readiness?

Testing readiness

  • test scope is approved
  • test environment is stable
  • test accounts are ready
  • test data is ready
  • architecture and API are described
  • contact persons are assigned
  • testing rules are accepted

Conformity assessment or certification readiness

  • product has risk assessment
  • product has technical documentation
  • product has SBOM
  • product has vulnerability handling process
  • product has security update process
  • product has test results
  • product has remediation and risk decision evidence

Business example

A SaaS company prepares a B2B platform for a security test required by a large customer. The team wants to order a penetration test immediately, but quickly discovers that there is no current architecture diagram, the test environment differs from production, accounts for different roles are missing and the API is not well documented.

The company first prepares for testing. It defines the scope, creates test accounts, prepares test data for two customers, documents the API, collects documentation and runs internal dependency and secret scanning.

As a result, the external test becomes more valuable. Testers do not waste time organizing access. They check real risks: authorization, customer data separation, API, administrator panel, data export and integrations.

After the test, the company performs triage, fixes vulnerabilities and completes retesting. Then it uses the report as part of a broader evidence pack: SBOM, threat model, vulnerability register, update process and technical documentation for CRA.

How can ccyber.io help?

ccyber.io helps companies prepare digital products for security testing, certification, conformity assessment and B2B customer requirements. We do not start from the test alone. First, we check whether the product, environment, documentation and processes are ready.

We can support your organization with:

  • test-readiness assessment
  • security test scope preparation
  • architecture and data flow review
  • threat model preparation
  • SBOM preparation
  • API and access control review
  • technical documentation preparation for CRA
  • vulnerability handling process
  • security update process
  • evidence pack for customers, audits, certification or conformity assessment

The best first step is a short product readiness assessment. It shows whether the product is ready for testing, what is missing before conformity assessment and which actions should be completed before involving external testers or an assessment body.

FAQ

Are security testing and certification the same?

No. Security testing detects vulnerabilities and technical risks. Certification or conformity assessment checks the product against defined requirements and usually requires broader documentation, process and evidence.

Is a penetration test report enough for CRA?

No. A test report can be important evidence, but CRA requires a broader approach: risk assessment, technical documentation, vulnerability handling, updates, SBOM, support period and user information.

Does every CRA product need a notified body?

No. For many products, manufacturer self-assessment will be possible. However, some important or critical products may require a stricter procedure or notified body involvement.

What should be prepared before web application testing?

Test scope, test environment, user accounts, test data, role description, API description, architecture, testing rules, contact persons and a findings handling process.

What should be prepared before API testing?

API documentation, accounts and tokens with different roles, sample requests, test data, rate limits, authorization description, business scenarios and test environment.

Is SBOM needed before certification?

In many cases, yes. SBOM is very important for CRA, vulnerability management, component assessment, customer responses and product technical documentation.

What is certification readiness?

It is the state where the product has not only test results, but also scope, documentation, processes, evidence, owners and version control needed for formal assessment.

Where should a company start if the product has never been tested?

The best starting point is readiness assessment: scope, architecture, test environment, accounts, data, API, basic scanning, threat model and test findings handling plan.

Summary

Preparing a digital product for security testing and certification requires organizing the product, process and evidence. Simply giving testers access to an application is not enough if scope, environment, data, documentation and findings handling process are missing.

For companies preparing for CRA or large customer requirements, the broader approach is essential: risk assessment, technical documentation, SBOM, vulnerability process, security updates, threat model and Secure SDLC evidence.

The best order is: readiness first, then testing, then remediation and retesting, and only later formal certification or conformity assessment if required.

Sources

Secure Updates: How to Prepare a Product Update Process for CRA Requirements?

Secure updates for a digital product are not only about releasing a patch. Under the Cyber Resilience Act, a manufacturer should have a process for detecting vulnerabilities, preparing fixes, testing, signing, secure distribution, user communication, deployment monitoring and evidence documentation throughout the product support period.

Prepared by: CCyber Editorial Team

Short answer

A secure update process for CRA should cover the entire patch lifecycle: vulnerability detection, risk assessment, change preparation, testing, approval, artifact signing, secure distribution, user communication, deployment monitoring and evidence documentation. A manufacturer of a product with digital elements should also define the support period, provide security updates without undue delay, prepare automatic updates where applicable and separate security updates from functionality updates where technically feasible.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies building digital products or product-related remote data processing solutions
  • web, mobile and desktop application vendors
  • IoT, hardware and embedded systems manufacturers
  • companies developing components, libraries, APIs and modules
  • CTOs, Heads of Engineering and technical leaders
  • DevOps and DevSecOps teams
  • product security teams
  • CISOs and application security leaders
  • people responsible for CRA, Secure SDLC, SBOM, vulnerabilities and product technical documentation

Key takeaways

  1. A secure update is a process, not a one-time delivery of a patch to the user.
  2. Under CRA, a manufacturer should be able to show that it can remediate vulnerabilities and deliver security updates throughout the product support period.
  3. Security updates should be tested, signed, distributed through a secure channel and linked to a specific product version.
  4. If the product supports automatic updates, users should receive clear information, have an option to postpone updates and be able to opt out where CRA requires it.
  5. The best starting point is a product and version map, update policy, release process, vulnerability register, SBOM, communication procedure and evidence pack for technical documentation.

What are secure product updates?

Secure updates are the process of preparing, verifying and delivering product fixes in a way that reduces vulnerability risk, avoids introducing new issues and prevents attackers from substituting a malicious product version.

In practice, a secure update process answers:

  • how do we know that the product needs a fix?
  • which product versions are supported?
  • who decides on a security update?
  • how do we test the fix?
  • how do we sign and protect artifacts?
  • how does the user receive the update?
  • can the update be installed automatically?
  • how can the user postpone or disable automatic updates where they have that right?
  • how do we communicate risk, workarounds and recommended actions?
  • how do we document that the update was released and available?

A secure update is not only about code. It also concerns the build process, change control, signatures, distribution channels, documentation, user support and vulnerability response.

Why does CRA change the approach to updates?

The Cyber Resilience Act introduces cybersecurity requirements for products with digital elements. One of the key areas is vulnerability handling throughout the product support period.

For manufacturers, this means the product should be designed and maintained so that the company can:

  • detect and document vulnerabilities
  • prepare security fixes
  • deliver updates in a timely manner
  • securely distribute updates
  • inform users about available updates
  • separate security updates from functionality updates where technically feasible
  • define the end of the support period
  • prepare evidence for technical documentation

CRA therefore turns updates from a technical issue into a product, regulatory and business issue. The team must know not only how to release a fix, but also how to prove that the process works.

Which CRA requirements matter most for updates?

1. Security updates must remediate vulnerabilities

The manufacturer should have a process that makes it possible to respond to vulnerabilities and remediate them through security updates. This requires connecting vulnerability management, release process, testing, communication and documentation.

2. Updates should be provided without undue delay

If the company is aware of a significant vulnerability, it should not delay a fix without justification. Priority should depend on risk, product exposure, active exploitation, customer impact and workaround availability.

3. Security updates should be separate from functionality updates where feasible

A user should not be forced to install a large feature update only to receive a security fix if the two can be technically separated.

4. The product should support automatic updates where applicable

The CRA refers to automatic security updates in certain cases, especially for consumer products. At the same time, users should have a clear and easy mechanism to turn off automatic updates and temporarily postpone installation.

5. Users should receive clear information

A security update should be accompanied by information explaining what it fixes, what the user should do and whether additional risk reduction actions are needed.

6. The manufacturer must define the support period

The user should know until when vulnerability handling and security updates can be expected. The support end date should be specified clearly, including month and year.

Secure update process step by step

Step 1: define products, versions and support periods

Updates cannot be managed well if the company does not know which products and versions are still supported. The first step is a product and version register.

The register should include:

  • product name
  • supported versions
  • versions no longer supported
  • support end date
  • product type
  • distribution model
  • business owner
  • technical owner
  • key customers or user segments
  • critical dependencies and components

Evidence to prepare: register of products, versions and support periods.

Step 2: define a security update policy

The update policy should define when the company releases a security fix, who makes the decision, how testing works and how users are informed.

The policy should include:

  • definition of a security update
  • difference between security and functionality updates
  • urgency criteria
  • roles and responsibilities
  • fix preparation and release timelines
  • automatic update rules
  • postponement and opt-out rules
  • user communication rules
  • evidence documentation rules

Evidence to prepare: security update policy approved by product and security owners.

Step 3: connect updates with vulnerability management

A security update usually results from a vulnerability. The update process should therefore be connected with the vulnerability register, SBOM and risk assessment process.

For each important vulnerability, define:

  • which product is affected
  • which versions are affected
  • whether the vulnerability is actively exploited
  • whether a workaround exists
  • whether a fix is needed
  • when the fix can be released
  • whether CRA reporting is required
  • how users should be informed

Evidence to prepare: link between vulnerability, fix release and communication decision.

Step 4: prepare a secure build and release process

An attacker may try to replace the patch, compromise the build process, steal a signing key or inject malicious code into the release process. Update security therefore depends on development process security.

Check:

  • who can approve the change
  • who can start the build
  • who can deploy the fix to production
  • where secrets and keys are stored
  • whether artifacts are signed
  • whether duties are separated
  • whether the CI/CD process is logged
  • whether the artifact can be linked to source code and product version

Evidence to prepare: build and release process description, approval logs and list of privileged users.

Step 5: sign updates and verify integrity

The user or system should be able to verify that the update comes from the correct manufacturer and has not been modified in transit.

In practice, this means:

  • artifact signing
  • protection of signing keys
  • key rotation where needed
  • key revocation procedure
  • signature verification by the client or installation system
  • protection against rollback to an older vulnerable version
  • protection against installation of an incorrect package

Evidence to prepare: update signing procedure, key register and signature verification evidence.

Step 6: secure the update distribution channel

The update distribution channel can be attacked. If an attacker compromises the update server, repository, administrator account or distribution system, they may try to deliver a malicious product version.

Security controls should cover:

  • MFA for administrators
  • restricted access to update repositories
  • administrator action logging
  • package integrity verification
  • rollback protection
  • monitoring of unusual changes
  • backups of metadata and artifacts
  • contingency plan for distribution channel compromise

Evidence to prepare: update channel diagram, access control, logs and contingency plan.

Step 7: test updates before release

A security fix should not resolve one vulnerability while creating a new incident. Testing should cover both security and product stability.

Testing should include:

  • test of the remediated vulnerability
  • regression test
  • compatibility test
  • update installation test
  • failed update recovery test
  • package integrity test
  • signature verification test
  • user communication test

Evidence to prepare: update test report, release approval and list of known limitations.

Step 8: plan automatic installation, postponement and opt-out

For some products, automatic security updates are the best way to reduce risk. However, it is not always possible to install fixes automatically without affecting the user, production or integrations.

The process should define:

  • whether the product supports automatic updates
  • whether automatic installation is the default setting
  • whether users can temporarily postpone the update
  • whether users can turn off automatic updates
  • how users receive opt-out instructions
  • what risk is created by disabling updates
  • how the company monitors outdated versions

Evidence to prepare: description of the automatic update mechanism, user instruction and product decision register.

Step 9: prepare user communication

A security update should be understandable for the user. The communication does not need to disclose every technical detail before remediation, but it should clearly state what the user should do.

The communication may include:

  • product name
  • affected versions
  • fixed version
  • risk level
  • recommended actions
  • whether the update is automatic
  • whether the user can postpone installation
  • whether a workaround exists
  • whether restart or maintenance window is required
  • where to find more information

Evidence to prepare: approved security advisory and communication channel list.

Step 10: monitor update deployment

Releasing a fix does not mean that risk is gone. The company should know how many users installed the update, which versions remain vulnerable and whether problems appeared after the update.

Monitor:

  • number of updated installations
  • number of still vulnerable installations
  • installation failures
  • user reports
  • product impact
  • attempts to exploit the vulnerability after the fix
  • time from release to user installation

Evidence to prepare: update adoption report and post-release issue list.

Step 11: maintain update availability for the required time

The CRA requires each security update made available to users during the support period to remain available after release for a minimum of 10 years or for the remainder of the support period, whichever is longer.

This means the manufacturer should plan:

  • where updates are stored
  • how long artifacts are retained
  • how the update repository is protected
  • how metadata and signatures are maintained
  • how older supported versions are handled
  • how update availability is documented

Evidence to prepare: update retention policy and available version register.

Step 12: document evidence for CRA

Under CRA, security updates are part of the evidence that the manufacturer handles vulnerabilities and maintains the product securely. Evidence should be available in technical documentation or related registers.

Document:

  • vulnerability or security issue
  • risk assessment
  • decision to release a fix
  • scope of the fix
  • testing
  • release approval
  • artifact signature
  • publication date
  • user communication
  • deployment monitoring
  • decision on CRA reporting or no reporting

Evidence to prepare: complete security update evidence pack.

Secure updates checklist for CRA

Product and support

  • do we have a list of products covered by CRA?
  • do we know supported versions?
  • do we know the support end date?
  • does the user receive support period information?
  • do we have a process for products reaching end of support?

Vulnerabilities and decisions

  • do we have a vulnerability register?
  • do we know which vulnerability requires an update?
  • do we assess active exploitation?
  • do we have remediation timelines?
  • do we have a user communication decision?

Build and release

  • is the change approved?
  • is the artifact linked to source code?
  • is the artifact signed?
  • are signing keys protected?
  • is the CI/CD process controlled?
  • can we reconstruct who approved the release?

Distribution and installation

  • is the update delivered through a secure channel?
  • does the system verify update integrity?
  • does the product support automatic updates where applicable?
  • can the user postpone the update?
  • can the user turn off automatic updates where applicable?

Evidence and documentation

  • do we have a test report?
  • do we have a security advisory?
  • do we have evidence of update publication?
  • do we have an update adoption report?
  • is the update included in technical documentation?
  • has SRP reporting obligation been assessed?

Secure updates for different product types

SaaS applications

In a SaaS model, the manufacturer usually controls the production environment and can deploy fixes faster. The challenge is change control, regression testing, customer communication and monitoring impact on integrations.

In SaaS, the following are especially important:

  • production change control
  • regression tests
  • post-deployment monitoring
  • maintenance window communication
  • administrative access control
  • evidence of fix deployment

Customer-installed applications

For software installed in the customer environment, the manufacturer often does not fully control the installation date. The update mechanism, notifications, instructions, compatibility and version monitoring where possible are therefore important.

Mobile applications

Mobile applications depend on app stores, operating systems and user behavior. The company should plan how quickly the fix will reach the user and how to reduce risk for older versions.

IoT and embedded systems

In IoT and embedded systems, updates may involve firmware, resource-constrained devices, unstable connectivity and physical risk. Signatures, integrity verification, resilience to interrupted updates and safe recovery are particularly important.

Components and libraries

If the company provides a component, library, SDK or API, it should prepare clear versioning, vulnerability advisories, update instructions and information for integrators. The customer must know how to safely update the component in their product.

Common security update mistakes

Mistake 1: no list of supported versions

If the company does not know which product versions it supports, it is difficult to decide which versions need a fix and which customers should be informed.

Mistake 2: fix without testing

Time pressure after vulnerability discovery can lead to a rushed release. A security fix still needs testing, especially when it affects authentication, access, customer data or the installation process.

Mistake 3: no update signing

Unsigned or weakly protected updates can be replaced. For a digital product, the update mechanism is one of the most sensitive security elements.

Mistake 4: no plan for failed updates

An update may fail. The company should know how the product returns to operation, how data is protected and how the user receives support.

Mistake 5: mixing security fixes with large feature changes

If the user must install a large feature change only to receive a security fix, delay and compatibility risk increase.

Mistake 6: no user communication

The user must know that an update is available, what it fixes and what they should do. Lack of communication extends exposure time.

Mistake 7: no evidence

If the company does not document tests, approvals, signatures, publication and communication, it is difficult to demonstrate compliance even if the update was done correctly.

30, 60 and 90-day implementation plan

First 30 days

  • assign an owner for the security update process
  • list products, versions and support periods
  • review the current patch release process
  • check whether updates are signed
  • check who has access to the release process
  • prepare a basic security update policy
  • select one pilot product

Days 31 to 60

  • connect the update process with the vulnerability register
  • define security fix timelines
  • prepare a security advisory template
  • add update tests to the release process
  • review protection of keys and artifacts
  • prepare an emergency procedure for failed updates
  • define rules for separating security and functionality updates

Days 61 to 90

  • implement update signing and verification where controls are missing
  • start monitoring update adoption
  • prepare CRA reporting procedure
  • add updates to product technical documentation
  • run an urgent security fix exercise
  • prepare an evidence pack for a customer or audit
  • expand the process to additional products

What documents and evidence should be prepared?

Governance documents

  • security update policy
  • product and support period register
  • roles and responsibilities
  • user communication rules
  • risk acceptance rules for delayed updates

Technical documents

  • update mechanism description
  • distribution channel description
  • artifact signing process
  • key protection procedure
  • update testing procedure
  • failed update handling procedure
  • link between updates, SBOM and vulnerabilities

Operational evidence

  • vulnerability report
  • risk assessment
  • remediation task
  • test results
  • release approval
  • artifact signature
  • security advisory
  • evidence of update publication
  • update adoption report
  • CRA reporting or no-reporting decision

How to measure update process effectiveness

Speed metrics

  • time from vulnerability detection to update decision
  • time from decision to fix preparation
  • time from fix to release
  • time from release to user installation

Quality metrics

  • number of updates withdrawn because of defects
  • number of post-update issues
  • percentage of updates with full tests
  • percentage of signed and verified updates

Compliance metrics

  • number of products with defined support period
  • number of products with documented update mechanism
  • number of updates with evidence pack
  • number of CRA reporting decisions made on time

Adoption metrics

  • percentage of installations on the latest version
  • percentage of vulnerable installations
  • number of users who postponed the update
  • number of users with automatic updates disabled

Business example

A company develops a desktop application used by B2B customers in a regulated sector. The product has an update module, but no clear support policy, update signing is manual and customer communication is prepared only when a problem appears.

After a CRA analysis, the company realizes that it must organize the whole process. First, it creates a supported version register, defines the support period, assigns the update process owner and links vulnerabilities with fix releases.

Then the company introduces artifact signing, update installation tests, a failed update procedure and a security advisory template. It also adds an adoption report to see which customers still use older versions.

After 90 days, the company not only releases fixes faster, but also has evidence: who approved the fix, what was fixed, how it was tested, when it was published and how many customers installed it.

How can ccyber.io help?

ccyber.io helps companies building digital products prepare a secure update process aligned with CRA requirements, Secure SDLC practices and the real way product teams work.

We can support your organization with:

  • CRA readiness assessment for the update process
  • mapping products, versions and support periods
  • security update policy design
  • connecting updates with vulnerability management
  • CI/CD and fix release process review
  • update signing and distribution review
  • security advisory preparation
  • CRA reporting procedure
  • evidence pack for product technical documentation
  • workshop for product, engineering and security teams

The best first step is a short update process assessment. It helps determine which products require the most attention, where controls are missing and what should be implemented before CRA deadlines.

FAQ

What is a secure product update?

It is an update prepared, tested, signed, distributed and monitored in a way that reduces security risk without creating new risk for the user and product.

Does CRA require automatic updates?

CRA refers to automatic security updates where applicable, especially for consumer products. Users should also have a clear opt-out mechanism and the ability to temporarily postpone installation.

Should security updates be separate from functionality updates?

CRA states that where technically feasible, security updates should be delivered separately from functionality updates. The goal is to avoid forcing the user to install a large feature change just to receive a security fix.

Should security updates be free of charge?

CRA indicates that security updates addressing identified security issues should be provided without delay and free of charge, unless otherwise agreed between the manufacturer and a business user for a tailor-made product.

How long must updates remain available?

CRA requires each security update made available to users during the support period to remain available after release for at least 10 years or for the remainder of the support period, whichever is longer.

Is publishing a patch file on a website enough?

Not always. The company should ensure a secure distribution channel, update integrity, user instructions, communication, testing, monitoring and evidence. Publishing the file alone may be insufficient.

Is the update process part of CRA technical documentation?

Yes. The update process, vulnerability handling, testing, support and evidence should be linked to product technical documentation and conformity assessment.

Where should update process preparation start?

The best starting point is a product and supported version register, security update policy, connection with the vulnerability register, update signing review and preparation of communications and evidence.

Summary

Secure updates are one of the most important parts of CRA compliance and real digital product security. A product that cannot be updated securely will be difficult to maintain, difficult to defend in front of customers and difficult to demonstrate in technical documentation.

The most important process elements are product register, support period, vulnerability management, testing, signing, secure distribution, automation where applicable, communication and update adoption monitoring.

Companies that prepare this process early will be better ready for CRA, customer questions, audits, incidents and situations where a critical security fix must be released quickly.

Sources

Vulnerability Management for Digital Products: Where Should You Start?

Vulnerability management for digital products does not end with scanning libraries or waiting for a penetration test report. Software companies should have a process for detecting, assessing, prioritizing, fixing, testing, communicating and documenting vulnerabilities throughout the product lifecycle, especially under the Cyber Resilience Act.

Prepared by: CCyber Editorial Team

Short answer

Vulnerability management for digital products is a process for detecting, assessing, prioritizing, fixing, testing, communicating and documenting vulnerabilities in software, components, APIs, cloud, configuration, dependencies and the release process. A company should start with a product register, component register, vulnerability reporting channel, clear roles, risk classification, remediation deadlines, update process, SBOM, security testing and a reporting procedure under the Cyber Resilience Act.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies
  • digital product manufacturers
  • web and mobile application companies
  • IoT, hardware and embedded systems manufacturers
  • CTOs, Heads of Engineering and technical leaders
  • DevOps and DevSecOps teams
  • product security teams
  • CISOs and application security leaders
  • people responsible for CRA, Secure SDLC, SBOM, security testing and product documentation

Key takeaways

  1. Vulnerability management is not a one-time scan. It is a process that operates across the entire product lifecycle.
  2. The first step is knowing which products, components, versions, dependencies and environments the company maintains.
  3. Prioritization should not be based only on CVSS score. Exposure, exploitation, product criticality, fix availability and business context must also be considered.
  4. Under the CRA, manufacturers must prepare vulnerability handling, security updates, documentation and reporting of actively exploited vulnerabilities and severe incidents.
  5. The best start is a product register, vulnerability reporting channel, SBOM, risk assessment process, remediation deadlines and an evidence pack for customers, audits and authorities.

What is vulnerability management for a digital product?

Vulnerability management for a digital product is an organized process for handling security weaknesses that may exist in the product, its components, configuration, libraries, APIs, cloud environment, release process or documentation.

In practice, the process answers the following questions:

  • how do we know that the product has a vulnerability?
  • who receives the report?
  • who assesses the impact on the product and customers?
  • how do we set remediation priority?
  • who decides on a security update?
  • how do we test the fix?
  • how do we inform customers?
  • does a CRA reporting obligation arise?
  • how do we document decisions, deadlines and evidence?

Good vulnerability management does not mean that the company “has a scanner”. A scanner is only one source of information. The key is a process that turns vulnerability information into a decision, fix, test, communication and evidence.

Vulnerability, bug, risk and incident: what is the difference?

Vulnerability

A vulnerability is a weakness in a product, component, process or configuration that can be exploited to compromise security. It may affect code, dependencies, cloud settings, access control, business logic or the update process.

Bug

A bug is incorrect system behavior. Not every bug is a security vulnerability, but some bugs can lead to vulnerabilities. Example: an input validation bug may allow command injection or access control bypass.

Risk

Risk combines the likelihood of vulnerability exploitation and the impact on the company, product and customers. The same vulnerability may have a different risk level in different products.

Incident

An incident is an event that negatively affects or may negatively affect the security of a product, data or functions. A vulnerability can lead to an incident, but not every vulnerability means that an incident has already occurred.

Why is vulnerability management important under CRA?

The Cyber Resilience Act introduces cybersecurity requirements for products with digital elements. For software companies, this means securing the product across its lifecycle: design, development, release, updates, vulnerability handling and user communication.

Under the CRA, the manufacturer must be ready for:

  • identifying vulnerabilities and product components
  • documenting vulnerabilities and remediation actions
  • preparing and maintaining an SBOM
  • issuing security updates
  • reporting actively exploited vulnerabilities
  • reporting severe incidents affecting product security
  • maintaining technical documentation
  • informing users about risks and fixes where required

From 11 September 2026, reporting requirements apply for actively exploited vulnerabilities and severe incidents through the Single Reporting Platform. This means companies should not wait until 2027 to build the process. Without a vulnerability register, owners, classification and escalation path, meeting reporting deadlines will be difficult.

Where should vulnerability management start?

Step 1: prepare a product and version register

You cannot manage vulnerabilities effectively if the company does not know which products, versions and components it maintains. The first step is a digital product register.

The register should include:

  • product name
  • business owner
  • technical owner
  • currently supported versions
  • versions no longer supported
  • key components
  • code repositories
  • container images
  • production environments
  • customers or customer segments covered by the product
  • product criticality

Evidence to prepare: product and version register with owners and support status.

Step 2: create a component register and SBOM

A large part of digital product vulnerabilities affects third-party components: libraries, packages, container images, transitive dependencies and tools used in the build process.

The company should prepare an SBOM, or Software Bill of Materials, and link it to a specific product version.

An SBOM helps answer:

  • do we use the vulnerable component?
  • in which products?
  • in which versions?
  • is the component direct or transitive?
  • does the vulnerability actually affect the product?
  • is a fix or update needed?

Evidence to prepare: SBOM for key products, component register and SBOM update process for releases.

Step 3: define sources of vulnerability information

Vulnerabilities can be detected in many ways. The company should define which sources it uses and who monitors them.

Typical sources:

  • dependency scanning
  • code scanning
  • application testing
  • API testing
  • penetration testing
  • customer reports
  • security researcher reports
  • supplier advisories
  • CVE databases and vulnerability information
  • information about active exploitation
  • incidents and security alerts

Evidence to prepare: list of vulnerability sources, monitoring owners and review frequency.

Step 4: prepare a vulnerability reporting channel

A company creating a digital product should have a clear way to receive vulnerability reports. Without it, a researcher, customer or partner may not know where to report a problem.

Prepare:

  • security contact email address
  • security.txt file
  • vulnerability reporting policy page
  • scope of systems covered by reports
  • safe testing rules
  • information expected in a report
  • communication rules with researchers
  • internal escalation path

Evidence to prepare: vulnerability disclosure policy, public contact channel and report handling procedure.

Step 5: create a vulnerability register

The vulnerability register is the center of the process. It should collect all vulnerabilities regardless of source: scanner, customer, penetration test, researcher, incident or supplier information.

The register should include:

  • unique vulnerability identifier
  • report source
  • product and version
  • vulnerability description
  • component or feature
  • impact on confidentiality, integrity and availability
  • severity assessment
  • exploitability assessment
  • remediation status
  • owner
  • remediation deadline
  • risk acceptance decision, if applicable
  • evidence of fix and retest

Evidence to prepare: central vulnerability register with decision and action history.

Step 6: assess vulnerabilities in product context

Not every high-score vulnerability means the product is truly exposed. Conversely, a medium-score vulnerability may be critical if it affects a public feature, customer data or administrative access.

When assessing a vulnerability, consider:

  • CVSS score
  • whether the vulnerability is actively exploited
  • exploit probability, for example EPSS
  • whether the component is used in a vulnerable way
  • whether the function is reachable from the internet
  • whether authorization is required
  • whether a workaround or mitigating control exists
  • product criticality
  • number of customers at risk
  • impact on personal or confidential data
  • contractual and regulatory requirements

Evidence to prepare: classification decision with justification, not only scanner score.

Step 7: define remediation deadlines

The company should have internal response and remediation timelines. Deadlines depend on vulnerability severity, product exposure, fix availability and real risk.

Example model:

  • critical and actively exploited vulnerability: immediate escalation and same-day action plan
  • critical vulnerability without active exploitation: priority remediation within a defined short timeframe
  • high vulnerability: remediation within a timeframe based on product risk
  • medium vulnerability: remediation in the planned release cycle
  • low vulnerability: remediation at the next reasonable opportunity or risk acceptance

Timelines should not be copied mechanically from the internet. They should follow risk appetite, customer requirements, regulations and team capacity.

Evidence to prepare: remediation timeline policy and history of meeting deadlines.

Step 8: fix root causes, not only symptoms

A good fix should not only change one line of code if the problem comes from a weak design pattern, missing tests or poor access control.

For every important vulnerability, ask:

  • why did this vulnerability appear?
  • could a similar issue exist elsewhere?
  • is a new automated test needed?
  • should the coding standard be changed?
  • should threat modeling be improved?
  • does the team need training?
  • should the library or component be changed?

Evidence to prepare: root cause description, fix, regression test and preventive actions.

Step 9: test and verify fixes

A vulnerability fix should be tested. Otherwise, the company does not know whether the problem is really gone or whether a new issue was introduced.

Verification may include:

  • unit test
  • integration test
  • security test
  • vulnerability retest
  • code review
  • configuration check
  • regression test
  • validation by an external tester or customer, if applicable

Evidence to prepare: retest result and confirmation of vulnerability closure.

Step 10: prepare communication and security update

If a vulnerability affects customers or users, communication must be planned. Not every vulnerability requires a public advisory, but every important vulnerability should have a communication decision.

A security advisory may include:

  • description of the issue at a user-understandable level
  • affected products and versions
  • fixed versions
  • recommended user actions
  • workarounds if a fix is not yet available
  • impact on confidentiality, integrity and availability
  • credit to the reporter, if agreed
  • security contact

Evidence to prepare: approved advisory, recipient list, publication date and update history.

Step 11: check CRA reporting obligations

From 11 September 2026, manufacturers of products with digital elements must report actively exploited vulnerabilities and severe incidents affecting product security through the Single Reporting Platform.

The process should specify:

  • who assesses whether a vulnerability is actively exploited
  • who assesses whether an incident is severe
  • who is responsible for reporting
  • who approves the report
  • how the 24-hour, 72-hour and final report deadlines are tracked
  • how decisions are documented
  • how the report is linked to the vulnerability and incident registers

Evidence to prepare: CRA reporting procedure, role list, note templates and reporting register.

Step 12: learn and improve the process

Every serious vulnerability is an opportunity to improve the process. The company should analyze not only how quickly it fixed the issue, but why it appeared and whether similar mistakes can be prevented.

After an important vulnerability, run a short review:

  • how was the vulnerability detected?
  • how long did classification take?
  • how long did remediation take?
  • was communication sufficient?
  • were there delays?
  • are new tests needed?
  • should the Secure SDLC process be improved?
  • does the team need training?

Evidence to prepare: lessons learned note and improvement actions.

How to prioritize vulnerabilities?

Do not rely only on CVSS

CVSS is a useful standard for technical severity assessment, but it should not be the only remediation priority criterion. A digital product has its own context: customers, data, exposure, architecture, mitigating controls and contractual obligations.

Consider active exploitation

A vulnerability actively exploited by attackers should have higher priority than a theoretical vulnerability with a similar technical score. Under the CRA, active exploitation may trigger reporting obligations if it affects a product with digital elements.

Consider exploitation probability

EPSS can support the assessment of the probability that a vulnerability will be exploited in the near future. It does not replace team judgment, but helps distinguish vulnerabilities that are only “technically high” from those more likely to be exploited.

Consider product exposure

A vulnerability in an internet-facing feature has a different priority than a vulnerability in a component that is not externally reachable and is not used in the product.

Consider data and customers

If a vulnerability can lead to access to customer data, personal data, financial data, secrets, API keys or multi-tenant SaaS data, the priority should increase.

Consider remediation effort

Sometimes a quick library update removes significant risk with low effort. In other cases, a fix requires architecture changes. Prioritization should consider both risk and a realistic remediation plan.

Minimum vulnerability register: what fields should it include?

Identification data

  • vulnerability identifier
  • detection date
  • report source
  • reporting person or system
  • product
  • product version
  • component or feature

Technical data

  • vulnerability description
  • vulnerability type
  • CVE, if applicable
  • CWE, if applicable
  • CVSS, if calculated
  • EPSS, if available
  • technical evidence
  • exploitation conditions

Business data

  • customer impact
  • data impact
  • availability impact
  • number of customers at risk
  • product criticality
  • contractual requirements
  • regulatory requirements

Process data

  • remediation owner
  • status
  • priority
  • remediation deadline
  • remediation plan
  • retest result
  • communication decision
  • CRA reporting decision
  • risk acceptance decision

30, 60 and 90-day implementation plan

First 30 days

  • assign a vulnerability management process owner
  • create a product and version register
  • identify main vulnerability sources
  • launch a basic vulnerability register
  • prepare a public vulnerability reporting channel
  • define the first severity and priority scale
  • choose a pilot product
  • start dependency and secret scanning

Days 31 to 60

  • prepare an SBOM for the pilot product
  • introduce vulnerability assessment and classification
  • define remediation timelines for different risk levels
  • connect vulnerabilities with product team tasks
  • prepare a security advisory template
  • prepare a fix retesting procedure
  • train developers and support teams

Days 61 to 90

  • connect the process with Secure SDLC
  • add security testing to CI/CD
  • prepare the CRA reporting procedure
  • define process metrics
  • prepare an evidence pack for customers and audits
  • run a critical vulnerability handling exercise
  • expand the process to additional products

Digital product vulnerability management checklist

Product visibility

  • do we have a product register?
  • do we know supported versions?
  • do we know which products are covered by CRA?
  • do we have a component and dependency list?
  • do we have an SBOM for key products?

Vulnerability detection

  • do we scan dependencies?
  • do we scan secrets?
  • do we test the application and API?
  • do we analyze customer and researcher reports?
  • do we monitor supplier advisories?

Assessment and prioritization

  • do we have a severity scale?
  • do we consider active exploitation?
  • do we consider product exposure?
  • do we consider customer data impact?
  • do we document decisions?

Remediation and verification

  • do vulnerabilities have owners?
  • do they have remediation deadlines?
  • are fixes tested?
  • do we perform retesting?
  • do we update SBOM after component changes?

Communication and reporting

  • do we have a vulnerability disclosure policy?
  • do we have a security advisory template?
  • do we know when to inform customers?
  • do we have a CRA reporting procedure?
  • do we track the 24-hour, 72-hour and final report deadlines?

Common mistakes

Mistake 1: scanner instead of process

A scanner can find a vulnerability, but it will not define owner, priority, deadline, communication, customer impact or reporting obligations. The company needs a process, not only a tool.

Mistake 2: no link between vulnerability and product version

If a vulnerability is not linked to a specific product version, it is difficult to determine which customers are exposed and whether the fix was deployed.

Mistake 3: no vulnerability reporting channel

If a researcher or customer does not know where to report a vulnerability, the information may go to the wrong person, be ignored or be published without coordination.

Mistake 4: relying only on CVSS

CVSS is important, but not enough. Remediation priority must consider product, customers, exposure, active exploitation and fix availability.

Mistake 5: no retesting

Closing a task in a project system does not mean the vulnerability was effectively removed. Retesting or another form of confirmation is needed.

Mistake 6: no communication decisions

Not every vulnerability requires a public advisory, but lack of any communication decision can create chaos when a customer asks about risk.

Mistake 7: no CRA preparation

Companies covered by CRA must be ready to report actively exploited vulnerabilities and severe incidents. Without procedures and roles, meeting deadlines will be difficult.

How to measure process effectiveness?

Operational metrics

  • number of open vulnerabilities by severity
  • mean time to classify vulnerabilities
  • mean time to remediate
  • percentage of vulnerabilities fixed on time
  • number of overdue vulnerabilities
  • number of vulnerabilities reopened after retesting

Product metrics

  • number of products with SBOM
  • number of products covered by dependency scanning
  • number of products with vulnerability reporting process
  • number of releases with security scanning completed
  • number of critical components overdue for update

Quality metrics

  • number of vulnerabilities found before production
  • number of vulnerabilities found after release
  • number of recurring weakness classes
  • number of preventive actions after root cause analysis
  • number of customer and researcher reports handled on time

Business example

A SaaS company develops a platform for B2B customers. The product has a web application, API, reporting module, several integrations and hundreds of open-source dependencies. A regulated sector customer asks how the company handles vulnerabilities and how quickly it can respond to a new vulnerability in a popular library.

At first, the team checks vulnerabilities manually. Some dependencies are in different repositories, some in container images and some in build tools. There is no single vulnerability register and no clear decision on who approves customer communication.

The company implements a vulnerability management process. It creates a product register, generates an SBOM for the main application, starts dependency scanning, prepares a vulnerability reporting channel, defines remediation deadlines and prepares a security advisory template.

After 90 days, the company can answer the customer clearly: which products are covered by the process, how vulnerabilities are detected, how they are assessed, what remediation deadlines apply, how communication works and what evidence can be shown.

How can ccyber.io help?

ccyber.io helps software companies implement a practical vulnerability management process for digital products, aligned with CRA, Secure SDLC, SBOM and B2B customer requirements.

We can support your organization with:

  • vulnerability management maturity assessment
  • product, version and component mapping
  • vulnerability register design
  • vulnerability reporting and handling process
  • SBOM integration with vulnerability management
  • product-context vulnerability prioritization
  • customer communication procedure
  • CRA reporting procedure
  • evidence pack for customers, audits and authorities
  • training for product, development and support teams

The best first step is a short vulnerability process assessment. It helps determine where the biggest gaps are, whether the company is ready for CRA and which actions should be implemented in the first 30, 60 and 90 days.

FAQ

What is vulnerability management in a digital product?

It is the process of detecting, assessing, prioritizing, fixing, testing, communicating and documenting vulnerabilities in a product, its components, configuration, APIs, cloud and release process.

Is a vulnerability scanner enough?

No. A scanner helps detect issues, but it does not replace a process. Roles, decisions, priorities, deadlines, fixes, tests, communication and evidence are required.

How is a vulnerability different from an incident?

A vulnerability is a weakness that can be exploited. An incident is an event that already affects or may affect the security of a product, data or functions.

How should vulnerabilities be prioritized?

It is useful to combine CVSS, active exploitation, EPSS, product exposure, data criticality, customer impact, fix availability and regulatory or contractual requirements.

Is SBOM needed for vulnerability management?

Yes, especially for digital products. SBOM helps determine which components and versions are in the product and whether a new vulnerability affects a specific release.

Does CRA require a vulnerability management process?

CRA requires manufacturers of products with digital elements to handle vulnerabilities, document them, provide security updates and report actively exploited vulnerabilities and severe incidents according to defined timelines.

Does every vulnerability need to be reported under CRA?

No. CRA focuses on actively exploited vulnerabilities and severe incidents affecting product security. The company should have a procedure to assess whether a reporting obligation exists.

Where should a company start if it has no process?

The best starting point is a product register, vulnerability register, reporting channel, basic risk classification, dependency scanning, SBOM for the main product and clear remediation deadlines.

Summary

Vulnerability management for digital products is one of the most important elements of product security. Finding a vulnerability is not enough. It must be assessed, fixed, tested, documented and, where needed, communicated or reported.

For software companies, this process is becoming increasingly important from both business and regulatory perspectives. Customers want evidence, auditors want a process and the CRA strengthens manufacturer obligations for vulnerabilities, updates and reporting.

The best approach is to start simply: product register, SBOM, vulnerability register, owners, priorities, deadlines, tests and communication procedure. Automation, scaling and integration with the full Secure SDLC can come next.

Sources

Software Bill of Materials (SBOM): What Software Companies Must Prepare for CRA

An SBOM, or Software Bill of Materials, helps a company show which components, libraries and dependencies make up a digital product. Under the Cyber Resilience Act, software companies should prepare an SBOM generation process, dependency control, vulnerability management, technical documentation and a way to share information with customers, auditors and market surveillance authorities.

Prepared by: CCyber Editorial Team

Short answer

An SBOM, or Software Bill of Materials, is a formal and structured record of components, libraries, dependencies and relationships that make up a digital product. Under the Cyber Resilience Act, software companies should prepare a process for generating SBOMs in a machine-readable format, link SBOMs to vulnerability management, technical documentation, security updates and compliance evidence.

Last updated

July 2026

Who this article is for

  • software houses
  • SaaS companies
  • web and mobile application companies
  • digital product manufacturers
  • IoT, hardware and embedded systems manufacturers
  • CTOs, Heads of Engineering and technical leaders
  • DevOps and DevSecOps teams
  • product security teams
  • CISOs and application security leaders
  • people responsible for CRA, Secure SDLC, vulnerability management and product technical documentation

Key takeaways

  1. An SBOM is not a package list in a spreadsheet. It is a formal record of software components and supply chain relationships.
  2. The CRA requires manufacturers to identify and document vulnerabilities and components in products with digital elements, including by drawing up an SBOM in a commonly used and machine-readable format.
  3. Under the CRA, an SBOM should cover at least the top-level dependencies, but in practice companies should aim for better visibility into transitive dependencies as well.
  4. An SBOM has the greatest value when it is connected with vulnerability management, security updates, product risk assessment and technical documentation.
  5. The best first step is to automatically generate an SBOM for key products, choose a format, assign an owner and update it at every important release.

What is an SBOM?

An SBOM is a structured record of components used in software. It can be compared to an ingredients list for a product. In physical manufacturing, a company knows which parts a device contains. In software, an SBOM plays a similar role.

An SBOM helps answer:

  • which components are in the product?
  • which component versions are used?
  • where do the components come from?
  • what are the relationships between components?
  • does a component have known vulnerabilities?
  • is the component still maintained?
  • which licenses apply to the components?
  • does a new vulnerability affect our product?

The most important point is that an SBOM is not a goal by itself. It is a tool for software supply chain visibility, vulnerability management, customer responses and compliance evidence.

Why is SBOM important under the Cyber Resilience Act?

The Cyber Resilience Act introduces cybersecurity requirements for products with digital elements. This includes hardware and software products made available on the EU market.

The CRA requires manufacturers to identify and document vulnerabilities and components contained in products with digital elements. It explicitly refers to drawing up an SBOM in a commonly used and machine-readable format, covering at least the top-level dependencies of the product.

In practice, a company creating a digital product should know what the product is made of. When a new vulnerability appears in a popular library, the company must quickly determine:

  • do we use this component?
  • in which products and versions?
  • is the vulnerable version in production?
  • is the component direct or transitive?
  • is the vulnerability exploitable in our product?
  • do we need to release a fix?
  • do we need to inform customers?
  • does a CRA reporting obligation arise?

Without an SBOM, answering these questions often requires manual searching across repositories, pipelines, container images, documentation and assumptions about what actually reached the release.

Is SBOM mandatory under CRA?

The CRA states that manufacturers must identify and document vulnerabilities and components contained in products with digital elements, including by drawing up an SBOM. Such an SBOM should be in a commonly used and machine-readable format and cover at least the top-level dependencies of the product.

In practice, companies should treat SBOM as one of the key elements of CRA preparation, alongside:

  • product cybersecurity risk assessment
  • secure software development lifecycle
  • vulnerability management
  • vulnerability disclosure process
  • security update process
  • product technical documentation
  • security testing and review evidence

Important: an SBOM does not automatically mean public disclosure of the full component list to every user. Under CRA, technical documentation, including the SBOM, may be requested by market surveillance authorities. If the manufacturer decides to make the SBOM available to users, information on where it can be accessed should be provided.

What should a good SBOM contain?

The minimum SBOM scope depends on the standard, tool and use case. For companies preparing for CRA, the SBOM should be practical, current, machine-readable and linked to a specific product version.

Basic component data

  • component name
  • component version
  • supplier or author of the component
  • unique component identifier, if available
  • component source
  • component type, such as library, package, module, container or application

Relationships and dependencies

  • whether the component is a direct dependency
  • whether the component is a transitive dependency
  • which component depends on which
  • which product or module contains the component
  • which product version uses the component

Security data

  • connection with vulnerabilities
  • vulnerability analysis status
  • whether the vulnerability affects the product in practice
  • fix or update information
  • risk level, if assessed

Licensing and compliance data

  • component license
  • copyright information, if available
  • usage restrictions
  • license risk

SBOM metadata

  • who generated the SBOM
  • which tool generated it
  • when it was generated
  • for which product version
  • which format was used
  • whether the SBOM was validated
  • where it is stored

Top-level dependencies and transitive dependencies

What are top-level dependencies?

Top-level dependencies are components that the product uses directly. Example: an application directly uses a library for authentication, file handling, logging or database communication.

What are transitive dependencies?

Transitive dependencies are components used by other components. Example: your application uses library A, and library A uses library B. Library B is a transitive dependency.

What should be prepared for CRA?

The CRA refers to at least top-level dependencies. However, from a real vulnerability management perspective, companies should aim to gain visibility into transitive dependencies as well. Many serious vulnerabilities appear in libraries that were not manually added by the team, but entered the product through other packages.

Practical recommendation for software companies:

  • start with top-level dependencies if the company has no process yet
  • then expand the SBOM to transitive dependencies
  • link the SBOM to a specific product release
  • automate SBOM generation in CI/CD
  • connect SBOM with vulnerability scanning

Which SBOM formats should be known?

SPDX

SPDX is an open standard developed by the Linux Foundation. It is used to describe software components, licenses, dependencies and supply chain information. The SPDX specification is available as the international standard ISO/IEC 5962:2021.

SPDX works well where license compliance, customer exchange and interoperability between tools matter.

CycloneDX

CycloneDX is an OWASP standard for bills of materials, designed with software supply chain cybersecurity in mind. It supports SBOM, SaaS bills of materials, cryptography bills of materials, hardware bills of materials and AI bills of materials.

CycloneDX is often used in DevSecOps teams for automatic SBOM generation, vulnerability analysis and integration with security tools.

Which format should be chosen?

There is no single answer for every company. More important than the format itself is whether the SBOM is current, machine-readable, generated repeatedly, linked to a product version and used in vulnerability management.

In practice, choose a format supported by the company’s tools, customer requirements and future regulatory needs. In many organizations, supporting both SPDX and CycloneDX can be useful if tools and processes allow it.

SBOM and vulnerability management

An SBOM has the greatest value when it is used operationally. A file stored in a repository does not reduce risk if nobody analyzes it.

A good process should work as follows:

  • the product is built
  • the SBOM is generated automatically
  • the SBOM is linked to a specific product version
  • components are checked against known vulnerabilities
  • the team assesses whether a vulnerability actually affects the product
  • important vulnerabilities generate remediation tasks
  • after remediation, a new SBOM is generated
  • decisions and evidence are stored for customers, audits or CRA

Not every vulnerability means real risk

An SBOM may show that a product contains a vulnerable component. This does not always mean the vulnerability is exploitable in the product. The team should assess context: whether the vulnerable function is used, whether the component is reachable, whether a mitigating control exists and whether the product is exposed to the internet.

This is why VEX is increasingly used alongside SBOM. VEX is a way of communicating whether a vulnerability actually affects a specific product.

SBOM and VEX: what is the difference?

SBOM shows what is in the product

SBOM answers the question: which components make up the product?

VEX shows whether a vulnerability affects the product

VEX answers the question: does a specific vulnerability in a component affect this product in practice?

Example:

  • the SBOM shows that the product uses library X version Y
  • a vulnerability database says library X has a vulnerability
  • the team’s analysis shows that the vulnerable function is not used in the product
  • VEX can communicate to the customer that the product is not affected in that specific scenario

For companies selling B2B software, combining SBOM and VEX can significantly reduce chaotic customer questions after a new vulnerability is disclosed in a popular library.

How to prepare an SBOM step by step?

Step 1: assign an SBOM process owner

SBOM should not be only one developer’s task. It is part of product security, vulnerability management and compliance. The owner may be product security, DevSecOps, CTO, security engineer or the team responsible for product quality.

Evidence to prepare: SBOM process owner, responsibility scope and supporting people.

Step 2: choose products and versions covered by SBOM

At the beginning, not everything needs to be covered. Start with products that are most important for the business, covered by CRA, sold to B2B customers or containing sensitive data.

Priority:

  • main product sold to customers
  • product covered by CRA
  • product containing customer data
  • product installed in the customer environment
  • product with frequent integrations
  • product with many open-source components

Evidence to prepare: list of products and versions covered by the SBOM process.

Step 3: choose format and tools

Choose a format supported by the team’s tools and customer requirements. In most cases, SPDX or CycloneDX should be considered.

When choosing a tool, check:

  • whether it supports the programming languages used
  • whether it detects direct and transitive dependencies
  • whether it works in CI/CD
  • whether it generates a machine-readable format
  • whether it links the SBOM to a product version
  • whether it integrates with vulnerability scanning
  • whether it supports containers and production images

Evidence to prepare: decision on format, tool and SBOM generation scope.

Step 4: generate SBOM automatically

Manual SBOM creation quickly stops working. The product changes with every release, and dependencies are updated frequently. The SBOM should be generated automatically during build or release.

Automation should cover:

  • source code repository
  • dependency files
  • container images
  • release artifacts
  • product version
  • release metadata

Evidence to prepare: automatic SBOM generation configuration and sample file for a product release.

Step 5: link SBOM to product release

An SBOM that is not linked to a product version has limited value. When a customer asks about a vulnerability in a specific version, the company must know which SBOM applies to that version.

Link SBOM to:

  • product version number
  • release date
  • build identifier
  • repository commit or tag
  • container image
  • production environment

Evidence to prepare: product release register with assigned SBOM.

Step 6: scan SBOM for vulnerabilities

After an SBOM is generated, it should be used to assess vulnerabilities. The SBOM alone is not enough. Component analysis against vulnerability information sources is needed.

The process should include:

  • component scanning
  • assessment of critical and high vulnerabilities
  • checking whether the vulnerability affects product use
  • remediation prioritization
  • team tasks
  • retesting after updates

Evidence to prepare: vulnerability report, triage decisions, remediation tasks and remediation confirmation.

Step 7: check SBOM quality

An SBOM may be incomplete, incorrect or inconsistent. Tools do not always detect components in the same way. This is why quality review is needed.

Check:

  • whether the SBOM covers the right artifact
  • whether it includes top-level dependencies
  • whether it includes transitive dependencies, if that is the goal
  • whether component versions are correct
  • whether the format is technically valid
  • whether the file can be processed automatically
  • whether the SBOM does not contain information the company does not want to disclose externally

Evidence to prepare: SBOM quality checklist and validation result.

Step 8: define SBOM sharing rules

An SBOM may contain sensitive business or technical information. The company should define who receives it, when and at what level of detail.

Possible models:

  • internal SBOM only
  • SBOM shared with customers under a non-disclosure agreement
  • SBOM shared only for selected products
  • limited SBOM shared externally
  • vulnerability status information without full SBOM
  • SBOM shared with market surveillance authorities upon reasoned request

Evidence to prepare: SBOM sharing policy, approval path and customer response template.

30, 60 and 90-day SBOM plan

First 30 days

  • assign an SBOM process owner
  • list products and repositories
  • select a pilot product
  • choose a format: SPDX or CycloneDX
  • choose an SBOM generation tool
  • generate the first SBOM manually or semi-automatically
  • check whether the SBOM covers top-level dependencies

Days 31 to 60

  • add SBOM generation to CI/CD
  • link SBOM to product version
  • add vulnerability scanning based on SBOM
  • define the vulnerability triage process
  • prepare the first SBOM quality checklist
  • define SBOM storage rules
  • define who can share SBOMs with customers

Days 61 to 90

  • expand SBOM to additional products
  • add transitive dependencies if the tool supports it
  • prepare the SBOM sharing procedure
  • connect SBOM with vulnerability management
  • add SBOM to product technical documentation for CRA
  • prepare a customer response template
  • prepare a report for the board and product team

SBOM checklist for CRA

Product scope

  • do we know which products may be covered by CRA?
  • do we know which product versions are actively supported?
  • do we have a product and component register?
  • do we know which components are placed on the market separately?
  • do we know which products contain open-source software?

SBOM generation

  • is SBOM generated automatically?
  • is SBOM machine-readable?
  • are we using a commonly used format?
  • does SBOM cover at least top-level dependencies?
  • is SBOM linked to the product version?
  • is SBOM stored as release evidence?

Quality and security

  • is SBOM technically validated?
  • are component versions correct?
  • are dependencies complete?
  • does SBOM avoid unnecessary disclosure?
  • is access to SBOM controlled?

Vulnerabilities and updates

  • is SBOM scanned for vulnerabilities?
  • is there a process to assess whether a vulnerability affects the product?
  • is there a component vulnerability register?
  • are vulnerabilities converted into remediation tasks?
  • is a new SBOM generated after updates?
  • is the process linked to CRA reporting?

Documentation and evidence

  • is SBOM part of the product technical documentation?
  • do we have an SBOM generation policy?
  • do we have an SBOM sharing procedure?
  • do we have SBOM history for product releases?
  • can we provide evidence to customers, auditors or market surveillance authorities?

Common SBOM mistakes

Mistake 1: treating SBOM as a one-time document

An SBOM must change together with the product. If the product has a new release, new dependencies or a new container image, the SBOM should also be updated.

Mistake 2: no link between SBOM and product version

If it is not clear which SBOM applies to which product version, answering a customer or authority question becomes difficult. SBOM must be tied to a specific release.

Mistake 3: generating SBOM without vulnerability analysis

Generating the file alone does not reduce risk. SBOM should feed vulnerability assessment and update processes.

Mistake 4: no quality control

Tools may produce different results. SBOM should be validated and checked for completeness, correctness and usefulness.

Mistake 5: sharing full SBOM too quickly without rules

An SBOM may reveal information about architecture, dependencies and potential product weaknesses. The company should define who receives this information and at what level of detail.

Mistake 6: no process owner

If nobody owns SBOM, the process will quickly fall apart. An owner is needed in product security, DevSecOps, engineering or security.

Mistake 7: ignoring customer or supplier-provided components

In B2B products, some components may come from a customer, integrator or supplier. It is important to define who is responsible for describing them, tracking vulnerabilities and applying updates.

SBOM and technical documentation under CRA

SBOM should be linked to product technical documentation. Under CRA, technical documentation should show how the product was designed, developed and maintained from a cybersecurity perspective and how the manufacturer handles vulnerabilities.

In the documentation, connect SBOM with:

  • product architecture
  • cybersecurity risk assessment
  • secure software development process
  • vulnerability management
  • security update process
  • coordinated vulnerability disclosure procedure
  • security test results
  • product support period

A good SBOM also helps with customer communication. When a new vulnerability appears, the company does not need to answer generally. It can check the impact on specific products and versions.

How to measure SBOM process maturity?

Level 1: SBOM created manually

The company has the first component list, but the process is manual, irregular and not connected with product releases.

Level 2: SBOM generated by a tool

The company uses a tool to generate SBOM for a selected product, but does not always do it for every release.

Level 3: SBOM in CI/CD

SBOM is generated automatically at release, linked to product version and stored as evidence.

Level 4: SBOM connected with vulnerabilities

SBOM feeds vulnerability management. The team can quickly answer whether a new vulnerability affects the product.

Level 5: SBOM as part of compliance and customer communication

SBOM becomes part of technical documentation, CRA processes, customer responses, audits and software supply chain risk management.

Business example

A SaaS company develops a B2B platform. The product uses hundreds of open-source components, several container images, a web application, API and reporting module. A regulated sector customer asks whether the company can identify which component versions are in the product and whether a vulnerability in a popular library affects their environment.

At first, the team checks dependencies manually. It turns out that different repositories use different library versions, containers contain additional packages and documentation does not show which components reached a specific release.

The company implements an SBOM process. First, it generates SBOMs for the main application and container images. Then it links SBOMs to product versions, adds vulnerability scanning, prepares a procedure for sharing information with customers and includes SBOM in product technical documentation.

After several weeks, the company can answer customer questions faster and manage vulnerabilities better. SBOM stops being an audit document and becomes an operational tool.

How can ccyber.io help?

ccyber.io helps software companies prepare an SBOM process in a practical way aligned with CRA, vulnerability management and the real product development process.

We can support your organization with:

  • SBOM readiness assessment for CRA
  • product and component mapping
  • SBOM format selection
  • SBOM generation process design
  • SBOM integration with CI/CD
  • SBOM integration with vulnerability management
  • SBOM sharing procedure for customers and authorities
  • SBOM preparation for product technical documentation
  • training for product, development and DevOps teams
  • CRA roadmap for components and vulnerabilities

The best first step is a short SBOM readiness assessment. It helps determine which products need SBOMs, what tools are available, how the release process works and what must be prepared before the CRA deadlines.

FAQ

What is an SBOM?

An SBOM is a formal record of components and supply chain relationships in software. It shows which libraries, packages, modules and dependencies make up a digital product.

Is SBOM required by CRA?

The CRA states that manufacturers must identify and document vulnerabilities and components in products with digital elements, including by drawing up an SBOM in a commonly used and machine-readable format, covering at least top-level dependencies.

Does SBOM need to include all transitive dependencies?

The CRA refers to at least top-level dependencies. From a practical perspective, however, visibility into transitive dependencies is valuable because many vulnerabilities appear there.

Does SBOM need to be published publicly?

Not always. An SBOM may be internal or shared with customers or authorities under defined conditions. The company should define sharing rules because an SBOM may contain sensitive information.

Which SBOM format should be used?

SPDX or CycloneDX are the most common options to consider. The choice should depend on tools, customer requirements, CI/CD process, vulnerability analysis needs and future regulatory requirements.

Does SBOM replace security testing?

No. SBOM shows components and dependencies, but it does not replace application testing, code review, API testing, threat modeling or architecture assessment.

What is the difference between SBOM and VEX?

SBOM shows what is in the product. VEX helps communicate whether a specific vulnerability actually affects a product and its usage context.

Where should SBOM preparation start?

The best starting point is one pilot product: choose a format, generate the first SBOM, link it to a product version, check vulnerabilities and prepare an update and sharing procedure.

Summary

SBOM is becoming one of the key elements of digital product security. Under CRA, it is not enough to know that a product “uses open-source libraries”. The company must be able to show which components are in the product, how they are documented, how they are monitored and how they support vulnerability management.

The best approach is to treat SBOM as a process, not a one-time file. SBOM should be generated automatically, linked to a product version, analyzed for vulnerabilities and stored as part of technical documentation.

Companies that prepare the SBOM process early will be better ready for CRA, customer requirements, audits, vulnerability incidents and growing expectations around software supply chain transparency.

Sources

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

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.