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Cyber Resilience Act (CRA) vs EU GDPR
Regulation (EU) 2024/2847 on horizontal cybersecurity requirements for products with digital elements (Cyber Resilience Act) (European Union) compared with Regulation (EU) 2016/679 (General Data Protection Regulation) (European Union (EEA)) on the same topics. Every value comes from the law pages, which link to the official sources.
| Topic | Cyber Resilience Act (CRA) European Union 13/14 facts confirmed by two sources | EU GDPR European Union (EEA) ✓ Confirmed by two sources |
|---|---|---|
| Status | In force since 10 Dec 2024; reporting obligations apply from 11 Sep 2026; main obligations from 11 Dec 2027.✓ | In force since 25 May 2018. Digital Omnibus amendments proposed Nov 2025, not adopted as of Oct 2026.✓ |
| Who it applies to | Manufacturers, importers and distributors of hardware and software products with digital elements placed on the EU market, wherever they are based (consumer IoT, apps, software, components).✓ | Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.✓ |
| Size thresholds | None — applies regardless of size; no fines on micro/small firms for missing the 24h early-warning deadline.✓ | None — applies regardless of size. Limited record-keeping relief for organisations under 250 staff (Art 30(5)), lost if processing is risky, not occasional, or includes special-category or criminal data.✓ |
| Regulator | National market surveillance authorities and CSIRTs; ENISA runs the Single Reporting Platform✓ | National data protection authorities (DPAs), coordinated by the European Data Protection Board (EDPB)✓ |
| Breach or incident reporting | Actively exploited vulnerabilities and severe incidents: early warning within 24h, notification within 72h; final report 14 days after a fix (vulnerabilities) or 1 month after notification (incidents). Via ENISA Single Reporting Platform.✓ | Notify the competent supervisory authority without undue delay and within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals (Art 33). If you have an EU main establishment, that is your lead authority; if you have no EU establishment (even with an EU representative), notify the authority of every member state where affected people live (EDPB Guidelines 9/2022, para 73). Tell affected individuals without undue delay if the risk is high (Art 34).✓ |
| Deadline to answer personal data requests | N/A✓ | 1 month from receipt; extendable by 2 further months for complex requests if the person is told within the first month. Free of charge unless manifestly unfounded or excessive.✓ |
| Data protection officer | N/A✓ | DPO mandatory for public bodies, and where core activities involve large-scale regular and systematic monitoring, or large-scale processing of special-category or criminal-offence data.✓ |
| Local representative | Non-EU manufacturers may appoint an EU authorised representative; importers must ensure compliance.✓ | Non-EU controllers/processors caught by Art 3(2) must appoint an EU representative in writing, unless processing is occasional, low-risk and excludes large-scale sensitive data, or they are a public body.✓ |
| Sending data abroad | N/A✓ | Transfers outside the EEA need an adequacy decision (e.g. UK, Switzerland, EU-US Data Privacy Framework), or safeguards such as Standard Contractual Clauses or Binding Corporate Rules, or a narrow Art 49 derogation.✓ |
| Cookies and consent | N/A✓ | Cookie/tracker consent is governed by the ePrivacy Directive Art 5(3); where consent is the GDPR legal basis it must be freely given, specific, informed, unambiguous and as easy to withdraw as to give.✓ |
| Maximum penalty | Up to EUR 15m or 2.5% of worldwide turnover (essential requirements, Arts 13-14); EUR 10m or 2% (other duties); EUR 5m or 1% (misleading info). | Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher (lower tier: EUR 10 million or 2%).✓ |
= confirmed by two independent sources, at least one official.
Facts marked “Being verified” are still being confirmed and are not given as answers.
Who each law applies to
- Cyber Resilience Act (CRA)
- Manufacturers, importers and distributors of hardware and software products with digital elements placed on the EU market, wherever they are based (consumer IoT, apps, software, components).
- EU GDPR
- Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.
What you must do under Cyber Resilience Act (CRA)
- Report actively exploited vulnerabilities and severe incidents within 24h (from 11 Sep 2026).
- Register on ENISA's Single Reporting Platform and assign a reporting owner.
- Design products to meet Annex I security requirements by 11 Dec 2027.
- Define a support period and ship security updates throughout it.
- Keep an SBOM and run a coordinated vulnerability disclosure policy.
- Complete conformity assessment and CE marking before placing products on the market.
What you must do under EU GDPR
- Identify a lawful basis for every processing purpose and record it.
- Publish a clear privacy notice covering purposes, recipients, retention and rights.
- Keep a record of processing activities and sign Art 28 contracts with processors.
- Run a DPIA before high-risk processing such as large-scale profiling or sensitive data.
- Report qualifying breaches within 72 hours (lead authority, or every relevant DPA if you have no EU establishment) and log all breaches.
- Answer access, erasure and other rights requests within one month.
Information only, not legal advice. Laws change; confirm with the regulator or a qualified lawyer before relying on this page. Spotted an error? Email contact@