Cyber Resilience Act: What Goes in the User Instructions and Technical File

If your product has software and connects to anything, the CRA likely matters to you. That includes industrial controllers, smart sensors, connected equipment, and devices with apps.

Many teams see the CRA as an engineering task. It is also a documentation task. The law asks you to explain security to users, and to prove it in a technical file. Someone has to write those documents.

This guide breaks down the paperwork in plain words. It is not legal advice. Confirm the details with counsel and the official text.

The CRA timeline in short

The Cyber Resilience Act is Regulation (EU) 2024/2847. It entered into force on December 10, 2024. It applies in stages.

• June 11, 2026: Rules for notifying conformity assessment bodies began to apply.
• September 11, 2026: Manufacturers must report actively exploited vulnerabilities and severe security incidents. This applies to products already on the market.
• December 11, 2027: Most other rules apply, including full requirements for products, documentation, and CE marking.

The reporting duty is already live. The documentation duties come next. Writing, review, and translation take time. Starting now keeps you out of a rush in 2027.

Which products does the CRA cover?

The CRA covers “products with digital elements.” That means hardware and software products that connect, directly or indirectly, to a device or network. Some product types have their own EU rules and are treated differently. Examples include medical devices and motor vehicles.

If you make connected equipment and sell in the EU, check your scope early. Our quick tool below can give you a first read.

The four document sets the CRA expects

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A first read, not legal advice. Confirm scope with counsel and the official text.

Think of the CRA paperwork in four parts. Each has a different reader.

1. Information and instructions for the user. Written for buyers and operators. Described in Annex II.
2. Technical documentation. Written for authorities and auditors. Described in Annex VII.
3. The EU declaration of conformity. A formal statement that the product meets the rules.
4. A software bill of materials (SBOM). A machine-readable list of software components in the product.

What the user instructions must cover

Annex II lists what you must tell users. The text must be clear. Users should be able to understand it in their own language. In broad terms, expect to cover the following.

Who you are and how to reach you

Give the maker’s name and contact details. Add a single contact point for reporting security problems. Say where users can find your vulnerability disclosure policy.

What the product is and what it is for

Name the product, type, and version. State the intended purpose. Describe the security environment the product expects. Explain known or foreseeable misuse that could create risk.

Where to find the declaration of conformity

Point to the internet address where users can read it.

What security support you offer, and until when

State the type of security support. State the end date of the support period. Industry guides say the support period should generally be at least five years, unless the product’s expected use time is shorter. Check the rule for your product. Tell users how long they will receive security updates.

How to use the product securely

Give step-by-step guidance for these tasks:

• Safe first setup (commissioning).
• Secure everyday use.
• Installing updates, and how updates affect security.
• Turning automatic updates on or off, where that is possible.
• Removing the product from service and wiping data safely.

Where to find the SBOM

If you choose to share the software bill of materials with users, say where they can get it.

Most of these items are normal manual content. The new part is the security angle. Many existing manuals say nothing about update policy, support dates, or data wiping.

What the technical documentation must show

The technical file is for regulators. It proves your product meets the rules. Annex VII sets out the minimum content. In plain terms, expect to include:

• A description of the product and its intended use.
• How you designed, developed, and tested it, including how you handle vulnerabilities.
• A cybersecurity risk assessment.
• Support period information and how you check for new vulnerabilities.
• Standards or specifications you applied.
• Test reports.
• A copy of the EU declaration of conformity.
• The software bill of materials.

The technical file must be ready before you place the product on the market. You also need to keep it up to date. And you must keep it available for authorities for the period the law requires.

Why the cost of getting this wrong is real

Penalties can be high. Summaries of the CRA say fines can reach up to 10 million euros or 2 percent of global annual turnover for some duties, including market-access and documentation duties. Higher amounts apply to core security requirements.

Beyond fines, bad documents slow sales. EU buyers and distributors may ask for proof. If you cannot supply it, deals stall.

A practical plan for documentation teams

1. Check scope. List products with software or connectivity. Mark which ones ship to the EU.
2. Gather what exists. Pull manuals, release notes, update policies, and risk files. Note what is missing.
3. Add a security chapter. Create a reusable section for setup, updates, support dates, and decommissioning.
4. Set a document owner. Security, engineering, and documentation must agree on who approves changes.
5. Link versions. Tie each manual revision to a software release. Our guide to updating manuals after product changes shows how.
6. Plan languages. Decide which languages you need and build review time in.

For a wider view of writing for products that run software, see our article on documentation for connected products.

Writing tips for security instructions

• Use short steps. One action per step.
• Name things exactly. Use the same menu and setting names as the product.
• Say why it matters. A short reason helps users follow security steps.
• Show dates clearly. Put the end-of-support date where users will see it.
• Avoid jargon. Not every user is a security expert.
• Keep it findable. Put security guidance in one clear section, not scattered through the manual.

How CPG Documentation can help

We write and manage documentation for connected and software-driven products. We can add a security chapter to your existing manuals, align versions with software releases, and handle every language.

• Technical writing for user instructions and technical files.
• Translation so each market gets clear, matching instructions.
• Document production for version control and clean, consistent layouts.

Need help with the writing side of CRA readiness? Talk to our team.

Frequently asked questions

What is the Cyber Resilience Act?

The Cyber Resilience Act is an EU regulation that sets cybersecurity rules for products with digital elements. It covers hardware and software that connect to a device or network. It requires secure design, ongoing vulnerability handling, and clear documentation.

When do CRA documentation rules apply?

Vulnerability and incident reporting began on September 11, 2026. Most other rules, including documentation and CE marking, apply from December 11, 2027.

What must the CRA user instructions include?

They must include the maker’s contact details, a contact point for reporting vulnerabilities, the product name and version, the intended purpose, the end date of security support, and guidance on secure setup, use, updates, and removal from service. They should also say where to find the declaration of conformity.

What is in the CRA technical file?

The technical file includes a product description, design and development details, a cybersecurity risk assessment, vulnerability handling information, test reports, applied standards, the declaration of conformity, and a software bill of materials.

Does the CRA apply to US manufacturers?

It applies to products placed on the EU market. If you sell connected products to EU customers, directly or through distributors, you may be covered. Check your product scope with counsel.

Do we need to translate CRA instructions?

The instructions must be easy for users to understand, so plan for the languages of your target markets. Rules on language can vary by country. Check each market before you publish.

This article is general information, not legal advice. Confirm scope, dates, and duties against the official regulation and with qualified counsel. Further reading: CRA compliance guide, CRA obligations for manufacturers.