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ARTICLE · 22 SEPTEMBER 2026

Ireland Update: The Cyber Resilience Act

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The Cyber Resilience Act (Regulation (EU) 2024/2847)1 (“CRA”) establishes horizontal cybersecurity requirements for products with digital elements (“PDEs”) placed on the European Union (“EU”) market. Reporting obligations took effect on 11 September 2026, with full application of the CRA from 11 December 2027.

IrelandTechnology
Claire Morrissey
Claire Morrissey
Sarah Lydon
Sarah Lydon
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Introduction

The Cyber Resilience Act (Regulation (EU) 2024/2847)1 (“CRA”) establishes horizontal cybersecurity requirements for products with digital elements (“PDEs”) placed on the European Union (“EU”) market. Reporting obligations took effect on 11 September 2026, with full application of the CRA from 11 December 2027.

Scope – A Three-Step Analysis

A three-step process can be used to determine whether an organisation falls within the CRA’s scope:

Step 1: Is the product a PDE?

A PDE is “a software or hardware product and its remote data processing solutions, including software or hardware components being placed on the market separately”. “Remote data processing solutions” (“RDPS”) involve (i) data processing at a distance, (ii) without which a PDE cannot perform one of its functions and (iii) software designed and developed by the manufacturer, or under its responsibility.

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