The Cyber Resilience Act Is Coming. And Your Off-Highway Machines Are in the Crosshairs

By December 2027, any product with digital elements placed on the EU market must meet strict cybersecurity requirements, or lose market access. Here is what you need to know.

At DMCA Solutions, we operate with a simple principle:

If you are still treating cybersecurity as an IT problem, you are already behind.

The Cyber Resilience Act (CRA) - Regulation (EU) 2024/2847 is not guidance. It is not optional. It is a binding regulation that fundamentally reshapes how any product with digital elements is designed, developed, and maintained for the EU market.

And it directly impacts the off-highway machinery sector.

If you manufacture tractors, excavators, forklifts, cranes, or any mobile machine containing ECUs, telematics, connectivity, or embedded software, you are in scope. The transition period is limited, and the deadline is approaching fast.

The Timeline: The Countdown Has Already Started

Date	Obligation
10 December 2024	CRA enters into force
11 June 2026	Conformity assessment obligations begin
11 September 2026	Incident and actively exploited vulnerability reporting becomes mandatory
11 December 2027	Full compliance required for all products placed on the EU market

While industry stakeholders have advocated for extended transition timelines, the current regulatory framework stands: December 2027 remains the enforcement horizon.

What the CRA Covers

The Cyber Resilience Act establishes horizontal cybersecurity requirements for products with digital elements placed on the EU market, including:

• Hardware products: ECUs, controllers, sensors, industrial IoT devices, connected machinery

• Software components: firmware, operating systems, mobile applications, cloud-connected systems

If a product contains software and can connect, directly or indirectly, to another device or network, it is very likely within scope.

Why Off-Highway Machinery Is in the Crosshairs

Off-highway equipment presents a particularly high exposure under the CRA due to:

• High connectivity: CAN networks, telematics systems, wireless diagnostics, remote access

• Safety-critical environments: Cyber incidents can translate into physical risk

• Long lifecycle assets: 15–20+ years of operational life requiring long-term security maintenance

“For mobile machinery, this is a complex undertaking because they are highly networked, operate in harsh environments, and sometimes possess open architectures, all factors that increase the attack surface.”

This combination of connectivity, safety relevance, and longevity makes the sector a priority exposure area under the CRA.

What the CRA Requires in Practice

For OEMs and Tier-1 suppliers, compliance is not theoretical. It translates into concrete obligations:

1. Security by Design

Cybersecurity must be embedded from the earliest design phases, including:

• Structured risk assessments

• Threat modeling (TARA)

• Documented security controls across the product lifecycle

2. Lifecycle Vulnerability Management

Manufacturers must define and communicate a support period for security updates.

For off-highway machinery, this introduces a structural challenge: aligning 20-year machine lifecycles with sustainable cybersecurity maintenance models.

3. Incident Reporting Obligations

From September 2026, strict reporting timelines apply for actively exploited vulnerabilities and severe incidents:

• Initial notification: within 24 hours

• Detailed report: within 72 hours

• Final update: within 14 days after mitigation

4. CE Marking for Cybersecurity

Compliance with CRA requirements becomes a condition for CE marking.

No compliance → no CE marking → no EU market access.

The Cost of Non-Compliance

The CRA introduces significant financial exposure under Article 64:

Offence	Maximum Penalty
Non-compliance with essential cybersecurity requirements	€15M or 2.5% of global turnover
Non-compliance with other obligations	€10M or 2% of global turnover
Providing incorrect information	€5M or 1% of global turnover

“Those who neglect CRA compliance risk high fines, significant insurance, liability, and reputational damage, as well as the loss of market access (e.g., due to a missing CE certificate).”

What This Means for Your Components

A key question for the off-highway ecosystem is scope definition at component level:

Are CAN-based controllers in scope?

Yes, in most cases.

• ECUs, gateways, telematics modules, and firmware-driven controllers are clearly within scope when they include digital functionality and connectivity.

What about “pure” PWM components?

A simple analog or PWM-controlled component without software, memory, or communication capability is likely out of scope.

However, the boundary is shifting.

Once a PWM system includes:

• Microcontrollers

• Firmware

• Diagnostics

• Configuration interfaces

• Remote updates or connectivity

…it transitions into a “product with digital elements”, and is therefore likely in scope.

The principle is straightforward:

If it contains software and communicates, assume it falls under the CRA.

The Regulatory Stack: CRA Is Not Alone

The CRA sits within a broader regulatory framework shaping off-highway machinery:

• EU Machinery Regulation (2023/1230) – mandatory from January 2027, introducing explicit cybersecurity and software safety expectations

• NIS2 Directive – cybersecurity obligations across operators and supply chains

• EU AI Act – applicable to autonomous and highly automated systems

“Safety and security go hand in hand. In connected machines, a cyberattack can disable or negatively affect a safety function.”

How Industry Leaders Are Responding

Leading suppliers are already integrating CRA expectations into product ecosystems.

For example, OEMs and Tier-1 suppliers incorporates:

• Structured security engineering aligned with ISO 21434

• TARA (Threat Analysis and Risk Assessment) methodologies

• Software Bill of Materials (SBOM) management

• 24/7 security monitoring and incident response

• Secure over-the-air update infrastructure

The direction is clear: cybersecurity maturity is becoming a competitive differentiator, not just a compliance requirement.

What You Should Do Now

To prepare effectively, organizations should focus on six immediate priorities:

1. Product portfolio mapping

Identify all products with digital elements and determine CRA exposure.

2. Define security support commitments

Establish clear lifecycle support periods for cybersecurity updates.

3. Embed Security-by-Design

Integrate cybersecurity into development processes, including TARA and documentation.

4. Prepare incident response capability

Ensure readiness for mandatory reporting timelines starting 2026.

5. Align regulatory strategy

Coordinate CRA compliance with Machinery Regulation and AI Act requirements.

6. Evaluate ecosystem partnerships

Assess whether leveraging external cybersecurity frameworks or platforms accelerates compliance readiness.

The DMCA Perspective

At DMCA Solutions, we support industrial companies in navigating sourcing complexity and emerging regulatory constraints. The Cyber Resilience Act is not just a compliance obligation. It is a structural shift in how products are designed, supplied, and supported across their entire lifecycle. Companies that treat CRA early as a strategic design constraint will gain resilience and market advantage. Those that delay risk disruption, cost escalation, and restricted market access.

The timeline is clear. December 2027 is fixed.

And for off-highway machinery with decades-long lifecycles, the decisions made today will define competitiveness for years to come.

Official Resources

• Regulation (EU) 2024/2847: Cyber Resilience Act

• European Commission summary: CRA overview and guidance