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    EU Cyber Resilience Act

    Cyber Resilience Act Penetration Testing. Evidence for Your CRA Technical File.

    StealthNet delivers Cyber Resilience Act penetration testing for connected products: devices, firmware, companion apps and the cloud APIs behind them. Every finding is mapped to Annex I, and the report is formatted for your Annex VII technical documentation. First report in 48 hours, human-validated, at a fixed fee. The CRA does not use the words penetration test. It requires products to ship with no known exploitable vulnerabilities and requires effective and regular tests and reviews of security across the support period. A pentest report is the most direct evidence for both.

    Last reviewed:

    Reporting obligations live since 11 Sep 2026 · Full application 11 Dec 2027

    Annex I Mapped Device + Cloud + API AI + Human Hybrid Free Retest

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    Does the Cyber Resilience Act require penetration testing?

    Not by name. The CRA requires products with digital elements to ship with no known exploitable vulnerabilities (Annex I Part I) and requires manufacturers to apply effective and regular tests and reviews of security for the whole support period (Annex I Part II). A dated penetration test report is the most direct evidence for both, and it belongs in the technical documentation described in Annex VII.

    Regulatory Context

    What is the EU Cyber Resilience Act?

    The Cyber Resilience Act, Regulation (EU) 2024/2847, sets cybersecurity requirements for products with digital elements placed on the EU market, including the remote data processing solutions they need to function. It entered into force on 10 December 2024 and applies in stages.

    When does the CRA apply?

    1. 10 Dec 2024

      Regulation enters into force

    2. 11 Jun 2026

      Provisions on notification of conformity assessment bodies apply

    3. 11 Sep 2026

      Article 14 reporting obligations apply

    4. 11 Dec 2027

      All remaining obligations apply

    Which products are in scope?

    • IoT and consumer electronics
    • Industrial and OT equipment
    • Drones and robotics
    • Firmware
    • Desktop and mobile software
    • The cloud backends and APIs those products depend on

    What is out of scope?

    • Medical devices and IVDs. See FDA medical device penetration testing.
    • Motor vehicles
    • Certified civil aviation products and marine equipment
    • Products developed exclusively for national security or defence
    • Pure SaaS that is not part of a product, which falls under NIS2 instead

    EU financial entity testing sits under DORA. See DORA penetration testing.

    What must be reported under the CRA, and how fast?

    Actively exploited vulnerabilities and severe incidents, reported through ENISA's single reporting platform.

    24 hours

    Early warning

    72 hours

    Notification

    14 days / 1 month

    Final report: 14 days after a corrective measure is available (vulnerabilities), or one month (incidents)

    Article Mapping

    How a Pentest Maps to CRA Requirements

    Annex I Part I: no known exploitable vulnerabilities
    What we test
    Pre-release pentest of device, app and cloud
    Evidence in your report
    Finding list with severity and exploit proof
    Annex I Part I: access control, secure defaults, confidentiality, integrity, attack surface, logging
    What we test
    Validated by exploitation attempts
    Evidence in your report
    Pass or fail per control area
    Annex I Part II: SBOM
    What we test
    Known-vulnerability check against the components you declare
    Evidence in your report
    Component findings tied to your SBOM
    Annex I Part II: regular tests and reviews
    What we test
    Periodic and continuous testing across the support period
    Evidence in your report
    Dated report series
    Article 13: risk assessment
    What we test
    Threat model summary and scope rationale
    Evidence in your report
    Threat model summary and scope rationale
    Article 14: reporting
    What we test
    Exploitable flaws found and fixed before they are actively exploited and become reportable
    Evidence in your report
    Fixed-before-exploited finding log
    Article 31 and Annex VII: technical documentation
    What we test
    Full engagement documentation
    Evidence in your report
    Dated report with scope, method, findings, remediation, retest
    Article 32: conformity assessment for important and critical products
    What we test
    Evidence package for third-party assessment
    Evidence in your report
    Report as an input to your notified body (we are not one)
    The Problem

    Why CRA Testing Can't Wait Until 2027

    2027 sounds far off. Reporting is live now.

    Article 14 obligations have applied since 11 Sep 2026. An exploitable flaw found by an attacker first starts a 24 hour reporting clock.

    Standards aren't final.

    No harmonised standards are cited in the Official Journal yet, so your evidence has to stand on its own.

    Product security labs are slow and priced for enterprises.

    StealthNet returns a fixed-fee quote in 24 hours and a first report in 48 hours.

    How a CRA Pentest Runs

    From product scope to Annex I mapped evidence in days

    Scope the device, firmware, app and cloud, AI agents map the attack surface, a senior tester validates exploitability, and you receive an Annex I mapped report for your technical file.

    From kickoff to auditor-ready report, delivered in 48 hours.

    Coverage

    What We Test for CRA

    Device and firmware

    Firmware, interfaces and local protocols on the product itself.

    Hardware and IoT penetration testing

    Companion and desktop apps

    Mobile and desktop software that controls or configures the product.

    Cloud backend and APIs

    The remote data processing the CRA covers: the services your product needs to function.

    Update and provisioning path

    How updates are built, signed, distributed and installed, and how devices are onboarded.

    SBOM known-vulnerability check

    The components you declare, checked against known vulnerabilities.

    Authentication and secure defaults

    Default credentials, access control and out-of-the-box configuration.

    Pricing

    How Much Does a CRA Penetration Test Cost?

    Fixed fee, quoted before any work begins.

    Technical file evidence

    Hybrid (AI + Human) Pentest

    $5,000 to $10,000

    Fixed fee, quoted before any work begins

    • AI attack simulation plus senior US-based OSCP tester validation
    • Device, firmware, companion app and cloud API surface
    • Findings mapped to Annex I
    • Report formatted for Annex VII technical documentation
    • Free retest included

    Best for: Pre-release evidence for your CRA technical file

    StealthStrike (AI-Only)

    $1,500

    Single small scope: 1 role, one target. Larger or multi-role scopes move to Hybrid or a custom quote.

    • 48-hour delivery, AI-only testing
    • Exploit-validated findings
    • App and API surface coverage
    • Useful between releases

    Best for: Regular testing between releases

    Quarterly / Continuous Bundle

    Custom quote

    • Scheduled testing across the support period
    • Retest after every fix
    • Dated report series for your technical file

    Best for: Support-period testing for product lines

    What moves the number

    Single app or API

    One companion app or one API. Lands near the bottom of the range.

    Device + app + cloud

    The device, its companion app and the cloud backend it needs. The most common CRA scope.

    Product family

    Several products or a full line. Quoted above the range.

    Which one counts as technical file evidence?

    StealthStrike is good for regular testing between releases. It is AI-only, so we do not position it as standalone evidence for your technical file, and we will tell you so on the call. For evidence you put in front of a notified body or a market surveillance authority, use Hybrid.

    Free Tool

    CRA Readiness Checklist

    Twelve Annex I Part I requirements. Tick what you can already prove.

    Annex I Part I readiness

    0 of 12 confirmed

    Items drawn from Annex I Part I of Regulation (EU) 2024/2847. Not legal advice.

    Is StealthNet a notified body?

    No. StealthNet is not a notified body. We do not issue conformity assessments, EU declarations of conformity or CE marks, and we do not give legal advice. Our report is evidence you place in your technical file or hand to your notified body. Confirm your product class and obligations with counsel or a notified body.

    FAQ

    Cyber Resilience Act Questions

    Not by name. The CRA requires products with digital elements to ship with no known exploitable vulnerabilities (Annex I Part I) and requires manufacturers to apply effective and regular tests and reviews of security for the whole support period (Annex I Part II). A dated penetration test report is the most direct evidence for both, and it belongs in the technical documentation described in Annex VII.

    The Cyber Resilience Act is Regulation (EU) 2024/2847. It sets cybersecurity requirements for products with digital elements placed on the EU market, including their remote data processing solutions. It has been in force since 10 December 2024.

    Provisions on notification of conformity assessment bodies apply from 11 June 2026, Article 14 reporting obligations from 11 September 2026, and all remaining obligations from 11 December 2027.

    Manufacturers must report actively exploited vulnerabilities and severe incidents through ENISA's single reporting platform: an early warning within 24 hours, a notification within 72 hours, and a final report within 14 days after a corrective measure is available for vulnerabilities, or within one month for incidents.

    Products with digital elements placed on the EU market, including the cloud backend they need to function. Medical devices and IVDs, motor vehicles, certified civil aviation products, marine equipment and products developed exclusively for national security or defence are excluded.

    Yes, if you place products with digital elements on the EU market. The rules attach to the product sold in the EU, not to where the manufacturer is based.

    It covers the remote data processing solutions a product needs to function, so a device's cloud backend and APIs are in scope. Pure SaaS that is not part of a product falls under NIS2 instead.

    Default products can self-assess. Important class I products (Annex III) can self-assess when harmonised standards are applied, otherwise they need a third-party assessment. Important class II products need a third-party assessment. Critical products (Annex IV) may require EU cybersecurity certification.

    No. StealthNet is not a notified body. We do not issue conformity assessments, EU declarations of conformity or CE marks, and we do not give legal advice. Our report is evidence you place in your technical file or hand to your notified body.

    Under Article 31 and Annex VII, the technical documentation includes reports of tests carried out to verify conformity with the Annex I requirements, alongside your cybersecurity risk assessment under Article 13. A pentest report with scope, method, findings, remediation and retest fits there.

    Annex I Part II requires effective and regular tests and reviews across the support period, which is at least 5 years unless the product's expected use time is shorter. The CRA does not set a test frequency. Our recommendation is a test before each major release plus periodic testing between releases.

    Not as of October 2026. None are cited in the Official Journal. First horizontal drafts are due to the Commission by a proposed 31 October 2026 deadline, and product-specific drafts by 31 December 2026.

    Up to EUR 15M or 2.5% of worldwide annual turnover for breaches of the essential requirements and Articles 13 and 14, up to EUR 10M or 2% for other obligations, and up to EUR 5M or 1% for supplying incorrect information.

    A CRA penetration test from StealthNet is a fixed fee. Hybrid (AI + Human) engagements for technical file evidence run $5,000 to $10,000. StealthStrike AI-only testing between releases starts at $1,500 for a single small scope. Support-period bundles are quoted. You get a quote within 24 hours.
    Related Services

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    Every compliance pentest pulls from these test-type services as needed. Scope is sized to your environment, not padded with hours.

    Get Started

    Get Your CRA Pentest Scoped in 24 Hours

    Share a few details and we'll follow up within one business day.

    Annex I MappedHuman-ValidatedTechnical File Ready

    Fixed-fee quote in 24 hours. No credit card. No sales pitch.

    Your details stay private. NDA available on request.

    No commitment. We'll follow up within 1 business day.