How to use the checklist
Review one actual product release with the product owner and engineering lead. Mark each item as evidenced, incomplete, not applicable with a rationale, or needing qualified review. Keep the artifact reference, owner and due date next to each decision. Revisit the list when the product or supported release changes.
- Define the product and intended purpose
- Identify the manufacturer and EU economic-operator roles
- Map EU sales channels and markets
- Record hardware, firmware, app and necessary remote processing boundaries
- Document the likely class against Annex III and Annex IV
- Select and review the conformity route
- Check external lab or notified-body scope
- Assign a product-security owner and substitute
- Inventory all supported releases
- Generate a machine-readable SBOM from the build
- Validate component names and versions
- Record vendored and backported components
- Connect SBOMs to immutable release identifiers
- Match public vulnerability information
- Check CISA KEV and ENISA EUVD information
- Triage product applicability with engineering
- Document VEX decisions and rationale
- Track remediation and verification
- Assess secure defaults and reset behaviour
- Review authentication and access controls
- Review confidentiality and integrity controls
- Check data minimisation
- Review availability and network impact
- Limit exposed interfaces and attack surfaces
- Assess exploitation mitigation
- Review logging and relevant opt-out
- Test secure deletion and data transfer
- Review update authenticity and integrity
- Plan automatic security-update behaviour and opt-out
- Publish a coordinated disclosure policy
- Publish and monitor a security contact and security.txt
- Record the Article 14 awareness timestamp process
- Confirm SRP access and coordinator route
- Prepare 24-hour and 72-hour draft templates
- Define separate final-report anchors for vulnerabilities and incidents
- Run a reporting drill including the backup owner
- Document the support-period rationale and end date
- Prepare Annex II user information
- Assemble Annex VII evidence and Annex V declaration draft
- Plan ten-year record and update-availability retention duties
The support-period minimum is not automatically sufficient for every product. Reporting already applies, while most remaining CRA obligations apply from 11 December 2027. Use the deadline guide and the reporting guide to interpret the relevant checks.
Keep a printable copy.
The PDF includes all forty checks with space for a review. We email a download link after your request. Your details are used to respond to this request, with no newsletter subscription.