The CRA has teeth. Unlike earlier cybersecurity guidelines, this regulation comes with GDPR-level penalties and empowers market surveillance authorities to pull products from the market.
Penalty Structure
- €15 million or 2.5% of global turnover — For non-compliance with essential cybersecurity requirements
- €10 million or 2% of global turnover — For failure to meet other CRA obligations (reporting, documentation, etc.)
- €5 million or 1% of global turnover — For providing incorrect or misleading information to authorities
Market Surveillance Powers
National authorities can:
- Require product modifications or withdrawal from the market
- Order product recalls
- Prohibit or restrict product availability
- Conduct unannounced inspections
- Request technical documentation and test results
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The CRA leverages the existing EU market surveillance framework. If one member state identifies a non-compliant product, the information is shared across all member states through the RAPEX/Safety Gate system. There's no hiding in a single market.
Reputational Risk
Beyond fines, having a product pulled from the EU market signals security deficiencies to global customers. In B2B markets, CRA non-compliance will increasingly become a disqualifier in procurement evaluations.
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Luca Berton
