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Understanding the Impact of the EU Cyber Resilience Act on Business Operations for CISOs

The European Union's recent legislative effort, the Cyber Resilience Act, presents a formidable challenge and a significant compliance mandate for businesses operating within or selling into the EU market. This regulation marks a substantial shift in the way companies must approach cybersecurity, with a focus on the resilience of products throughout their lifecycle.

What the Cyber Resilience Act Entails

The Act mandates rigorous adherence to cybersecurity protocols for products that connect to networks, including both IoT devices and conventional software solutions. It encompasses detailed requirements for vulnerability management and incident reporting, aiming to reduce cyber risks associated with digital products.

Financial Implications and Penalties

Non-compliance with the new regulation carries severe penalties. Companies could face fines of up to €15 million or 2.5% of their global annual turnover, whichever is higher. These substantial fines underscore the EU's commitment to enforcing stringent cybersecurity measures, reflecting the high stakes involved in protecting consumer and business data.

Role of CISOs Under the New Regulation

Chief Information Security Officers (CISOs) are at the forefront of adapting to these changes. Their role involves not only ensuring compliance with the Cyber Resilience Act but also leading their organizations in the implementation of secure software practices. This includes the adoption of tools like Software Bill of Materials (SBOM), which offers transparency about software components and vulnerabilities, aiding in compliance and risk management.

Technological Solutions and SBOM

SBOM solutions, such as those provided by Codenotary, become crucial under the new act. These tools help in mapping out and understanding the components that make up software products, an essential step in managing vulnerabilities effectively. By leveraging SBOM, companies can better track the origin and status of each component, ensuring timely updates and patches are applied, thus reducing the risk of cyber threats.

Strategic Considerations for CISOs

  1. Risk Assessment: Conduct thorough risk assessments to understand where vulnerabilities lie and how they can impact compliance with the new EU regulation.
  2. Investment in Technology: Invest in robust SBOM tools that provide detailed insights into software components, which will be crucial for compliance.
  3. Training and Awareness: Ensure that all stakeholders, from developers to management, are aware of the implications of the Cyber Resilience Act and understand their role in maintaining cybersecurity resilience.
  4. Incident Response: Develop a proactive incident response strategy that complies with the Act's reporting requirements, ensuring that any breaches are swiftly and efficiently managed.


The introduction of the EU Cyber Resilience Act represents a significant shift towards more regulated and stringent cybersecurity measures across the EU. For CISOs, adapting to these changes is not just about compliance; it's about steering their organizations towards safer and more resilient digital practices. As the landscape of cyber threats continues to evolve, staying ahead of regulatory requirements and leveraging advanced technological solutions will be key to maintaining trust and ensuring the security of digital products.