CRA Post-Market Surveillance: Building Continuous Security Monitoring Infrastructure

CRA compliance doesn't end at product launch. Manufacturers must continuously monitor their products for new vulnerabilities, emerging threats, and component risks throughout the support period. This requires dedicated monitoring infrastructure.

What Post-Market Surveillance Covers

• New CVEs in product components — Continuous correlation of your SBOM against vulnerability databases
• Upstream component changes — Monitoring open-source dependencies for security advisories, maintainer changes, or abandonment
• Threat landscape changes — New attack techniques that affect your product category
• Customer-reported issues — Structured intake and triage of security reports
• Exploitation indicators — Monitoring for signs your product is being actively exploited in the wild

Monitoring Infrastructure Architecture

Component Intelligence Platform

Central system that tracks every component across every product version. Integrates with: NVD, OSV, GitHub Security Advisories, vendor advisories, and commercial threat intelligence feeds. Automatically flags affected products when new vulnerabilities are published.

Coordinated Vulnerability Disclosure Infrastructure

Public-facing vulnerability reporting channel (security.txt, bug bounty program integration). Internal triage workflow with SLA tracking. Integration with the 24-hour ENISA reporting pipeline for actively exploited vulnerabilities.

Product Telemetry (Where Applicable)

For connected products: anonymous security telemetry collection (with user consent). Monitor for: anomalous behavior patterns, exploitation attempts, update adoption rates, and configuration drift from secure defaults.

The Long Game

This infrastructure operates for 5+ years per product. The cost of building it once and sharing across products is dramatically lower than managing post-market surveillance manually per product. This is infrastructure engineering, not compliance consulting.