The Cyber Resilience Act (CRA) is fundamentally changing how companies must prove the security of their digital products. In the future, security will no longer be seen as a one-off measure, but will be required consistently throughout the entire product life cycle: from design and development to operation, maintenance and support.
Many manufacturers are faced with the same question: How can the new requirements be implemented in a verifiable manner without unnecessarily slowing down or complicating development and operating processes?
Our recommendation based on our experience: Rely on threat modeling. Used correctly, threat modeling is evolving from a purely mandatory compliance topic to an effective accelerator for well-founded, comprehensible security decisions.
Cyber Resilience Act at a Glance
With the Cyber Resilience Act, the EU requires manufacturers of products with digital elements to comply with the following, among other things:
- Security by Design and Secure by Default
- a documented cyber security risk assessment
- structured vulnerability and incident management.
The timeline is clearly defined: The first reporting requirements for actively exploited vulnerabilities and serious security incidents will take effect on September 11, 2026. All other requirements must be fully implemented by December 11, 2027.
You can find out which companies and products are specifically affected and how the CRA fits into other regulations in our blog article 7 Questions About the Cyber Resilience Act (CRA).
Why the Cyber Resilience Act Is Fundamentally Changing Security Decisions
The CRA does not use a rigid checklist of measures. Instead, it calls for a risk-based approach. Manufacturers must clearly explain the cybersecurity risks arising from the product, its intended use, and its operating environment, and how appropriate security measures are derived from these risks.
The CRA does not prescribe which method should be used for this. What is crucial is a structured, comprehensible basis for decision-making that is maintained throughout the product life cycle (PLC). This shifts the focus from not only the what, but above all the why of security decisions.
Against this background, threat modeling is considered a recognized method for risk-based security assessment within the meaning of the Cyber Resilience Act.
Threat Modeling: From Mandatory Compliance Topic to Accelerator
This is exactly where threat modeling becomes the central lever for CRA implementation. Accompanied by security experts, it supports you in deriving security requirements from realistic threat scenarios in a targeted, risk-based and comprehensible manner.
Essentially, it answers three relevant questions:
- How is the product structured (components, interfaces, data flows)?
- Where can it realistically be attacked (threats, attack routes, abuse scenarios)?
- Which security measures are required and which are not (clear prioritization)?
Threat modeling thus provides exactly the structured and risk-based basis for decision-making that the Cyber Resilience Act requires. At the same time, it accelerates implementation: risks and measures are prioritized at an early stage, decisions are documented in a comprehensible manner, and coordination and follow-up work costs are significantly reduced.
Implementing CRA Requirements with Threat Modeling
The central articles and annexes of the regulation in particular demonstrate how threat modeling supports the requirements of the CRA in practice:
Art. 13 – Cyber Security Risk Assessment
Threat modeling covers exactly the elements that Art. 13 requires: the analysis of risks based on the intended purpose, the foreseeable use, the operating environment and the assets to be protected. As a continuously updated risk assessment, the changes can be mapped in a targeted manner and transferred directly to the technical documentation.
Annex I (Part I) – Secure by Design and Secure by Default
Architecture decisions and security controls such as authentication, encryption or least privilege are derived and justified on a risk-based basis. This helps to implement effective measures without creating unnecessary complexity or over-engineering.
Annex I (Part I) – Attack Area Reduction, Logging and Monitoring
Threat modeling reveals which interfaces, ports and services are necessary. Functions that are not needed can be removed in a targeted manner, and logging and monitoring requirements can be derived from plausible attack scenarios.
Annex I (Part II) – Vulnerability Handling and Reporting
By linking threats, components, and controls, vulnerabilities can be prioritized more effectively. This supports effective patch management and creates the basis for timely reporting, for example, for the 24- and 72-hour reporting deadlines provided for in the CRA as well as the necessary follow-up.
Art. 13(4) – Justification of Derogations
Where CRA requirements are not applicable, the EU regulation requires a comprehensible justification. Threat modeling enables precisely this transparent, risk- or architecture-related documentation.
Nico Fechtner, usd Managing Consultant, sums it up as follows:
“Through threat modeling, we ensure that security decisions are based on transparent reasoning. Only after real threats have been identified are targeted measures derived in a second step, not the other way around. This saves effort, prevents over‑engineering and provides exactly the transparency that the CRA requires.”
Your Roadmap: Threat Modeling for Your CRA Compliance
In actual practice, a clearly structured approach has proven successful:
- Define scope and purpose: Define the product, its application scenarios and the operating environment. At the same time, it defines which values must be protected, such as data, core functions or interfaces. This forms the basis for the risk-based assessment according to CRA Art. 13.
- Create system and data flow diagrams: Comprehensible representation of components, interfaces, data flows and trust zones. The goal is a common understanding of the system, not complete detailed technical documentation.
- Identify and assess threats: Identify realistic threats and attack paths, including dependencies on third-party components and external services.
- Derive security measures in a targeted manner: Specific security measures are derived directly from the identified risks and assigned to the requirements of Annex I.
- Documenting decisions: Risks, measures, accepted residual risks and justified exceptions are recorded in a verifiable and comprehensible manner.
- Continuously maintain threat modeling: In the event of product changes, new vulnerabilities or security incidents, the threat model is updated in a targeted manner and used as a basis for decision-making.
Conclusion
The Cyber Resilience Act makes it clear that in the future, security decisions must be justified, documented and maintained in a risk-oriented manner throughout the entire product life cycle. Blanket measures are no longer sufficient for this.
Threat modeling thus becomes the central lever of CRA implementation. It combines risk assessment, architecture decisions and documentation and creates a reliable basis for security, compliance and product development.
Threat modeling not only supports initial CRA compliance, but also ongoing operations and compliance with reporting and response obligations.
Threat Modeling & CRA Compliance: How the usd Supports
We support you in structuring CRA requirements for your products and translating them into comprehensible and documented security decisions using threat modeling.
A typical starting point is the joint analysis of architecture, data flows, and realistic threat scenarios. This reveals risks, prioritizes measures, and documents decisions in a comprehensible manner.
Would you like to classify the CRA requirements for your products or establish threat modeling as an integral part of your development cycles? Please feel free to contact us.
