By Editorial Staff
The landscape for connected products in Europe is undergoing a seismic shift. With the European Union’s Cyber Resilience Act (CRA) beginning its phased implementation, the regulatory burden on manufacturers and the operational realities for network operators are colliding. To navigate this new era of mandatory cybersecurity compliance, we sat down with Steven Offerein, VP of Product, Device Intelligence and Protection Services at CUJO AI, to dissect the implications of these rules.
For many in the telecommunications sector, the CRA has been viewed as a "2027 problem"—a distant hurdle tied to CE marking and product conformity. However, the reality is far more immediate. As of September 11, the first major obligations concerning the reporting of actively exploited vulnerabilities have come into force, creating a new, high-stakes operational environment for operators and manufacturers alike.
The Core Facts: A New Regulatory Mandate
The CRA is designed to raise the baseline security of all hardware and software products with digital elements. While the regulation primarily targets the manufacturers of these devices, the ecosystem surrounding the internet-connected home is complex.
Operators, who supply and manage millions of Customer Premises Equipment (CPE) units—gateways, routers, and modems—are increasingly finding themselves in the crosshairs. The regulation does not merely target "original" manufacturers; it also captures any entity that modifies a product in a way that impacts its cybersecurity profile or brands a device as its own. Consequently, many operators are effectively "manufacturers" under the eyes of the law, inheriting the full suite of reporting and compliance obligations.
"The CRA is a manufacturer’s law on paper, but it is an operator’s problem in practice," says Offerein. "The exploit traffic doesn’t stop at the manufacturer’s firewall; it flows through the operator’s network and into the customer’s home. The regulation formalizes the reporting, but it doesn’t change who is on the front lines of the incident."
Chronology of Compliance
The implementation of the CRA is not a "big bang" event but a multi-stage transition that requires immediate attention from leadership teams.
- September 11, 2026 (Immediate): The reporting obligations for actively exploited vulnerabilities and severe security incidents take effect. Crucially, these rules apply to all products currently on the market, not just those manufactured after this date. Manufacturers must provide an early warning to the relevant national CSIRT (Computer Security Incident Response Team) and ENISA within 24 hours, a detailed notification within 72 hours, and a final report upon resolution.
- December 2027 (The "Full" Deadline): This marks the application of broader requirements, including full conformity assessments, essential security standards, CE marking, and the definition of mandatory support periods for software updates.
The misconception that operators can wait until 2027 is the most significant strategic error currently being made by the industry. The 24-hour reporting window is an aggressive timeline that requires robust, pre-existing internal processes that many firms simply do not have in place.
The Visibility Crisis: Mapping the Connected Home
One of the most persistent challenges for operators is the "visibility gap." An operator may know exactly which gateways they have shipped to customers, but they rarely have a clear, real-time view of the hundreds of millions of connected devices residing behind those gateways.
"When a vulnerability disclosure lands, the difference between a crisis and a manageable situation is the ability to say, ‘We have 340,000 potentially affected devices across these markets,’ rather than, ‘We genuinely don’t know,’" Offerein explains.
The complexity of the modern smart home—filled with unmanaged IoT devices that lack consistent registration or identification protocols—makes this a gargantuan task. Traditional procurement databases are insufficient because they only track what was sold, not what is currently active, connected, and vulnerable within the home. Achieving this visibility requires continuous, population-scale monitoring that identifies devices by type, model, and firmware version.
Implications for Operators: From Remediation to Mitigation
When a vulnerability is disclosed, the operator’s path forward depends on the nature of the device. For CPE that the operator owns and manages, the response is relatively clear: prioritize and push the firmware update. However, for the myriad of third-party IoT devices—smart cameras, sensors, and appliances—the situation is far more tenuous.
The "Abandoned Device" Dilemma
A significant portion of the devices in the average European home are effectively "orphaned." Their manufacturers may have gone out of business, or the product may have reached the end of its support lifecycle while still being perfectly functional.
"This is the reality nobody likes to talk about," says Offerein. "The customer’s camera still streams, and their plug still switches, but the software is a sieve for vulnerabilities. The CRA will help for future products by forcing defined support periods, but it does nothing to fix the millions of existing, unsupported devices already in homes."
This creates an opening for network-level security. Since the gateway is the gateway to the internet, it is the ideal point to apply protection. By analyzing traffic at the network level, operators can block malicious activity targeting vulnerable devices, detect anomalies that indicate a compromise, and contain infected devices before they can join a botnet or threaten other devices in the home.
Changing the RFP and Lifecycle Management
The CRA is poised to fundamentally alter the procurement process for CPE. Historically, price and performance dominated Request for Proposal (RFP) criteria. Security and support lifecycles were often secondary considerations.
"That is going to change," Offerein notes. "When a gateway carries a defined support period, the end of support becomes a visible, contractual event. Operators must now decide: do we extend the support contractually, replace the hardware, or mitigate the risk through other means? Price can no longer be the only metric."
This shift may actually drive more sustainable practices. Instead of replacing hardware simply because the software has been abandoned, operators have a business case to demand longer support commitments from vendors. This avoids the environmental and financial waste of premature hardware retirement.
Essential Questions for Vendors
To prepare for this new environment, operators need to initiate a series of rigorous inquiries with their hardware and software vendors. Offerein suggests that the following questions must become part of every standard conversation:
- The "Manufacturer of Record" Question: Who is legally responsible for this product under the CRA—the vendor or the operator? Is this clearly documented in the contract?
- The Support Commitment: What is the committed support period, and what specifically does "support" include? Does it cover security patches for known vulnerabilities, or is it limited to critical bug fixes?
- Software Bill of Materials (SBOM): Can the vendor provide and maintain an accurate SBOM to facilitate rapid impact analysis when a new vulnerability is disclosed?
- Reporting Protocols: Is the coordinated vulnerability disclosure process established and tested? How quickly will the operator be notified of active exploitation?
Conclusion: Building the Foundation for Compliance
Compliance with the CRA is not a software plugin; it is a profound change in organizational culture and operational capability. No vendor platform can make an organization "CRA compliant" in isolation. Compliance requires a synthesis of legal accountability, formal processes, and deep technical visibility.
For operators, the mandate is clear: first, perform a legal audit of the product portfolio to define their role (manufacturer, importer, or distributor). Second, establish and rehearse incident response processes for the 24-hour reporting window. Finally, invest in the granular visibility required to transform a vulnerability disclosure from a chaotic fire drill into a structured, addressable operational task.
As the industry moves toward December 2027, the operators that win will be those that have mastered the balance between providing high-speed connectivity and acting as the primary guardian of the consumer’s digital home. Those that fail to build this visibility may find that the regulatory burden of the CRA becomes an unmanageable weight.
About Steven Offerein
Steven Offerein is the VP of Product, Device Intelligence and Protection Services at CUJO AI. With over 15 years of experience in the cybersecurity and telecommunications sectors, he has played a pivotal role in shaping security solutions for international markets. Before joining CUJO AI, he held senior leadership positions at F-Secure and TalkTalk, where he focused on the intersection of connected-home security and network-level protection.
