What the check covers
- Reporting (Article 14): actively exploited vulnerabilities and severe incidents, to the CSIRT designated as coordinator and ENISA through the single reporting platform, and informing users.
- The essential cybersecurity requirements for the product (Annex I, Part I): one general requirement and thirteen specific ones.
- The vulnerability handling requirements (Annex I, Part II): eight points, including the software bill of materials.
- The other obligations of manufacturers (Article 13): risk assessment, components, support period, updates, markings, user information, technical documentation, conformity assessment, declaration and CE marking, and keeping the documents.
Dates
- Article 14 (reporting) applies from 11 September 2026, also to products placed on the market before 11 December 2027 (Articles 69(3) and 71(2)).
- The rest of the Regulation applies from 11 December 2027. A product placed on the market before that date comes under it only if it is substantially modified from that date (Article 69(2)).
How the score works
Only rows answered “Done” count. “Partly done”, “Not started” and rows left unanswered count as open, so the score never shows more than you answered. “Not applicable” removes a row from the total; it is offered only for the specific requirements of Annex I, Part I, point (2), which apply on the basis of the cybersecurity risk assessment and where applicable, and the technical documentation must say why (Article 13(4)). The percentage is rounded down.
What the check does not do
It does not test or assess your product: the score is a count of your own answers, and a high score does not show that the product meets the Regulation. It covers manufacturers only, not importers (Article 19), distributors (Article 20) or open-source software stewards (Article 24). For the class of your product and its conformity assessment route, use the CRA check; for the reporting deadlines, the CRA reporting register; for the SBOM, the SBOM generator.
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