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Cyber Resilience Act

Operating Systems Under the CRA: What EN 304 626 Means for OS Vendors

Commercial operating systems are classified as Important Class I. From Windows to Linux distributions, here's how the CRA affects OS development.

Luca Berton6 min read

Operating systems are the foundation of digital security. The CRA classifies commercial OS products as Important Class I under EN 304 626, requiring either harmonized standard compliance or third-party assessment.

Who's Affected

  • Microsoft Windows — Full CRA manufacturer obligations
  • Apple macOS/iOS — Full CRA obligations for EU market
  • Commercial Linux distributions — RHEL, SUSE, Ubuntu Pro
  • Chrome OS — Full obligations
  • Android — Google as manufacturer; OEMs have additional obligations

Community Linux Distributions

Non-commercial distributions (Debian, Arch, Fedora community edition) fall outside CRA scope as non-commercial FOSS. However, when a company packages and sells a commercial product based on these (e.g., Ubuntu Pro, RHEL from Fedora), the commercial product is in scope.

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Key OS-Specific Requirements

  • Secure boot chain with integrity verification
  • Kernel hardening and exploit mitigations
  • Mandatory access control frameworks
  • Automated security patch delivery
  • Application isolation (sandboxing, containerization)
  • Encrypted storage by default

Support Period Considerations

The CRA requires security updates for at least 5 years. This aligns well with enterprise Linux support cycles (RHEL: 10 years, Ubuntu LTS: 5 years) but may challenge consumer OS vendors who historically dropped support earlier.

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cra
operating systems
linux
windows
en 304 626

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18+ years experience · Ex-Red Hat & Dell · Speaker at KubeCon EU 2026

Luca Berton

Written by

Luca Berton

CEO at Open Empower. 18+ years building enterprise infrastructure at JPMorgan Chase, Red Hat & Dell. Author of 9 technical books. Speaker at Red Hat Summit and KubeCon EU 2026. Instructor on Coursera, Pluralsight & Udemy.

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