Cyber Resilience Act technical documentation is the controlled evidence set that shows what product was assessed, which cybersecurity requirements apply, how the manufacturer addressed them, and which engineering and vulnerability-handling evidence supports that conclusion. Under Article 31 and Annex VII of Regulation (EU) 2024/2847, manufacturers must prepare it before placing a product with digital elements on the market, keep it updated where appropriate during the support period, and retain it for market-surveillance access.
What Article 31 requires
Article 31 does not define technical documentation as a single report or template. It requires all relevant data or details about the means used by the manufacturer to ensure that the product and the manufacturer's processes comply with the essential cybersecurity requirements in Annex I. Annex VII then defines the minimum content that must be present, as applicable to the product.
Three lifecycle rules matter operationally:
- the documentation must exist before the product is placed on the market;
- it must be continuously updated, where appropriate, at least during the support period; and
- the manufacturer must keep the technical documentation and the EU declaration of conformity available to market-surveillance authorities for at least ten years after the product is placed on the market or for the support period, whichever is longer.
This makes technical documentation a lifecycle record rather than a one-time release attachment. A manufacturer needs both a defensible baseline for the product placed on the market and a process for updating that baseline when security-relevant facts change.
Annex VII is the minimum evidence set
Annex VII lists eight categories of information. A practical documentation structure should make each category easy to locate without forcing reviewers to reconstruct the product from unrelated systems.
At minimum, as applicable, the documentation includes:
- A general product description. This covers intended purpose, software versions that affect compliance with essential cybersecurity requirements, hardware illustrations where relevant, and the user information required by Annex II.
- Design, development, production and vulnerability-handling information. This can include architecture, component relationships, vulnerability-handling processes, the SBOM, coordinated vulnerability disclosure policy, vulnerability contact evidence, secure-update solutions, production processes and monitoring.
- The cybersecurity risk assessment. It must show the risks considered and how the applicable Annex I Part I requirements were determined.
- Support-period reasoning. The record should contain the relevant information used to determine the product's support period.
- Standards and technical specifications. The documentation identifies harmonised standards, common specifications or relevant European cybersecurity certification schemes applied in full or in part, and describes other solutions used where those references were not applied.
- Test reports. These verify the product and vulnerability-handling processes against the applicable essential cybersecurity requirements.
- The EU declaration of conformity.
- The SBOM where applicable for market surveillance. Annex VII specifically provides for the SBOM to be supplied following a reasoned request from a market-surveillance authority when it is necessary to check compliance with Annex I.
The list is a minimum, not a requirement to duplicate the same evidence into eight separate documents. One controlled record can reference engineering artefacts, policies and test results, provided the relationship to the assessed product remains clear.
Build the documentation around an exact product baseline
The first practical risk is scope drift. Technical evidence loses value if a reviewer cannot determine which product, variant, software version or release it describes.
Start the file with an unambiguous product baseline:
- product name, type and internal identifier;
- responsible manufacturer legal entity;
- intended purpose and supported operating conditions;
- hardware variants and software or firmware versions relevant to compliance;
- product architecture and major interfaces;
- remote processing that belongs to the product context, where applicable;
- release date and market-placement context;
- user information and security instructions associated with that version; and
- links or identifiers for the evidence package supporting the baseline.
For software products, Annex VII explicitly calls out versions of software that affect compliance with essential cybersecurity requirements. That means a generic product-family document is not enough when materially different versions have different security properties, dependencies or controls.
A good baseline lets an engineer answer a simple question later: "Which exact evidence justified the conformity decision for this released version?"
Connect the risk assessment to requirement applicability
Article 13 requires the cybersecurity risk assessment to be included in the technical documentation. It also requires a clear justification when an essential cybersecurity requirement is considered not applicable.
The useful evidence chain is therefore not simply a risk register attached as a PDF. It should show how product context and risk decisions connect to applicable requirements and implementation evidence:
product context -> risk scenario -> Annex I applicability -> security control -> verification evidence -> residual-risk decision
For each requirement, record whether it applies, why that decision was made, which control addresses it, and what evidence verifies the control. When the answer is "not applicable", retain the justification rather than leaving a blank field.
This avoids a common documentation failure: the risk assessment says one thing, the requirements matrix says another, and the released product has changed since both were written.
Document vulnerability handling as an operating process
Annex VII treats vulnerability handling as part of the technical documentation, not as a separate post-market concern. The record should describe the processes the manufacturer has put in place and the evidence that those processes are usable for the product.
Relevant material includes:
- the SBOM and its relationship to the product or release;
- the coordinated vulnerability disclosure policy;
- evidence of a contact address for vulnerability reporting;
- intake, triage and remediation responsibilities;
- the technical approach used to distribute updates securely;
- how product and component vulnerabilities are assessed;
- how security updates are verified and released;
- how vulnerability decisions and remediation evidence are retained; and
- how production and monitoring processes are controlled and validated.
The purpose is not to copy every ticket into the technical file. The technical documentation should explain the controlled process and provide traceable references to the records that demonstrate it was applied.
Keep standards and alternative technical solutions explicit
Annex VII requires manufacturers to identify the harmonised standards, common specifications or relevant European cybersecurity certification schemes used to support conformity. If only part of a reference is applied, the applied parts need to be identified.
Where those references are not used, the manufacturer needs descriptions of the solutions adopted to meet the essential cybersecurity requirements, including other relevant technical specifications.
A practical standards register should therefore capture:
| Field | Example of what to record | | --- | --- | | Reference | Standard, common specification, certification scheme or internal technical specification | | Version | Exact edition or revision used | | Scope | Product, component, process or requirement covered | | Application | Full, partial or not applied | | Requirements | Annex I requirements supported | | Evidence | Design, test or process records demonstrating implementation | | Exceptions | Deviations, limitations and their justification |
The key control is version specificity. A statement such as "we follow industry standards" is not useful technical documentation because it does not identify what was applied to the assessed product.
Test reports should prove the applicable controls and processes
Annex VII requires reports of tests used to verify conformity of both the product and the vulnerability-handling processes with the applicable Annex I requirements.
The Regulation does not prescribe one universal test suite. Evidence should be proportionate to the product and risk assessment. Depending on the product, useful records can include security requirement verification, architecture review, access-control testing, update-path testing, vulnerability scanning, static or dynamic analysis, fuzzing, penetration testing, configuration validation, recovery testing or process exercises.
Each retained test record should identify:
- the product version or build tested;
- the requirement or risk being verified;
- the method and environment;
- the result and relevant findings;
- unresolved limitations or exceptions;
- remediation or acceptance decisions; and
- the accountable reviewer or approval.
A test report without a product version or requirement link is difficult to use later, especially after several releases.
Treat support-period reasoning and retention as separate controls
The support period affects more than vulnerability handling. Article 13 requires the information used to determine the support period to be included in the technical documentation, and Article 31 requires appropriate updates at least during that period.
Separately, Article 13 requires the technical documentation and EU declaration of conformity to remain available for at least ten years after market placement or for the support period, whichever is longer.
These are different controls:
- support-period evidence explains why the product has the support period it has; and
- retention ensures the documentation remains retrievable for the required duration.
For a long-lived industrial product, the support period may exceed ten years. In that case, a document-retention policy based on a fixed ten-year deletion rule would be insufficient.
Update the record without losing release history
Technical documentation must stay current where appropriate, but "current" should not mean silently overwriting the evidence for an older release.
A practical lifecycle model keeps a controlled current view while preserving prior baselines or superseded evidence where those records explain earlier products placed on the market. Define update triggers such as:
- a new product version or variant;
- changed intended purpose or operating environment;
- architecture or trust-boundary changes;
- security-relevant component changes;
- new or revised risk decisions;
- changes to applicable standards or technical specifications;
- material findings from security testing;
- vulnerability or incident information that changes the risk assessment;
- changes to update or vulnerability-handling processes; and
- a substantial-modification decision.
For each update, record what changed, why it changed, which product baseline is affected, and who approved the revised evidence.
Prepare for market-surveillance requests
Technical documentation is not only an internal engineering record. Manufacturers must keep it available to market-surveillance authorities and, following a reasoned request, provide the information and documentation necessary to demonstrate conformity.
That does not mean every internal engineering artefact must be published publicly. It means the manufacturer needs a controlled way to retrieve the relevant evidence and explain how it supports the product's compliance with Annex I.
The SBOM deserves specific handling. Annex VII includes SBOM information in the vulnerability-handling documentation and also provides for the SBOM, where applicable, to be supplied to a market-surveillance authority following a reasoned request when necessary to check compliance. Teams should therefore know which release-specific SBOM belongs to each product baseline and how it can be retrieved without reconstructing dependency data later.
A practical Annex VII evidence index
An evidence index can keep the technical file navigable while allowing engineering records to remain in their source systems.
| Annex VII area | Useful controlled evidence | | --- | --- | | Product description | Product identifier, intended purpose, versions, architecture, user information | | Design and development | Architecture diagrams, security requirements, design decisions | | Vulnerability handling | SBOM, CVD policy, contact evidence, triage process, secure-update design | | Production and monitoring | Build or production controls, validation records, monitoring process | | Risk assessment | Versioned risk assessment, applicability decisions, treatment rationale | | Support period | Expected-use analysis and support-period decision | | Standards and specifications | Standards register, partial-use mapping, alternative technical solutions | | Verification | Test plans, reports, findings, remediation and acceptance records | | Conformity | EU declaration of conformity and relevant conformity-assessment records |
This structure is an engineering recommendation rather than a prescribed CRA template. The legal requirement is the content and traceability of the evidence, not the folder names used to store it.
Use current guidance without confusing it with the law
The European Commission published non-binding CRA implementation guidance on 27 July 2026. It provides practical clarification for manufacturers and businesses and should be used alongside the Regulation, while the legal obligations remain those in Regulation (EU) 2024/2847 and applicable implementing or delegated acts.
The German Federal Office for Information Security, BSI, publishes TR-03183, "Cyber Resilience Requirements for Manufacturers and Products". Part 1, "General Requirements", is currently available as preliminary version 0.9.0 and is being revised after a community comment period. It can help teams structure technical implementation work, but it is not a replacement for the CRA or future harmonised standards.
Implementation is still evolving. Manufacturers should monitor Commission implementation material and relevant standardisation outputs, particularly where a documentation format, technical specification or presumption-of-conformity mechanism changes.
Make technical documentation part of release governance
A workable release process can keep the technical file current without creating a separate manual project before every market release.
- Freeze the product baseline. Identify the exact version, variant, architecture and intended purpose.
- Confirm the risk assessment. Check that it reflects the release and that applicability decisions are current.
- Refresh requirement mappings. Link applicable Annex I requirements to implemented controls.
- Collect verification evidence. Confirm that required tests and reviews are complete for the release.
- Refresh vulnerability evidence. Tie the current SBOM, vulnerability decisions and update process to the release.
- Review support-period evidence. Confirm that the support decision remains appropriate for the product.
- Update standards references. Record exact standards, specifications and any partial application.
- Complete conformity records. Add the declaration and other conformity-assessment outputs applicable to the product.
- Publish a controlled technical baseline. Preserve identifiers and references so the evidence can be retrieved later.
- Define lifecycle triggers. Route later product, vulnerability and process changes back into the documentation.
The control should be strict enough that a release cannot accidentally point to evidence for another product version, but simple enough that engineering teams can maintain it as part of normal work.
Technical documentation becomes difficult to maintain when risk decisions, test results, SBOMs and release evidence are spread across separate systems. AA-sec is designed around traceability between requirements, security evidence, decisions and exact product or lifecycle context, which can support keeping Annex VII evidence connected to the release it describes. CRA conformity and conformity assessment remain the manufacturer's responsibility.
Key takeaway
CRA technical documentation is the evidence layer connecting the product placed on the market to the manufacturer's cybersecurity decisions and processes. Annex VII requires more than a final risk report: it brings together product and software identification, architecture, vulnerability handling, the cybersecurity risk assessment, support-period reasoning, standards and alternative solutions, test reports, the EU declaration of conformity and, where applicable, the SBOM.
The practical objective is to keep that evidence release-specific, traceable and maintainable throughout the support period, while preserving it for the required retention window. If a product team can identify the exact baseline, retrieve the supporting evidence, explain requirement applicability and show how the record changed over time, the technical documentation can function as part of product-security governance rather than as a late compliance reconstruction.
Official sources
- Regulation (EU) 2024/2847 — Cyber Resilience Act — EUR-Lex
- The Cyber Resilience Act - Summary of the legislative text — European Commission
- Cyber Resilience Act - Manufacturers — European Commission
- Commission publishes new guidance to support timely Cyber Resilience Act implementation — European Commission
- BSI TR-03183: Cyber Resilience Requirements for Manufacturers and Products — BSI