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CRA Game-Specific Risk Assessment: A Conceptual Walkthrough

The EU Cyber Resilience Act (CRA) mandates that you, the game developer ("manufacturer"), perform a cybersecurity risk assessment for your game (Article 13, Paragraph 2). This isn't just paperwork; it's a foundational step to understanding and mitigating potential security weaknesses.

Why is it Crucial for Your Game?​

A risk assessment helps you identify:

  • What could go wrong (threats and vulnerabilities).
  • How likely it is to happen.
  • What the impact would be on your game, your players, and your business. This process informs how you apply the CRA's essential cybersecurity requirements (Annex I).

Conceptual Steps for a Game Risk Assessment​

This is not an exhaustive guide, but a way to think about it in the context of self-assessed games:

  1. Understand Your Game's Scope (Asset Identification):

    • What are the key components? (Client, server-side logic if any, databases).
    • What data does it handle? (Player accounts, game state, leaderboards, IAP details, user-generated content).
    • What are its connections? (Online authentication, multiplayer servers, third-party services like analytics or ad networks).
    • What is its intended purpose and foreseeable use/misuse? (Article 13, Paragraph 3).

  2. Identify Threats and Vulnerabilities (Threat Modeling for Games):

    • Common Game Threats: Cheating (memory editing, packet manipulation), account hijacking, data breaches (player info), denial of service on game servers, exploitation of bugs for unfair advantage.
    • Vulnerabilities: Bugs in your code (buffer overflows, input validation issues), insecure handling of player data, weak server configurations, vulnerable third-party libraries/SDKs.
    • Consider the essential requirements in Annex I: Where could your game fall short in areas like preventing unauthorized access, ensuring data confidentiality/integrity, or managing vulnerabilities?

  3. Analyze Risks (Likelihood and Impact):

    • For each threat/vulnerability, how likely is it to be exploited?
    • If exploited, what's the impact? (e.g., loss of player trust, financial loss from IAP fraud, reputational damage, non-compliance penalties).

  4. Determine Risk Treatment (Mitigation):

    • How will you address the identified risks? This is where you map risks to the CRA's essential cybersecurity requirements.
    • Examples: Implement stronger input validation (Annex I, Part I, Point 2f), encrypt player data (Annex I, Part I, Point 2e), set up a vulnerability disclosure policy (Annex I, Part II, Point 5).

  5. Document Everything:

    • The CRA requires the risk assessment to be documented and included in your technical documentation (Article 13, Paragraph 4; Annex VII). It should detail which essential requirements apply and how you meet them, or justify why one might not apply.

Living Document​

Your risk assessment isn't a one-time task. It needs to be updated when you add new features, integrate