Mistakes to Avoid in Your CRA Readiness Strategy

With the EU Cyber Resilience Act (CRA) enforcement timeline drawing closer, software-defined product manufacturers are under pressure to establish repeatable security processes, formalize disclosure workflows, and maintain continuous visibility into the software supply chain. While many organizations have started taking steps toward compliance, others are still approaching CRA like they would a traditional audit: a one-time event with a checklist and a submission deadline.

That mindset is one of the most costly—and common—mistakes companies make.

The CRA represents a significant shift in how product security is regulated. Compliance is not simply a matter of generating a few reports or purchasing a tool. It requires ongoing organizational coordination, investment in scalable processes, and the technical infrastructure to continuously manage and monitor vulnerability risk.

In this article, we outline the key missteps organizations should avoid and how a forward-looking approach to CRA compliance can reduce both regulatory and operational risk.

Mistake 1: Treating CRA Like a Point-in-Time Audit

The most fundamental misunderstanding about the CRA is that it can be treated like a fixed audit cycle. Unlike GDPR or ISO 27001, the CRA is focused on product lifecycle security. It requires manufacturers to continuously monitor vulnerabilities, disclose new findings in a coordinated manner, and maintain evidence of their efforts over time.

Filling out a spreadsheet and submitting a one-time report may suffice in the early stages of enforcement. But over the life of a product—especially one with a 5- to 10-year support window—this approach breaks down. Without a process for continuously updating SBOMs, correlating findings with new threat intelligence, and responding to emerging risks, teams will find themselves starting from scratch with each disclosure cycle.

To meet CRA expectations, compliance must become part of how your product organization operates, not a task your compliance team performs once a year.

Mistake 2: Sequencing Assessments and Remediation Linearly

Many organizations begin with an assessment phase: mapping products, scanning for vulnerabilities, and identifying gaps. The mistake comes when remediation is treated as a separate, later phase. By the time those fixes begin, the landscape has already changed. New vulnerabilities have emerged. Product code has evolved. Findings from the initial assessment may no longer be current or relevant.

A better approach is to conduct assessment and remediation in parallel. As findings are identified, the highest-risk items should be triaged, prioritized, and addressed immediately, using contextual signals like reachability, EPSS, and exploit maturity. Waiting to “finish” the assessment phase before taking action leads to delayed timelines, stale data, and missed compliance windows.

Mistake 3: Solving for a Single Product or Team

It’s tempting for product teams to focus CRA readiness efforts on their own scope of responsibility, especially if they’re the first to face an upcoming regulatory milestone. In many cases, they’ll select a scanning tool or disclosure workflow that works for their product line, solve for their own needs, and move on.

While this can deliver short-term progress, it creates long-term fragmentation. When other teams follow suit, the result is multiple uncoordinated solutions, siloed visibility, and inconsistent standards for SBOMs, disclosure formats, and remediation processes.

This pattern—what we call “shadow product security”—is not sustainable. CRA compliance must be approached as a strategic, organization-wide initiative. A centralized, scalable platform with shared data, repeatable processes, and team-specific views is essential for driving alignment without limiting autonomy.

Mistake 4: Relying Solely on Outside-In Analysis

Many legacy vulnerability management programs were built around outside-in scanning—tools that inspect firmware or applications after they’re built, often without access to source code or contextual information. While this method still has value, it’s insufficient for CRA compliance on its own.

Outside-in scanning misses important details about how components are integrated, how vulnerabilities are mitigated by architecture, and whether certain CVEs are actually exploitable in your environment. These insights are critical to making defensible decisions about what to disclose, what to remediate, and what to deprioritize.

Without access to source code analysis, enriched SBOMs, reachability assessments, and EPSS scoring, outside-in tools can’t provide the evidence CRA requires. Visibility must come from inside the product, not just around it.

Mistake 5: Failing to Build for Repeatability

A successful CRA compliance program doesn’t just produce disclosures. It produces repeatable disclosures. Every time a new vulnerability is discovered—or a new product version is released—your organization will be expected to determine risk, document the outcome, and communicate that status to the appropriate audience.

If your disclosure process is built on spreadsheets, email threads, or standalone PDF reports, it may work once. But it won’t scale. Without repeatability, each new disclosure becomes a time-consuming, ad hoc effort that strains resources and delays response times.

A better approach is to build workflows into your tooling and development pipelines. With Finite State, teams can automatically correlate new vulnerabilities with existing product data, generate VEX documentation, and publish audit-ready records without duplicating effort across teams. This kind of automation is essential for managing ongoing compliance with limited headcount and growing product portfolios.

Final Thought: The Real Risk Is Waiting Too Long

The most dangerous mistake of all is waiting. While CRA enforcement is being phased in over the next few years, the operational and technical changes required to comply are not trivial. Organizations that treat compliance as a last-minute effort will find themselves underprepared, understaffed, and unable to demonstrate due diligence when it matters most.

The time to act is now, not because of regulatory deadlines, but because CRA compliance reflects good security practice. Building the processes, platforms, and culture to support it will not only keep you ahead of regulators, it will also make your products safer, your teams more efficient, and your business more resilient.

Call to Action

Avoid the common pitfalls of CRA readiness. Talk to Finite State about how we help product teams operationalize compliance with repeatable, scalable workflows.