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CRA for Solo Devs and Micro Software Businesses: Key Priorities

If you're a solo developer or running a micro-business (fewer than 10 employees), the Cyber Resilience Act (CRA) can seem daunting. While you are still required to comply, focusing on the most critical, high-impact requirements can make the process manageable.

Priority 1: Risk Assessment is Non-Negotiable​

Everything flows from your risk assessment (Article 13). Even a simple, documented assessment for your app or software component is better than none. Focus on:

  • What data does my app handle? What's the worst that could happen if it's compromised?
  • What are the most likely ways someone might attack my software?
  • How do the basic security requirements in Annex I apply?

Priority 2: Manage Your Dependencies (SBOM)​

Your small project likely relies heavily on open-source libraries. Their vulnerabilities are your responsibility.

  • Use a tool to generate a Software Bill of Materials (SBOM) (Annex I, Part II). Many free tools can do this.
  • Regularly check your dependencies for known vulnerabilities and update them.

Priority 3: Have a Vulnerability Reporting Channel​

You must have a way for people to report security issues (Article 13, Paragraph 17).

  • Set up a simple email address like [email protected].
  • Create a basic Coordinated Vulnerability Disclosure (CVD) policy page on your website.

Priority 4: Prepare Your Documentation as You Go​

Don't leave documentation until the end.

  • The CRA plans for a simplified technical documentation form for micro and small enterprises (Article 33, Paragraph 5). Use this when it becomes available.
  • Document your key design decisions, risk assessment, and support period rationale as you make them. It's easier than trying to remember everything later.

Penalty Derogation​

The CRA provides some relief. Micro and small enterprises are exempt from administrative fines for failing to meet the 24-hour early warning notification deadline in Article 14 (Article 64, Paragraph 10). This doesn't remove the reporting obligation, but it provides a safety net for the initial tight timeline.

Key Takeway​

For a solo dev or micro-business, prioritize a solid risk assessment, manage your third-party dependencies with an SBOM, set up a simple vulnerability reporting channel, and use the simplified documentation format when it's released.