CRA and the Software Supply Chain: Adapting Without Lock-In

The Cyber Resilience Act has changed the equation for any company that develops and sells software in Europe. Unlike DORA or NIS2, which primarily address internal IT and critical services, the CRA directly applies to digital products placed on the EU market. And the consequences for noncompliance are severe: fines of up to €15 million or 2.5% of global turnover, as well as the power to issue stop-sale orders or initiate product recalls.

For organizations across sectors, demonstrating the security of your software supply chain has moved from best practice to business necessity. With software now carrying the same systemic weight as utilities and critical infrastructure, the risks are no longer abstract. In response, many enterprises are racing to invest in automation and traceability. These capabilities are essential for consistently meeting higher operational thresholds — especially at scale. Organizations often benefit from the support of a partner with deep supply-chain expertise that won’t lock them into a single stack.

Automate and accelerate

Manual supply chain security practices are under mounting pressure. According to the Linux Foundation, a complete and tamper-proof Software Bill of Materials consumes more than nine hours per build for many organizations. Today, your approaches to mapping vulnerabilities across systems and planning for long-term support obligations may be fragmented or informal. And as enterprise codebases increasingly rely on public packages, so does the risk of integrating malicious or unverified components. 

Pipelines must now prove the origin and integrity of what they build. Automated supply chain tooling can help you achieve this goal, particularly when integrated directly into Continuous Integration and Continuous Deployment pipelines. By embedding SBOM generation, vulnerability tracking and patch feed logic into the build process, you can significantly reduce audit preparation time — often from days to hours. In addition, this type of integration creates a reliable audit trail. Regulators increasingly expect records of secure-by-design decisions that demonstrate the use of hardened, enterprise-ready components across multiple distributions. 

By using pipelines that meet SLSA Level 3 or higher, you give each build a signed attestation of origin and reinforce that record with tamper-resistant proof. Tools like SUSE Rancher Manager, SUSE Security and SUSE Observability can help automate SBOMs, enforce policy gates, map dependencies and maintain unified patch and CVE feeds across heterogeneous estates.

Fundamentally, automation helps strengthen compliance posture while helping you keep releases on schedule. It makes secure-by-design practices a repeatable, traceable part of everyday delivery, benefiting security and platform teams alike. For teams that are still getting started, consider automating SBOMs and policy gates on one product line first. Then, start scaling across portfolios.

Define your digital sovereignty

Digital sovereignty means maintaining control over your software, data and operational dependencies — within your jurisdiction, under your policies and on your terms. In the past, many organizations prioritized delivery speed, scalability and seamless integration over control. They often relied on internal policies or third-party certifications to manage risk, rather than building data sovereignty or end-to-end oversight into system design.

Now, regulations like the CRA are shifting the burden of proof. Regulators expect organizations to demonstrate how and where their software is developed, deployed and supported. That includes visibility into pipelines, data residency and infrastructure access. Verifiable accountability is no longer optional.

As a result, digital sovereignty has become a practical requirement. Yet its exact shape varies widely by organization. When Forrester asked buyers and vendors to define digital sovereignty, they found no clear consensus — despite its growing legal and operational stakes. This ambiguity has led cloud providers to develop varied and sometimes incompatible approaches, from EU-specific regions to layered compliance frameworks. 

In response, some enterprises are taking the lead in defining sovereignty for themselves and subsequently designing systems that meet those expectations. Engineering and security teams are adjusting their architecture decisions accordingly, with a twin focus on regulatory mandates and internal accountability goals. The resulting shifts can have major impacts on long-term infrastructure strategy, including the extent of your IT’s adaptability.

Some organizations are seeking support partners that promote these new operational needs and protect infrastructural flexibility. Partners like SUSE can help enterprises comply with localization requirements through open, multi-platform solutions and trusted regional partnerships. When working with SUSE, data generated during troubleshooting is encrypted and kept on servers located in the EU. In addition, SUSE can provide dedicated premium support staff massed in the region.

Align the boardroom and build pipeline

Regulators now expect executive accountability for software resilience. In turn, boards are internally demanding clearer, more actionable insight into build-time security. These expectations raise the bar for internal communication and require cross-functional teams to develop a shared language. 

A high-level view of key metrics — such as SBOM coverage, mean-time-to-patch and readiness to meet 24-hour disclosure timelines — can support these internal assessments and external audit preparations. Such metrics support leaders seeking to understand and collectively agree on their organization’s status, including its ability to meet new compliance requirements.

Many enterprises are formalizing cross-functional governance to strengthen coordination across engineering, security, legal and product teams. By directly connecting telemetry from build systems to compliance and risk workflows, you can make supply chain data accessible and actionable across an organization. In addition to improving audit readiness, this level of visibility promotes a more resilient operating model that is grounded in shared accountability.

Five steps that promote CRA readiness

Regulatory resilience isn’t achieved overnight. However, a focused and intentionally incremental approach can create the momentum you need.

Some enterprises start with a product-focused approach that also prioritizes audit-ready evidence, internal alignment and the agility to meet evolving requirements. The following five steps support such an approach: 

1. Inventory software components and assign ownership: Start by clarifying what you build and ship, and identify who is responsible for each component’s security posture.
2. Conduct a gap analysis: Use that inventory to assess your current state and map applicable requirements. Compare your tooling, documentation and practices against relevant regulatory requirements and internal standards.
3. Integrate policy-aware checks into CI/CD: Enforce secure defaults and centralized access control across clusters. Gate builds with tooling that blocks unverified components and allows curated, hardened open-source packages with SLSA attestations.
4. Plan for lifecycle support and coordinated incident response: Map your ability to patch supported products for multiple years and confirm your ability to respond within required reporting windows.
5. Strengthen traceability through SBOM coverage and audit trails: Confirm that every release produces a verifiable, machine-readable record of what was built — and how.

Most teams start by inventorying key systems, then phase subsequent moves over two or three quarters. Each step will contribute to a more transparent supply chain, reduce surprises during audit or rollout, and advance digital sovereignty. Partners like SUSE can support this process. They can help you align with CRA evidence expectations and localization requirements, while also reinforcing your broader operational goals. 

Design for the future

Today, the CRA is reshaping the design and documentation of software supply chains. Going forward, the regulatory landscape will continue to evolve. As technical requirements and harmonized standards adjust, rebuilding tooling with every shift becomes increasingly impractical and unsustainable.

Many teams are instead adopting modular, open architectures that can flex with new demands. By designing pipelines that support multiple Linux distributions and integrate with standard tooling, you can create more flexible foundations. Running those pipelines within sovereign environments gives them room to adapt as requirements evolve — without compromising control or transparency.

Listen in on industry leaders Andreas Prins and Markus Närenbäck as they discuss the latest legislation, risk mitigation strategies and practical steps for building resilient software development lifecycles.