text: Regulation (EU) 2024/2847

text: of the European Parliament and of the Council of 23 October 2024 on horizontal cybersecurity requirements for products with digital elements and amending Regulations

text: (EU) No 168/2013

text: and

text: (EU) 2019/1020

text: and

text: Directive (EU) 2020/1828

text: (Cyber Resilience Act) (OJ L, 2024/2847, 20.11.2024, ELI: http://data.europa.eu/eli/reg/2024/2847/oj). 2 ( ) There were 194 responses in total, with 174 being in the scope of the CRA. Percentages throughout are of the 194 responses. "No Answer" responses (n = 20, 10.31%) are excluded from all figures. 3 ( )

text: Commission Recommendation 2003/361/EC of 6 May 2003

text: concerning the definition of micro, small and mediumsized enterprises (OJ L 124, 20.5.2003, p. 36, ELI: http://data.europa.eu/eli/reco/2003/361/oj).

text: Table 1: Maturity scorecard: average score (1–5) by domain and company size NB: Scores in red indicate values below 2.5, reflecting ad hoc practices or no established process. Amber scores range from 2.5 to 3.4 and reflect processes that are only partly in place or applied inconsistently. Green scores start at 3.5 and indicate practices that are managed and applied consistently. None of the domains were fully in the green category. Microcompanies scored either in the red range or at the lower end of the amber range across all five domains. (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: ( ) Governance and documentation; risk management and security by design; vulnerability and patch management; incident response and life-cycle management; and awareness, competence and skills. 5 ( ) The maturity questions had five levels.

text: ( ) In this report, SMEs refer to microcompanies and small and medium-sized companies, as defined in

text: concerning the definition of micro, small and medium-sized enterprises (OJ L 124, 20.5.2003, p. 36, ELI: http://data.europa.eu/eli/reco/2003/361/oj). ( )

text: Regulation (EU) 2024/2847

text: (EU) No 168/2013

text: and

text: (EU) 2019/1020

text: and

text: Directive (EU) 2020/1828

text: (Cyber Resilience Act) (OJ L, 2024/2847, 20.11.2024, ELI: http://data.europa.eu/eli/reg/2024/2847/oj). 8 ( ) For more information, please visit the Commission's web page on the implementation of the CRA: https://digitalstrategy.ec.europa.eu/en/factpages/cyber-resilience-act-implementation 9 ( ) Governance and documentation; risk management and security by design; vulnerability and patch management; incident response and life-cycle management; and awareness, competence and skills.

text: Figure 1. Geographical distribution of survey responses (Q1.1) (n = 194). Countries are shaded according to the number of respondents indicating operations in that country. In total, 25 EU Member States are represented. Respondents operating EUwide (n = 30), EEA-wide (n = 3) or globally (n = 2) are included in the survey total (n = 194) but are not assigned to a specific country and are therefore not shown on the map. EEA = European Economic Area. All SME sizes were represented in the results. There were 72 medium-sized companies (37 %), 69 small companies (36 %) and 53 microcompanies (27 %). In terms of turnover, smaller SMEs are highly represented in the results, as 63 % of respondents report annual revenues of below EUR 10 million. Most respondents operate either across several Member States (41 %) or within a single country (33 %). A smaller share, around a quarter (26 %), report operating on a global scale.

text: Figure 2: Company size (Q1.2) NB: Numbers in brackets are numbers of employees.

text: Figure 3: Annual turnover (Q1.3)

text: Figure 4: Main market (Q1.4) Regarding the companies’ roles, software developers had the largest group of responses (80 respondents, 41 %). Service providers and integrators were second (53, 27 %) and product manufacturers were third (39, 20 %). Importers, distributors and authorised representatives together provided about 26 % of responses. These roles have different obligations under the CRA. Importers, distributors and authorised representatives are subject to specific requirements that differ from those applying to manufacturers, particularly regarding documentation and conformity assessment for products they place on the EU market without modification.

text: Figure 5: CRA scope (Q1.6: Do you fall under the CRA scope?)

text: Approximately one in five respondents were not sure whether the CRA actually applies to their products. This uncertainty exists most often among the importers, distributors and service providers, for whom understanding whether they are within the scope depends heavily on how the supply chain is set up.

text: Table 2: Prior awareness of the CRA (Q2.1: Before this survey, were you aware of the CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure) Awareness varies by company size. It is highest among medium-sized companies (94 %), followed by small companies (74 %) and microcompanies (62 %). In the microcompany segment, 38 % said they either were unsure or had not heard of the CRA.

text: ( ) Overall responses 194; 174 responses within the scope of the CRA. "No Answer" responses (n = 20, 10.31%) are excluded from all figures

text: Figure 6: Prior awareness of the CRA by company size (percentage of respondents) NB: Numbers in brackets are numbers of employees. (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Even among the SMEs that reported already being familiar with the CRA, most still rated their understanding of documentation and conformity assessment as limited or moderate. A similar trend can be observed across companies of all sizes, suggesting that this is not limited to a specific group of SMEs. While many organisations are aware of the regulation, this awareness does not necessarily translate into preparedness for its more detailed and operational requirements.

text: Table 3: Understanding of the CRA (percentage of respondents) (Q2.2: How would you rate your understanding of the CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 4: Cybersecurity responsibility by company size (percentage of respondents) (Q3.1: Do you have a person responsible for cybersecurity (internal or external)?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Threat modelling and software bills of materials stand out as the areas with the biggest gaps between current SME practices and what the CRA expects. Practical, easy-to-follow guidance, especially for organisations without dedicated security teams, would help address one of the clearest needs identified in the survey.

text: Table 5: Implementation of certifications, compliance measures or audits (Q3.2: Have you previously implemented any formal cybersecurity certifications, regulatory compliance measures or audits for your organisation or products?) NB: GDPR, General Data Protection Regulation; IEC, International Electrotechnical Commission; ISO, International Organization for Standardization; NIS2,

text: Directive (EU) 2022/2555

text: of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending

text: Regulation (EU) No 910/2014

text: and

text: Directive (EU) 2018/1972

text: , and repealing

text: Directive (EU) 2016/1148

text: (OJ L 333, 27.12.2022, p. 80, ELI: http://data.europa.eu/eli/dir/2022/2555/oj). (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure) On the technical practice side, most respondents implement at least one recognised security practice. Secure software development practices are the most common (99 respondents, 51 %), followed by secure coding guidelines (84, 43 %) and code review processes (82, 42 %). Vulnerability management processes are implemented by 80 respondents (41 %). Two practices stand out for their low level of adoption despite being explicit CRA requirements: threat modelling is used by only 47 respondents (24 %) and software bills of materials are used by 67 (35 %). Both are required for most in-scope products under the CRA.

text: Figure 7: Technical practices and standards (Q3.3: Which of the following technical practices or standards do you currently implement for your products with digital elements?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Figure 8: Difficulties integrating cybersecurity by design/default principles (Q4.1: Do you expect any difficulties integrating cybersecurity by design/default principles into your products or systems? Ensuring security is included in the design of products and activated by default) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 6: Challenge areas (Q4.1.a: In which areas do you expect challenges?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 7: Templates and checklists to support compliance with the CRA (Q4.2.a: What type of support would be most useful to support your efforts to comply with the CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 8: Guidance materials to support compliance with the CRA (Q4.2.b: What type of support would be most useful to support your efforts to comply with the CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 9: Operational or technical support to support compliance with the CRA (Q4.2.c: What type of support would be most useful to support your efforts to comply with CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 10: Regulatory or legal explanations to support compliance with the CRA (Q4.2.d: What type of support would be most useful to support your efforts to comply with CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 11: Other forms of support for compliance with the CRA (Q4.2.e: What type of support would be most useful to support your efforts to comply with CRA?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: The results suggest that SMEs are looking for support that is practical, accessible and easy to apply in their day-to-day work.

text: Maturity levels:

text: – processes are not implemented;

text: – processes are informal or ad hoc (inconsistent, dependent on individuals);

text: – processes are documented but not consistently applied;

text: – processes are consistently applied and regularly reviewed;

text: – processes are measured, monitored and continuously improved.

text: Table 12: Maturity by domain: lowest and highest scores (percentage of respondents) and average maturity score by company size(N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 13: Distribution across maturity levels for the governance domain by company size (percentage of respondents) (Q5.1: Do you have written rules or guidelines in your organisation covering cybersecurity, product security and CRA-related obligations (risk assessment, secure by design, updates, documentation)?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure, percentages are rounded to the nearest whole number)

text: Around 24 % of microcompanies report addressing security by design at a later stage despite the security by design approach of the CRA. This suggests that security is often still treated as a separate step rather than an integral part of development.

text: Table 14: Distribution across maturity levels for the use of security-by-design principles by company size (percentage of respondents) (Q6.2: Are your products designed with cybersecurity in mind from the beginning (secure configurations, minimal exposure, strong default settings)?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure, percentages are rounded to the nearest whole number)

text: Table 15: Distribution across maturity levels for vulnerability tracking by company size (percentage of respondents) (Q7.1: Do you have a process to receive, record and track vulnerabilities in your products if they are reported by customers, researchers or internal staff?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: ▪ Vulnerability management within smaller SMEs often remains informal or reactive. ▪ Significant differences persist between microcompanies and medium-sized organisations in the use of structured processes. ▪ Documentation and records are often not consistently maintained.

text: One takeaway is the potential for practical support to improve the situation. A simple incident response plan template for small organisations could be a useful support measure, especially if combined with clear guidance on when and how to report vulnerabilities, including how to use ENISA’s Single Reporting Platform.

text: Table 16: Distribution across maturity levels for product life cycle policy by company size (percentage of respondents) (Q8.2: Is there a defined product life-cycle policy for your products, including support periods, update timelines and end-of-support or end-of-life information?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 17: Distribution across maturity levels for staff training by company size (percentage of respondents) (Q9.1: Are relevant staff in your organisation trained or informed about secure development practices and vulnerability-handling requirements?) (N = 194. "No Answer" responses (n = 20, 10.31%) are excluded from this figure)

text: Table 18: Information preferences by company size (Q10.2: Which of the following types of information would you be interested in related to the CRA?) (N = 194, multiple responses were permitted. Percentages are calculated based on all respondents)

text: 1.1: Geographical region / economic area

text: Answer option Answers %

text: Belgium 8 4.12 Bulgaria 0 0 Czechia 1 0.52 Denmark 7 3.61 Germany 29 14.95 Estonia 2 1.03 Ireland 4 2.06 Greece 4 2.06 Spain 7 3.61 France 11 5.67 Croatia 2 1.03 Italy 5 2.58 Cyprus 5 2.58 Latvia 6 3.09 Lithuania 2 1.03 Luxembourg 1 0.52 Hungary 3 1.55 Malta 0 0 Netherlands 5 2.58 Austria 10 5.15 Poland 11 5.67 Portugal 3 1.55 Romania 3 1.55 Slovenia 1 0.52 Slovakia 1 0.52 Finland 8 4.12 Sweden 11 5.67 Iceland 0 0

text: Answer option Answers %

text: Liechtenstein 0 0 Norway 2 1.03 Switzerland 5 2.58 United Kingdom 2 1.03 EU-wide (operations in multiple Member States) 30 15.46 EEA-wide (operations in multiple EEA countries) 3 1.55 Global / outside Europe 2 1.03 NB: EEA, European Economic Area.

text: 1.2: Company size (number of employees)

text: Answer option Answers %

text: Micro (1–9) 53 27.32 Small (10–49) 69 35.57 Medium (50–249) 72 37.11

text: 1.3: Annual turnover

text: Answer option Answers %

text: < EUR 2 million 59 30.41 EUR 2–10 million 63 32.47 EUR 10–50 million 44 22.68 > EUR 50 million 28 14.43

text: 1.4: Main market

text: Answer option Answers %

text: Local (within one country) 64 32.99 EU-wide (more than one Member State) 80 41.24 Global (also countries outside the EU) 50 25.77

text: 1.5: Your company’s role (select all that apply)

text: Answer option Answers %

text: Manufacturer of ICT hardware or connected devices 28 14.43 Software developer 80 41.24 Component manufacturer 28 14.43 Final product manufacturer 39 20.10 Importer or distributor of hardware or software products 33 17.01 Service provider or integrator 53 27.32

text: Answer option Answers %

text: Authorised representative of one of the companies mentioned

text: above Other 8 4.12

text: 1.6: Do you develop or sell hardware or software products that are likely to fall under the scope of the CRA? The CRA applies to products with digital elements meaning any hardware or software that is connected or can communicate with other devices or networks.

text: Answer option Answers %

text: Yes 135 69.59 No 20 10.31 Not sure 39 20.10

text: 2.1: Before this survey, were you aware of the CRA?

text: Answer option Answers %

text: Yes 128 65.98 No 16 8.25 Not sure 30 15.46 No Answer 20 10.31

text: 2.2: How would you rate your understanding of the CRA?

text: Essential cybersecurity requirements for products with digital elements

text: Answer option Answers %

text: None 14 7.22 Limited 46 23.71 Moderate 54 27.84 Good 48 24.74 Very good 12 6.19 No Answer 20 10.31

text: Obligations on vulnerability handling and management

text: Answer option Answers %

text: None 19 9.79 Limited 43 22.16 Moderate 57 29.38 Good 45 23.20 Very good 10 5.15 No Answer 20 10.31

text: Secure development / security by design – ensuring security is included in the design of products and activated by default

text: Answer option Answers %

text: None 13 6.70 Limited 49 25.26 Moderate 57 29.38 Good 38 19.59 Very good 17 8.76 No Answer 20 10.31

text: Required documentation, including technical documentation

text: Answer option Answers %

text: None 25 12.89 Limited 57 29.38 Moderate 67 34.54 Good 18 9.28 Very good 7 3.61 No Answer 20 10.31

text: Necessary conformity assessment and compliance procedures

text: Answer option Answers %

text: None 27 13.92 Limited 78 40.21 Moderate 42 21.65 Good 20 10.31 Very good 7 3.61 No Answer 20 10.31

text: 3.1: Do you have a person responsible for cybersecurity (internal or external)?

text: Answer option Answers %

text: Yes, internal staff 112 57.73 Yes, external service provider 10 5.15 No 52 26.80 No Answer 20 10.31

text: 3.2: Have you previously implemented any formal cybersecurity certifications, regulatory compliance measures or audits for your organisation or products? (Select all that apply)

text: Answer option Answers %

text: ISO/IEC 27001 (information security management) 101 52.06 CE marking for EU product regulations 62 31.96 GDPR compliance measures 94 48.45 NIS2-related security requirements 29 14.95 Sector-specific regulations (e.g. medical devices, automotive,

text: payments) Internal security audits or self-assessments 86 44.33 Certification schemes for products (e.g. Common Criteria,

text: EUCC) We have not followed any cybersecurity certification or

text: regulatory compliance process before Other 10 5.15 No Answer 20 10.31 NB: GDPR, General Data Protection Regulation; IEC, International Electrotechnical Commission; ISO, International Organization for Standardization; NIS2,

text: Directive (EU) 2022/2555

text: Regulation (EU) No 910/2014

text: and

text: Directive (EU) 2018/1972

text: , and repealing

text: Directive (EU) 2016/1148

text: (OJ L 333, 27.12.2022, p. 80, ELI: http://data.europa.eu/eli/dir/2022/2555/oj).

text: 3.3: Which of the following technical practices or standards do you currently implement for your products with digital elements? (Select all that apply)

text: Answer option Answers %

text: Secure software development practices 99 51.03 Threat modelling 47 24.23 Secure coding guidelines 84 43.30 Code review processes 82 42.27 Static or dynamic code analysis 69 35.57 Software bill of materials (SBOM) 67 34.54 Vulnerability management processes for products 80 41.24 Product-specific standards (e.g. IEC 62443) 76 39.18 Other frameworks, tools or methods 9 4.64 None 21 10.82 No Answer 20 10.31 NB: IEC, International Electrotechnical Commission.

text: 4.1: Do you expect any difficulties integrating cybersecurity-by-design/default principles into your products or systems? Ensuring security is included in the design of products and activated by default

text: Answer option Answers %

text: Yes 91 46.91 No 21 10.82 Not sure 62 31.96 No Answer 20 10.31

text: 4.1.a: In which areas do you expect challenges? (Select all that apply)

text: Answer option Answers %

text: Understanding CRA obligations 119 61.34 Understanding how to classify products (default, important,

text: critical) Understanding the required documentation 128 65.98 Understanding conformity assessment processes 128 65.98 Technical expertise related to cybersecurity 75 38.66 Established development processes that integrate cybersecurity

text: requirements Vulnerability handling and patching 73 37.63 Resource limitations (staff or time) 119 61.34 Financial impact (cost of implementation) 109 56.19 Other 9 4.64 No Answer 20 10.31

text: 4.2: What type of support would be most useful to support your efforts to comply with the CRA? (Select all that apply)

text: 4.2.a: Templates and checklists

text: Answer option Answers %

text: For required technical documentation 142 73.20 For risk assessment 100 51.55 For vulnerability-handling processes 108 55.67 For documenting secure development practices in line with the

text: CRA None of the above 3 1.55 No Answer 20 10.31

text: 4.2.b: Guidance materials

text: Answer option Answers %

text: Simple guidelines on how to establish development processes that integrate cybersecurity requirements (security by 111 57.22 design/default) Practical guides on risk assessment methodologies 108 55.67 Step-by-step guide for CRA documentation 128 65.98 Guidance on CRA product classification (default, important,

text: critical) Guidance on conformity assessment and CE marking 114 58.76 None of the above 4 2.06 No Answer 20 10.31

text: 4.2.c: Operational or technical support

text: Answer option Answers %

text: Access to test environments or sandboxes 66 34.02 Examples or use cases relevant to your sector 103 53.09 Technical tools that help assess compliance 132 68.04 None of the above 19 9.79 No Answer 20 10.31

text: 4.2.d: Regulatory or legal explanations

text: Answer option Answers %

text: Explanation of CRA obligations 115 59.28 Explanation of roles and responsibilities for importers,

text: distributors or authorised representatives Clarification on life-cycle requirements 106 54.64 None of the above 10 5.15 No Answer 20 10.31

text: 4.2.e: Other

text: Answer option Answers %

text: Financial support 142 73.20 Other 6 3.09 No Answer 20 10.31

text: 5.1: Do you have written rules or guidelines in your organisation covering cybersecurity, product security and CRA-related obligations (risk assessment, secure by design, updates, documentation)?

text: Answer option Answers %

text: No rules or guidelines exist 18 9.28 Some very basic ad hoc guidelines exist 30 15.46 Some basic guidelines exist but are not formalised 49 25.26 Written rules exist and are generally followed 62 31.96 Written rules exist, are formally approved, applied consistently

text: and regularly reviewed No Answer 20 10.31

text: 5.2: Are responsibilities clearly defined in your organisation for cybersecurity, secure development, vulnerability handling, product updates?

text: Answer option Answers %

text: No responsibilities are defined 14 7.22 Responsibilities exist only informally or ad hoc 44 22.68 Responsibilities exist but are not consistently applied 48 24.74 Responsibilities are defined, documented and generally followed 46 23.71 Responsibilities are clearly defined, documented,

text: communicated, applied consistently and periodically reviewed No Answer 20 10.31

text: 5.3: Do you maintain product-level technical documentation describing security features, risk assessments, design decisions and update procedures?

text: Answer option Answers %

text: No product security documentation exists 10 5.15 Some very basic documentation exists 44 22.68 Product security documentation is maintained for most products 55 28.35 Product security documentation is complete and generally

text: updated for most products Product security documentation is complete, regularly updated

text: and formally approved for all products No Answer 20 10.31

text: 5.4: Is there a process or management mechanism in your organisation to review product security and documentation quality?

text: Answer option Answers %

text: No review process exists 18 9.28 Reviews happen informally and ad hoc 51 26.29

text: Answer option Answers %

text: Reviews are documented but inconsistently applied 51 26.29 Reviews are systematic and lead to improvements 39 20.10 Reviews are systematic, documented, tracked and result in

text: continuous improvements No Answer 20 10.31

text: 6.1: Do you assess cybersecurity risks for your products with digital elements and use the results to guide your design or development decisions?

text: Answer option Answers %

text: No risk assessments are performed 39 20.10 Risk assessments are informal or occasional 48 24.74 Risk assessments are documented for most products 60 30.93 Risk assessments are systematic and regularly reviewed 22 11.34 Risk assessments are systematic, formally approved,

text: documented, applied to all products and continuously improved No Answer 20 10.31

text: 6.2: Are your products designed with cybersecurity in mind from the beginning (secure configurations, minimal exposure, strong default settings)?

text: Answer option Answers %

text: Cybersecurity is not considered during design 8 4.12 Security is considered only late in development 34 17.53 Security is considered during design for most products 64 32.99 Security by design is standard practice 54 27.84 Security by design is fully integrated, documented, reviewed and

text: continuously improved No Answer 20 10.31

text: 6.3: Do you perform security checks or testing before releasing or updating a product (for example code review, basic testing or threat analysis)?

text: Answer option Answers %

text: No security checks are performed 14 7.22 Some basic checks are performed occasionally 51 26.29 Security checks are part of most releases 54 27.84 Security checks are standard and consistently applied 37 19.07 Security checks are comprehensive, standard, systematically

text: documented and continuously improved No Answer 20 10.31

text: 7.1: Do you have a process to receive, record and track vulnerabilities in your products if they are reported by customers, researchers or internal staff?

text: Answer option Answers %

text: No vulnerability tracking exists 15 7.73 Vulnerabilities are handled informally 39 20.10 Vulnerabilities are documented and tracked 62 31.96 Vulnerabilities are systematically tracked and reviewed 41 21.13 Vulnerabilities are systematically tracked, reviewed, and lessons

text: learned are integrated into products and processes No Answer 20 10.31

text: 7.2: Do you have a defined process for creating, testing and delivering security updates for supported products?

text: Answer option Answers %

text: No update process exists 10 5.15 Updates are created on an ad hoc basis 42 21.65 Updates follow a documented process 52 26.80 Updates follow a defined process and timelines are monitored 50 25.77 Updates follow a defined process, are documented, monitored,

text: and continuously improved No Answer 20 10.31

text: 7.3: Do you document vulnerabilities, fixes and update history for each product or product version?

text: Answer option Answers %

text: No documentation exists 15 7.73 Some information is recorded informally 50 25.77 Vulnerability and update information is documented 64 32.99 Documentation is complete and maintained over time 27 13.92 Documentation is complete, maintained, reviewed and formally

text: approved No Answer 20 10.31

text: 8.1: Do you have a plan for handling security incidents in relation to your products, including how to inform customers or authorities when necessary?

text: Answer option Answers %

text: No incident response plan exists 37 19.07 A basic, informal plan exists 58 29.90 An incident response plan is documented 57 29.38 The plan is tested, reviewed and improved 13 6.70

text: Answer option Answers %

text: The plan is documented, tested, reviewed, continuously

text: improved and integrated into governance No Answer 20 10.31

text: 8.2: Is there a defined product life-cycle policy for your products, including support periods, update timelines and end-of-support or end-of-life information?

text: Answer option Answers %

text: No life-cycle policy exists 36 18.56 Life-cycle information is shared informally 37 19.07 Life-cycle policy is documented for products 61 31.44 Life-cycle policy is clear, communicated and reviewed 32 16.49 Life-cycle policy is documented, communicated, enforced and

text: periodically updated based on feedback No Answer 20 10.31

text: 8.3: Do you use lessons learned from incidents, vulnerabilities or customer feedback to improve the security of your product(s)?

text: Answer option Answers %

text: No structured improvement process exists 22 11.34 Improvements happen occasionally 52 26.80 Improvements are documented and planned 56 28.87 Continuous improvement is part of regular practice 35 18.04 Continuous improvement is systematic, documented, measured

text: and embedded in governance No Answer 20 10.31

text: 9.1: Are relevant staff in your organisation trained or informed about secure development practices and vulnerability-handling requirements?

text: Answer option Answers %

text: No training or awareness activities exist 9 4.64 Some informal knowledge sharing exists 51 26.29 Training or guidance is provided occasionally 64 32.99 Training is regular and role-specific 42 21.65 Training is formal, role-specific, documented and continuously

text: updated No Answer 20 10.31

text: 9.2: Does your organisation encourage cybersecurity culture including, for example, secure behaviour, responsible disclosure and proactive security thinking?

text: Answer option Answers %

text: Cybersecurity culture is not actively promoted 7 3.61 Security is discussed informally 57 29.38 Security expectations are documented 52 26.80 Security culture is actively promoted and reinforced 46 23.71 Security culture is formally embedded, monitored and

text: 9.3: Does your organisation actively monitor external cybersecurity information (alerts, advisories, authorities)?

text: Answer option Answers %

text: No external information is monitored 12 6.19 Information is monitored occasionally 50 25.77 Relevant sources are monitored regularly 59 30.41 Monitoring is systematic and well established 35 18.04 Monitoring is systematic and integrated into governance 18 9.28 No Answer 20 10.31

text: 9.4: Does your organisation engage with external cybersecurity communities (industry groups, peers, authorities)?

text: Answer option Answers %

text: No engagement or information sharing 8 4.12 Ad hoc or informal engagement 66 34.02 Regular engagement when relevant 61 31.44 Systematic engagement and information sharing 26 13.40 Systematic engagement, information sharing and active

text: contribution integrated into governance No Answer 20 10.31

text: 10.1: Are you part of an industry association, SME cluster or chamber of commerce?

text: Answer option Answers %

text: Yes 90 46.39 No 84 43.30 No Answer 20 10.31

text: 10.2: Which of the following types of information would you be interested in related to the CRA? (Select all that apply)

text: Answer option Answers %

text: Updates on CRA implementation, e.g. regulatory deadlines or

text: regulatory changes Training or webinars on CRA compliance 116 59.79 Practical CRA guidance, templates or checklists for

text: documentation and risk assessment Examples of sector-specific good practices or use cases related

text: to the CRA Technical tools to support compliance (for example test

text: environments or sandboxes) Other 3 1.55 No Answer 20 10.31

text: 10.3: Do you have a preferred channel for getting information related to the CRA?

text: Answer option Answers %

text: National cybersecurity authority 106 54.64 Industry association or cluster 90 46.39 EU-level website or helpdesk 109 56.19 Webinars or online sessions 111 57.22 ENISA web page and social media 72 37.11 Other 2 1.03 No Answer 20 10.31

identifier: SME CRA Survey Report

nummer: sme-cra-survey-report

title: SME CRA Survey Report

text: TLP - CLEAR

text: SME CRA Survey Report

text: Survey Results and Analysis JUNE 2026

text: SME CRA Survey Report

text: About ENISA

text: The European Union Agency for Cybersecurity, ENISA, is the Union’s agency dedicated to achieving a high common level of cybersecurity across Europe. Established in 2004 and strengthened by the EU Cybersecurity Act, the European Union Agency for Cybersecurity contributes to EU cyber policy, enhances the trustworthiness of ICT products, services and processes with cybersecurity certification schemes, cooperates with Member States and EU bodies, and helps Europe prepare for the cyber challenges of tomorrow. Through knowledge sharing, capacity building and awareness raising, the Agency works together with its key stakeholders to strengthen trust in the connected economy, to boost resilience of the Union’s infrastructure, and, ultimately, to keep Europe’s society and citizens digitally secure. More information about ENISA and its work can be found here: www.enisa.europa.eu.

text: CONTACT

text: To contact the authors, use product_security@enisa.europa.eu. For media enquiries about this paper, use press@enisa.europa.eu.

text: AUTHORS

text: European Union Agency for Cybersecurity (ENISA)

text: LEGAL NOTICE

text: This publication represents the views and interpretations of ENISA, unless stated otherwise. It does not endorse a regulatory obligation of ENISA or of ENISA bodies pursuant to

text: Regulation (EU) 2019/881

text: . ENISA has the right to alter, update or remove the publication or any of its contents. It is intended for information purposes only and must be accessible free of charge. All references to it or its use as a whole or in part must mention ENISA as the source. Third-party sources are quoted as appropriate. ENISA is not responsible or liable for the content of the external sources, including external websites, referenced in this publication. Neither ENISA nor any person acting on its behalf is responsible for the use that might be made of the information contained in this publication. ENISA maintains its intellectual property rights in relation to this publication.

text: COPYRIGHT NOTICE

text: © European Union Agency for Cybersecurity (ENISA), 2026 Unless otherwise noted, the reuse of this document is authorised under the Creative Commons Attribution 4.0 International (CC BY 4.0) licence (https://creativecommons.org/licenses/by/4.0/).

text: This means that reuse is allowed, provided appropriate credit is given and any changes are indicated.

text: Cover image: © Shutterstock For any use or reproduction of elements that are not owned by the European Union Agency for Cybersecurity, permission may need to be sought directly from the respective rightholders. ISBN 978-92-9204-793-1, DOI 10.2824/0994553, Catalogue Number TP-01-26-010-EN-N

text: SME CRA Survey Report

text: Table of contents

text: About ENISA 2 Executive Summary 5 Introduction 7 Background on the Cyber Resilience Act 7 Scope and methodology 7 1. Survey population 9 1.1 Geographical coverage and company profiles 9 1.2 Scope of the Cyber Resilience Act 11 2. Cyber Resilience Act awareness and understanding 12 2.1 Prior awareness of the Cyber Resilience Act 12 2.2 Understanding of Cyber Resilience Act obligations 13 3. Current practices and compliance readiness 15 3.1 Cybersecurity responsibility 15 3.2 Prior compliance activity and technical practices 15 4. Compliance challenges and support needs 18 4.1 Anticipated challenges 18 4.2 Demand for support measures 19 5. Product security maturity 22 5.1 Governance and documentation 23 5.2 Risk management and security by design and default 23 5.3 Vulnerability and patch management 24 5.4 Incident response and product life cycle management 25 5.5 Awareness, competence and skills 26

text: SME CRA Survey Report

text: 6. Communication and information channels 28 7. Findings and recommendations 29 7.1 Documentation and conformity assessment 29 7.2 Microcompanies as a distinct audience 29 7.3 Templates for technical documentation 29 7.4 Threat modelling and software bills of materials 30 7.5 Incident response and product life cycle management 30 7.6 Financial support 30 7.7 Guidance for small and medium-sized enterprises 30 Annex A: Questionnaire and results 31 Annex B: Abbreviations 44

text: SME CRA Survey Report

text: Executive Summary

text: The Cyber Resilience Act (CRA) ( ) introduces new cybersecurity requirements for products with digital elements placed on the EU market. With the regulation entering into application in December 2027, manufacturers, distributors and importers, including small and medium-sized enterprises (SMEs), will need to ensure that their products meet cybersecurity requirements throughout the product life cycle.

text: Since SMEs make up a large part of EU´s digital ecosystem, their ability to understand and implement the CRA will play an important role in the overall success of the regulation. At the same time, many smaller organisations face practical challenges related to resources, expertise, time and implementation capacity.

text: To help address this, the European Union Agency for Cybersecurity, ENISA, as part of the European Commission’s SME cybersecurity strategy, is working on practical guidance, tools and support activities tailored to the realities and needs of smaller organisations.

text: This report presents the findings of the ENISA SME CRA Survey, conducted in February and March 2026. The survey aimed to better understand:

text: ▪ how familiar SMEs are with the CRA; ▪ how well they understand the practical requirements of the regulation; ▪ what they are currently doing in terms of cybersecurity; ▪ what challenges they expect to face when working towards compliance.

text: The survey also gathered feedback on the support SMEs need and established a baseline for their maturity in product security practices.

text: A total of 194 ( ) organisations responded from 31 countries / geographical groupings.

text: The sample includes SMEs, covering microcompanies (1–9 employees), small companies (10–49 employees) and medium-sized companies (50–249 employees), in line with the European Commission definition of SMEs ( ).

text: Key findings

text: • There is a clear gap between awareness and practical readiness. The results showed that awareness of the existence of the CRA is relatively high, with 66 % of respondents stating that they had heard of it before the survey. However, the results indicate that this does not translate into a strong understanding of what the regulation requires in practice. The levels of understanding

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text: drop in more detailed areas, for example in the conformity assessment and compliance topic, where 54 % of the replies indicated limited or no understanding. Understanding is also low in relation to the required documentation, with 42 % indicating limited or no understanding. • The size of the enterprise is the most consistent factor influencing the level of maturity. Across all five domains ( ) in the survey, medium-sized companies scored about 1 point higher than microcompanies on average. At the same time, about half of microcompanies are still at level 1 or 2 ( ), meaning they either do not have formal processes in place or are handling product security in a more improvised way. • Incident response and product life cycle management is the weakest area overall. The average score is 2.6 out of 5. More than a third of microcompanies have no incident response plan. No microcompany reported a formally enforced product life cycle policy. • Practical templates are the most requested form of support. Technical documentation templates and secure development templates were each requested by more than 70 % of respondents. Only 3 out of all respondents said they needed none of the listed templates. • The challenge for SMEs is not only understanding the CRA requirements, but also

text: managing the time and resources needed to implement them and the cost involved.

text: Financial support was selected by 142 of the respondents who answered the open support question, the joint highest figure for any single item in the support needs section alongside support in terms of templates and checklists for required technical documentation. • SMEs do not rely on a single source of CRA information. SMEs prefer different channels to get information about the CRA. This means that effective outreach will require a combination of communication formats and platforms.

text: SME CRA Survey Report

text: Introduction

text: Background on the Cyber Resilience Act

text: Microcompanies and small and medium-sized enterprises (SMEs) ( ) make up the majority of manufacturers, distributors and importers of products with digital elements in Europe. Manufacturers, large and small, also rely on SMEs as their suppliers. With the Cyber Resilience Act (CRA) ( ) entering into application in December 2027, manufacturers of products with digital elements, including SMEs, will need to ensure the cybersecurity of their products. The European Commission and the European Union Agency for Cybersecurity, ENISA, aim to support the implementation of the CRA by SMEs ( ).

text: It is essential to understand the perspective of SMEs to ensure appropriate support and make sure that the guidelines being developed are practical and usable.

text: The CRA is a new EU regulation that introduces cybersecurity requirements for all products with digital elements placed on the EU market. Its aim is to ensure that software and hardware are designed securely, include proper vulnerability management and receive necessary security updates throughout their life cycle. The CRA affects manufacturers, importers and distributors of software and hardware products of all sizes, including SMEs.

text: ENISA supports the European Commission and EU Member States in strengthening cybersecurity across Europe. As part of the Commission’s SME strategy on cybersecurity, ENISA provides practical guidance, tools and expertise to help smaller companies understand and meet new cybersecurity requirements, including those introduced by the CRA.

text: This report presents the results of a survey conducted among SMEs to assess their awareness of and preparedness for the CRA. The objective of the report is to understand how SMEs interpret the requirements of the regulation in practice, where they feel confident and where challenges are emerging.

text: Scope and methodology

text: The report is based on responses collected through a structured survey of SMEs across different countries, sectors and company sizes. The survey covers awareness of the CRA, understanding of its requirements, existing cybersecurity practices, organisational responsibilities and anticipated challenges related to compliance. It also includes an assessment of maturity across five domains ( ).

text: Maturity is assessed through a set of questions for each domain, scored on a scale from 1 to 5. The scale reflects levels of development, from ad hoc or non-existent practices to structured and

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text: consistently applied processes. Domain scores are calculated as the average of the scores for the relevant questions.

text: The survey received 194 responses. For multi-select questions, counts reflect how many respondents selected each option, so totals may exceed 194. As participation was voluntary and limited to professionally engaged respondents, the results should not be considered representative of the

text: wider EU SME population.

text: The report begins with an overview of the respondent profile, followed by an assessment of respondents' awareness and understanding of the CRA. It then explores current practices and levels of preparedness before examining the key challenges SMEs expect and the types of support they require. The analysis also considers organisational maturity levels and preferred communication channels. The report concludes with a set of recommendations based on the findings.

text: Where relevant, qualitative input has been used to complement the survey results and provide additional context.

text: Limitations. As participation was voluntary, the sample is likely to reflect a more engaged group of SMEs. This should be considered when interpreting the findings, as overall levels of awareness and preparedness across the broader SME population may be lower.

text: SME CRA Survey Report

text: 1. Survey population

text: The following section describes the SMEs that responded to the survey. This population is an important factor in interpreting the results, since gaps in maturity and support needs may differ significantly depending on company size, market reach and role in the supply chain.

text: 1.1 Geographical coverage and company profiles

text: The survey received responses from 31 countries and geographical groupings. In total, 25 EU Member States are represented, alongside Norway, Switzerland and the United Kingdom. In addition, respondents reported operating EU-wide and EEA-wide. Two respondents indicated that they operate globally outside Europe.

text: The largest shares of responses were from companies operating across multiple Member States, with 30 responses (15 %), and in Germany, with 29 (also 15 %). France, Poland and Sweden each contributed 11 responses, while Austria provided 10. Belgium and Finland are represented by 8 responses each.

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text: 1.2 Scope of the Cyber Resilience Act

text: One of the aims of the survey was to gain an understanding of the overall awareness of the CRA – that is, whether SMEs know the regulation exists and if they consider themselves to fall within the scope of the regulation. In total, 135 respondents (70 %) replied that they are in the scope of the CRA. At the same time, there is still some uncertainty: 39 respondents (20 %) were not sure and 20 (10 %) believed that the CRA does not apply to them.

text: The results suggest that, although there is general awareness of the CRA, there is still some confusion among SMEs when it comes to determining whether and how the regulation applies to them in practice.

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text: 2. Cyber Resilience Act awareness and understanding

text: This section analyses how SMEs rate their understanding of what the CRA requires in practice in terms of product security. The responses have a consistent pattern. SMEs’ awareness of the regulation does not necessarily translate into confidence about what they need to do to comply with it.

text: 2.1 Prior awareness of the Cyber Resilience Act

text: Some level of prior awareness of the CRA was reported by the SMEs. In total, 128 out of 194 respondents (66 %) indicated that they were aware of the regulation before taking the survey. However, this primarily reflects general awareness of its existence rather than a detailed understanding of its requirements.

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text: 2.2 Understanding of Cyber Resilience Act obligations

text: Responses about SMEs’ understanding of specific CRA topics were more mixed. Across all areas, most SMEs rated their knowledge as moderate or limited. Higher ratings were more common for broader topics. Understanding of essential cybersecurity requirements and of obligations in relation to vulnerability handling were assessed as good or very good by 31 % and 28 % of respondents, respectively. Understanding of obligations in relation to secure development followed at 29 %.

text: Understanding is lower when it comes to documentation and conformity assessment. Only 13 % of respondents report a good or very good understanding of documentation requirements, and 14 % for conformity assessment.

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text: 3. Current practices and compliance readiness

text: This section brings together three elements: responsibility for cybersecurity within the organisation, steps already taken towards compliance and the technical practices currently in place. Taken together, they show the SMEs’ starting point as they begin to work towards CRA compliance.

text: 3.1 Cybersecurity responsibility

text: Having a person responsible for cybersecurity is strongly linked to company size and aligns closely with higher maturity scores across all five domains covered in the survey.

text: 93 % of medium-sized companies reported having an internal staff member responsible for cybersecurity. In contrast, 57 % of microcompanies said that they have no designated responsibility for cybersecurity at all.

text: This gap helps explain many of the maturity differences seen in Sections 4 and 5. For microcompanies in particular, guidance needs to be designed for organisations that may not have any in-house cybersecurity expertise. It should avoid assuming prior knowledge of security frameworks or specialised terminology.

text: 3.2 Prior compliance activity and technical practices

text: Most respondents report some level of prior compliance activity. Ensuring compliance with International Organization for Standardization standard 27001 is the most common, mentioned by 101 respondents (52 %), followed closely by measures related to the General Data Protection Regulation (94 respondents, 48 %) and internal security audits (86 respondents, 44 %). European Community conformity (CE) marking has been undertaken by 62 respondents (32 %), and product-specific

text: SME CRA Survey Report

text: certification such as under Common Criteria or the EU cybersecurity certification (EUCC) scheme has been undertaken by 44 respondents (23 %). 32 respondents (16 %) have undertaken no formal compliance activity whatsoever. The rate of no prior compliance is significantly higher among microcompanies (25 %) and small companies (22 %) than among medium-sized ones (6 %).

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text: 4. Compliance challenges and support needs

text: This section analyses where companies expect to have the most difficulties, especially when it comes to integrating security by design into their products. It also highlights the areas that companies consider the most challenging and the types of support they would find most useful. These insights provide an indication of where guidance could be most effectively targeted.

text: 4.1 Anticipated challenges

text: Only 21 of respondents (11 %) said they are confident they will not face difficulties when integrating security by design into their products and processes. The majority are not that confident. Nearly half (91, 47 %) expect to face challenges, while 62 (32 %) remain unsure. This indicates that overall confidence in current readiness is low.

text: Documentation requirements and conformity assessment procedures are the most commonly reported challenges, with each selected 128 times by respondents. Resource constraints and financial impact also emerge as major concerns, together accounting for more than 200 selections. This suggests that the expected cost and resource burden of compliance is a significant issue for SMEs, regardless of their current level of technical maturity. In addition, product classification was identified as a challenge by 73 respondents, reinforcing earlier findings that many SMEs remain uncertain about whether and how the CRA applies to their products or services.

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text: The overall results in this area suggest that SMEs are facing challenges not only in implementing technical measures, but also in navigating the complexity of the regulatory requirements.

text: 4.2 Demand for support measures

text: The survey results indicate a consistently high demand for support across all areas, with very few respondents stating that they do not need additional assistance. Overall, SMEs appear to prioritise practical and easy-to-apply forms of support over general or purely theoretical guidance.

text: Templates were selected as the most requested form of support. In particular, respondents highlighted the need for templates related to technical documentation (73 %), secure development practices (71 %) and vulnerability-handling processes (56 %). There is also significant demand for technical tools that could assist with compliance assessments, identified by 68 % of respondents. At the same time, many SMEs are seeking clearer and more structured explanations of regulatory requirements. Step-by-step guidance for CRA documentation was requested by 66 % of respondents, while explanations of obligations, explanations of organisational roles and guidance on conformity assessment procedures were each selected by approximately 59 %.

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text: Financial support was selected by the largest number of respondents. This reinforces the earlier finding that cost and resource challenges are major concerns for SMEs. Companies are looking not only for clarity around the CRA requirements, but also for ways to make compliance more manageable, less time-consuming and more affordable in practice.

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text: 5. Product security maturity

text: This section assesses initial maturity levels using a five-point scale based on 17 questions. These cover governance and documentation; risk management and security by design; vulnerability and patch management; incident response and product life cycle management; and awareness, competence and skills. The scale had five values, from level 1, where no processes are in place, to level 5, where processes are optimised, integrated and continuously improved.

text: Table 12 shows where respondents currently stand. It shows the shares of organisations operating at the lowest two levels (no formal process or ad hoc practices) and the highest two levels (managed and optimised), along with average scores for each domain by company size group. This serves as a useful reference point before moving into the more detailed findings that follow.

text: In terms of average maturity score, the weakest area across companies of all sizes is incident response and product life-cycle management. Governance and documentation shows the largest gap between microcompanies and medium-sized companies. For microcompanies, risk management and security by design has the second-lowest average score of any domain, at 2.4. It is also notable that none of the microcompanies have reached level 5 in incident response, product life cycle management or staff training.

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text: 5.1 Governance and documentation

text: This topic covers four main areas: written cybersecurity rules related to product security, clearly defined responsibilities for security, maintenance of product-level technical documentation, and regularly reviewed product security and documentation quality.

text: The most visible aspect in this area is the difference between company sizes. 64 % (level 4 and 5) of medium-sized companies report having written rules that are also followed in practice. Microcompanies are less developed in this area: more than half of respondents are at the lower two maturity levels, meaning that formal processes are either missing or handled in a more informal and ad hoc way.

text: The results also show lower maturity around technical documentation topics. Many SMEs indicated that their documentation is not yet fully complete or consistently maintained across products. At the same time, the level of detail required under CRA Annex VII appears to go beyond what most SMEs currently have in place.

text: 5.2 Risk management and security by design and default

text: Practices related to risk assessment and secure development vary across respondents. The survey examined whether risk assessments inform design decisions, whether security is considered early in development and whether security checks are carried out before release.

text: Risk assessment has lower levels of maturity, especially among smaller organisations. Many microcompanies either do not assess risks in a structured way or rely on informal approaches, and none have reached level 5. Similar gaps appear in development practices. Security is not consistently built in from the beginning, and in some cases is introduced later in the process. Around 24 % of microcompanies report addressing cybersecurity risks at a later stage despite the security by design approach of the CRA. This suggests that security is often still treated as a separate step rather than an integral part of product development.

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text: Medium-sized companies generally report more-developed practices in terms of using security by default principles, with 49 % reaching maturity level 4 or 5. At the same time, organisations operating with regularly reviewed and consistently maintained processes remain in the minority. This suggests that, while many companies have started introducing relevant measures, these practices are not yet consistently integrated into day-to-day operations.

text: 5.3 Vulnerability and patch management

text: The survey identified noticeable differences in how organisations manage vulnerabilities and software security updates. Questions focused on vulnerability tracking, update distribution, and the recording of identified issues and remediation activities.

text: The largest differences appear in vulnerability tracking. Many microcompanies still rely on informal or reactive methods, and formal processes are often missing altogether. Consequently, a large share of respondents remain concentrated in the lower maturity categories. Medium-sized companies show a more balanced distribution across maturity levels and are more likely to report established and structured procedures. Nearly half (48 %) fall within level 4 or 5.

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text: The findings show a gap between smaller and larger SMEs. Microcompanies are more often positioned at lower maturity levels, where processes are still informal or only partly established, while medium-sized organisations generally demonstrate more structured and mature practices. At the same time, fully integrated and consistently applied practices remain relatively uncommon across the sector overall.

text: Software update management shows higher maturity overall, although differences between smaller and larger SMEs remain visible. Medium-sized companies more often report structured and wellestablished update management practices, while microcompanies are still more likely to rely on less mature or only partially formalised approaches. Fully mature practices remain uncommon among the smallest organisations.

text: A similar pattern can also be seen in record-keeping practices. Many respondents reported that formal record-keeping processes either are missing or rely on informal and scattered documentation. Even in organisations where procedures exist, records are not always maintained in a fully consistent or systematic way.

text: 5.4 Incident response and product life cycle management

text: This area received the lowest average score (2.61). It covers practices related to incident response planning, product life-cycle management policies and the use of lessons learned from past incidents.

text: The findings show particularly low levels of maturity among microcompanies. More than one third (36 %) reported having no incident response plan in place, while only 2 % indicated that their plans are tested and regularly reviewed.

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text: Medium-sized companies demonstrate comparatively stronger practices, with 43 % reporting the existence of a documented incident response plan and 21 % indicating that their processes are either regularly tested or integrated into broader governance structures. However, even among these organisations, consistent testing and ongoing operational use remain relatively limited.

text: Product life cycle management shows similar patterns. Among microcompanies, 58 % either lack a formal policy or manage it informally, and none has reached level 5. This means that many microcompanies will need to introduce a formal policy where none currently exists, including provisions for support periods and end-of-life timelines.

text: 5.5 Awareness, competence and skills

text: People-related factors play an important role in product security. The survey covered training, security culture, threat awareness and engagement with the wider cybersecurity community.

text: Training remains a weak area. None of the microcompanies or small companies reported having formal, role-specific and documented training in place. Among medium-sized companies, only 12 % have reached that level. In practice, knowledge is most often shared informally, particularly in microcompanies.

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text: SME CRA Survey Report

text: 6. Communication and information channels

text: The survey also explored how SMEs access information and the role of industry associations. The sample included 90 members and 84 non-members of industry associations, indicating that a substantial share of SMEs operate outside formal association networks.

text: The findings show a strong preference for practical and directly applicable support. Hands-on guidance and templates were identified by 134 respondents (69 %), making them the most requested form of assistance. Training sessions and webinars followed closely, selected by 116 respondents (60 %), while 110 respondents (57 %) highlighted the importance of clear information on timelines and implementation deadlines. In addition, 109 respondents (56 %) expressed interest in sector-specific examples and good practices. Taken together, the results suggest that SMEs are primarily seeking support that can be easily translated into practical action within their organisations.

text: The survey results show that SMEs rely on a range of different information channels rather than one clearly preferred source. Webinars and online sessions are used most frequently, selected by 111 respondents (57 %). EU-level websites and helpdesks were mentioned almost as often, by 109 respondents (56 %), followed closely by national cybersecurity authorities, selected by 106 respondents (55 %). Industry associations are used by 90 respondents (46 %), while ENISA channels were identified by 72 respondents (37 %). Overall, usage is fairly evenly distributed across the different channels, with no single source standing out as dominant.

text: The findings further indicate that most respondents use multiple information sources at the same time rather than relying on a single communication channel. National authorities, industry associations and EU-level platforms are commonly consulted in parallel. This suggests that outreach efforts are likely to be more effective when information is distributed across several channels rather than confined to a single central source.

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text: 7. Findings and recommendations

text: Around two thirds of SMEs (66 %) stated that they were familiar with the CRA before participating in the survey, suggesting a relatively broad level of general awareness among the respondents. However, this awareness does not yet seem to translate into a deeper understanding of what the CRA will actually require. Across the topics covered in the survey, respondents most often described their knowledge as moderate or limited, with the lowest confidence levels reported in areas such as conformity assessment and technical documentation.

text: The following sections examine these findings in more detail and present recommendations aimed at addressing the identified gaps and support needs.

text: 7.1 Documentation and conformity assessment

text: Around two thirds of respondents (66 %) reported that they were familiar with the CRA before taking the survey.

text: Despite this, the results show that SMEs’ understanding of specific requirements is limited. Lower levels of understanding are reported in areas such as conformity assessment and technical documentation. These are the areas with the most clearly defined procedural requirements, yet more than half of respondents described their understanding as limited. The same pattern appears across all company size groups and is most pronounced among small companies, with 62 % reporting limited understanding of conformity assessment.

text: The same trend emerges in several parts of the survey. Documentation and conformity assessment rank lowest in terms of understanding, while also appearing at the top of both anticipated challenges and requested support. This points to a clear priority. General guidance on topics like risk assessment or vulnerability handling is useful, but on its own it is often not enough. Many SMEs are looking for more practical support, especially around how to create the documentation and processes required for CRA compliance in practice.

text: 7.2 Microcompanies as a distinct audience

text: Among microcompanies, 57 % report that no-one in the organisation is specifically responsible for cybersecurity. Across all domains measured, the maturity gap between microcompanies and mediumsized companies is roughly one full point on a five-point scale. This is not a single issue that can be addressed with one targeted measure. It reflects a more structural constraint.

text: In many microcompanies, the person expected to deal with CRA requirements is also responsible for development, customer management and day-to-day operations. They need practical tools that help non-specialists get started without reading the full document upfront.

text: 7.3 Templates for technical documentation

text: 73 % of respondents requested templates for required technical documentation, and 71 % requested templates for documenting secure development practices. Both figures are higher than the demand for written guidance materials, tools or regulatory explanations. When given a list of potential outputs and asked to select what would actually help, the respondents chose templates by a clear margin. The four

text: SME CRA Survey Report

text: types listed in the survey with the highest demand, covering technical documentation, secure development practices, vulnerability-handling processes and risk assessment, were each selected by more than half of all respondents. Only 3 of the respondents said they needed none of the listed templates.

text: 7.4 Threat modelling and software bills of materials

text: Only 24 % of respondents report using threat modelling and 35 % maintain a software bill of materials. These are less widely used than more familiar practices such as code review (42 %) and secure coding guidelines (43 %). Neither practice fits easily into the typical workflow of a small team. Addressing this is less about further explaining their importance and more about showing how they can be applied in practice. Simple, practical examples based on realistic product scenarios, using freely available tools, would probably make adoption easier for SMEs without adding significant cost.

text: 7.5 Incident response and product life cycle management

text: This is the lowest-scoring area across all SME size groups in the survey, with an average of 2.6 out of 5. Among microcompanies, 36 % said they do not have an incident response plan at all. CRA compliance may therefore be facilitated by means of a simple and practical incident response template tailored to small organisations. This should be accompanied by clear guidance on when and how to use ENISA’s Single Reporting Platform.

text: 7.6 Financial support

text: Out of all respondents who answered the open question on support needs, 142 identified financial support as a priority. This is the highest figure reported for any single item in this section. The responses indicate that SMEs are working with limited time and resources. As a result, requests for guidance appear to be driven more by regulatory obligations than by organisational capacity. This has implications for how guidance should be designed. It should provide a practical, step-by-step roadmap that companies can realistically follow. It also needs to be easy to use, without requiring companies to rely on additional tools, external support or consultants, and it should be freely accessible.

text: 7.7 Guidance for small and medium-sized enterprises

text: 50 % of respondents are not members of any industry association, so the distribution of guidance through association networks alone would miss roughly half the target audience. ENISA’s own channels reach 37 % directly. Webinars and online sessions ranked first among the preferred information channels (111 respondents, 57 %), followed closely by EU-level websites (109, 56 %) and national cybersecurity authorities (106, 55 %). The three leading channels are almost equal in reach, which confirms that national authorities and industry associations need to be treated as active distribution partners rather than secondary audiences. An initial webinar or online session should accompany each major guidance publication and sector-specific examples should be built into guidance materials wherever possible; 109 respondents explicitly asked for use cases relevant to their sector.

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text: Annex A: Questionnaire and results

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text: Maturity related questions

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text: Annex B: Abbreviations

text: CE European Community conformity CRA Cyber Resilience Act (

text: Regulation (EU) 2024/2847

text: ) EEA European Economic Area ENISA European Union Agency for Cybersecurity EU European Union EUCC European Common Criteria-based cybersecurity certification scheme (EUCC) GDPR General Data Protection Regulation ICT Information and Communication Technology IEC International Electrotechnical Commission ISO International Organization for Standardization NIS2

text: Directive (EU) 2022/2555

text: on measures for a high common level of cybersecurity across the Union (Network and Information Systems Directive 2) SME Small and medium-sized enterprise

text: TP -01 -26 -01 0- EN -N

text: ABOUT ENISA

text: ENISA

text: European Union Agency for Cybersecurity

text: Athens Office

text: Agamemnonos 14 Chalandri 15231, Attiki, Greece

text: Brussels Office

text: Rue de la Loi 107 1049 Brussels, Belgium

text: enisa.europa.eu