CRA technical documentation

What the file needs to contain

The CRA specifies the general categories of information technical documentation must cover: a general description of the product and its intended purpose, design and development information, the cybersecurity risk assessment, a list of applied harmonised standards or technical specifications, the SBOM, and evidence of the vulnerability handling process, including how the manufacturer intends to support the product with security updates. The documentation must be retained for a defined period after the product is placed on the market, and must be available to market surveillance authorities on request.

Structuring the documentation as a chain, not a binder

The single biggest determinant of how quickly an assessment proceeds is whether the documentation reads as a connected chain — from identified risk, to the design or process decision addressing it, to the verification evidence confirming it — or as a set of loosely related documents produced by different teams at different times. Reviewers spend most of their time trying to reconstruct this chain when it is not made explicit; making it explicit is the single most effective thing a documentation owner can do.

• Product description: intended purpose, operating environment, interfaces, and reasonably foreseeable misuse.
• Risk assessment: methodology, identified risks, severity and likelihood, and the decisions taken in response.
• Essential requirements mapping: each applicable requirement linked to the design feature or process addressing it and the verification evidence confirming it.
• SBOM: component inventory in a machine-readable format, kept current with released versions.
• Vulnerability handling: intake, triage, disclosure and update process, with evidence that it operates.
• Update and support commitments: defined support period and the mechanism for delivering updates to deployed products.

Common evidence gaps

Documentation prepared late, after design and verification are complete, frequently loses the connective tissue between requirement and evidence — engineers can no longer reconstruct why a particular design choice was made, only that it was. A second common gap is a risk assessment that lists risks and mitigations without a visible methodology, which makes it difficult for a reviewer to judge whether the assessment was systematic or after-the-fact rationalisation. A third is an SBOM that reflects a snapshot rather than the shipped configuration, which undermines confidence in the vulnerability handling process built on top of it.

Building the documentation incrementally

Technical documentation is produced most efficiently as a by-product of the development process rather than as a separate late-stage exercise. Risk assessments should be captured as they are performed, verification evidence should be tagged to the requirement it satisfies at the point of test, and the SBOM should be generated automatically from the build pipeline rather than compiled manually. This approach also reduces the risk of documentation drifting from the actual shipped product, which is one of the more serious findings a reviewer can raise.

• Define the documentation structure and templates before development work generating the evidence begins.
• Assign ownership for each section to the team producing the underlying evidence, not to a single compliance function.
• Automate SBOM generation from the build system and version it alongside releases.
• Review the documentation chain periodically against the essential requirements, not only at the point of assessment.
• Retain documentation and evidence for the period required after the product is placed on the market, with clear version control tying documentation to a specific product configuration.

Documentation and the reporting obligations

The technical documentation and the vulnerability handling process are closely linked to the reporting obligations that apply from 11 September 2026. A queryable, accurate component inventory — the operational counterpart of the SBOM in the documentation file — is usually the deciding factor in whether a manufacturer can produce a credible 72-hour notification. Organisations preparing technical documentation should treat this operational dimension as part of the deliverable, not a separate workstream.

Frequently asked questions