The EU Cyber Resilience Act (CRA) and Biometric Access Control
With the Cyber Resilience Act (Regulation (EU) 2024/2847), the European Union introduces binding cybersecurity requirements for products with digital elements placed on the EU market.
The regulation is directed primarily at manufacturers. Cybersecurity must demonstrably be integrated into product design, the update architecture, and vulnerability management throughout the entire lifecycle.
For biometric access control systems, this means that architectural choices become decisive. Network connectivity, remote management, and cloud integration increase both the technical and legal complexity under the CRA. Systems with a limited attack surface, local decision-making, and controlled update processes generally align better with the essential cybersecurity requirements defined in Annex I of the regulation.
In addition, the CRA indirectly influences procurement processes and supplier assessments. Organizations that fall under the NIS2 Directive are required to actively assess their supply chain for cyber risks. Product architecture and lifecycle management therefore become explicit evaluation criteria. Under the CRA, cybersecurity becomes an architectural matter: choices in system design, interfaces, and update control determine the product’s compliance profile.
Based on the above, we arrive at five questions that we will address.
The 5 Most Frequently Asked Questions About the Cyber Resilience Act (CRA) in Biometric Access Control
Who must comply with the CRA?
The Cyber Resilience Act primarily targets manufacturers of products with digital elements placed on the EU market. This includes producers of hardware and software, including suppliers of access control systems, controllers, and embedded systems. The formal compliance obligation therefore lies with the manufacturer.
We do not manufacture anything. Why does this concern us?
The CRA places the compliance obligation on manufacturers. For your organization, this means that the cybersecurity quality of purchased products is no longer optional. The way a product is designed and maintained directly affects your operational and security risks.
For organizations that fall under NIS2, supplier risk is a legal component of the duty of care. For other organizations, this is increasingly becoming part of governance, insurance requirements, and contractual obligations.
We are not subject to NIS2. Why is this still relevant for us?
The cybersecurity quality of the products you purchase directly determines your operational risk. An access control system without structured maintenance, a controlled update policy, or with unnecessary network exposure can lead to disruption of business processes, data loss, and reputational damage. When biometric data is processed, this may also have implications under the GDPR.
How can I assess whether a supplier takes its CRA responsibilities seriously?
Ask for concrete technical substantiation: insight into product architecture, update policy, and vulnerability handling. The CRA responsibility and the associated documentation form the basis for evaluating a product in a substantive manner. If the answer remains vague or consists only of general statements without technical substantiation, the necessary transparency is missing.
Why might a manufacturer not have this properly in place?
Many digital products were designed years ago within a different technical and regulatory context. Architectures with broad network access, remote management, or limited update control were common at that time.
If such systems were not designed from the outset with lifecycle security and controlled update management as core principles, adapting them afterward can be technically complex or costly.
What does this mean for you as a user?
If an existing architecture is difficult to adapt, this can affect updates, security improvements, and future support. The technical foundation of a system directly determines how secure and future-proof it is.