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EU Cyber Resilience Act (CRA) and Software: New Cybersecurity Obligations and CE Marking

By Dr. Viola Bensinger & Jana Rudt on September 30, 2026
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The EU Cyber Resilience Act (CRA) makes cybersecurity a prerequisite for access to the EU market, not only for hardware products with digital elements, but also for software placed on the market independently. Its core requirements are far-reaching: conformity assessments, European Conformity (CE) marking, and a duty to supply security updates free of charge throughout a defined support period. For some providers, meeting them might mean rethinking established go-to-market processes and pricing models from the ground up.

This issue is particularly relevant right now: While software and other products with digital elements do not need to comply with these obligations until Dec. 11, 2027, the process required for a first CE conformity assessment may require significant lead time. The requirements also apply to products developed or manufactured before Dec. 11, 2027, if they are placed on the market after that date. In addition, reporting requirements for actively exploited vulnerabilities and severe security incidents have already taken effect.

Link to Continue reading the full GT Alert. Continue reading the full GT Alert.

Photo of Dr. Viola Bensinger Dr. Viola Bensinger

Viola Bensinger is Global Co‑Chair of the firm’s Intellectual Property & Technology Practice Group and also chairs the Technology Practice in Germany. Viola advises clients from the technology, media, health care and other innovation-driven industries on digitisation projects, IT outsourcing, cloud computing, e‑commerce…

Viola Bensinger is Global Co‑Chair of the firm’s Intellectual Property & Technology Practice Group and also chairs the Technology Practice in Germany. Viola advises clients from the technology, media, health care and other innovation-driven industries on digitisation projects, IT outsourcing, cloud computing, e‑commerce, electronic payment, data protection, and software licensing.

She has wide-ranging experience in advising media and entertainment clients such as distributors, producers, broadcasters, digital platforms, publishers, and their contracting partners on licensing and distribution, as well as the legal set-up of digital platforms. Viola also advises clients on regulatory issues, especially with regard to broadcasting law, data protection, and AI regulation.

In her litigation practice, Viola represents clients at courts or arbitration panels in contract disputes, copyright and other litigation. For many years, Viola has also gained broad experience in the areas of insolvency and restructuring relating to IP assets and licensing agreements and has advised numerous clients in large-scale insolvency proceedings relating to their German business partners.

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Photo of Jana Rudt Jana Rudt

Jana Rudt is an Associate in the Intellectual Property & Technology Practice and advises national and international clients in privacy, data security and technology-related issues as well as litigation. Her practice particularly focuses on assessing data protection compliance of business models and products…

Jana Rudt is an Associate in the Intellectual Property & Technology Practice and advises national and international clients in privacy, data security and technology-related issues as well as litigation. Her practice particularly focuses on assessing data protection compliance of business models and products, international data transfers and advising clients in court proceedings concerning IT outsourcing and data protection law.

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  • Posted in:
    Privacy and Cybersecurity, Technology and AI
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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