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hermes-brain/projects/passepartout/strategy/compliance/cra.org
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CRA (EU Cyber Resilience Act)

transaction." First-mover advantage: wallets are being built now; the provider that integrates with the wallet standard first locks in the identity gate integration.

CRA (Cyber Resilience Act)

EU regulation (effective 2025-2027 phased). Mandates cybersecurity requirements for products with digital elements (hardware and software). Requires: secure-bydesign, vulnerability handling, security updates for minimum 5 years, SBOM (software bill of materials) disclosure, CE marking for cybersecurity.

Who must comply: Manufacturers, importers, and distributors of connected products sold in the EU. Categories: default (self-declaration), Class I (third-party audit), Class II (notified body assessment).

Penalties: Up to 15M EUR or 2.5% of global turnover for non-compliance with reporting obligations.

Why it matters: CRA's CE marking requirement creates a certification pipeline that the verification appliance can supply. If Passepartout's gate stack is itself CRA-compliant (verified by the evaluation harness), it becomes the compliance infrastructure for any product built on it. First-mover advantage: Class II products require notified body assessment — the bottleneck is notified body capacity. The gate stack's automated evidence pipeline bypasses the bottleneck.