EU MDR & Cyber Resilience Act

The MDR made security part of safety. The CRA put it on a clock.

Two EU regimes now govern device cybersecurity. MDR treats security as part of the safety case, proven in the technical file and re-examined at recertification. The CRA layers on vulnerability-handling duties and a reporting countdown measured in hours. ELTON produces the evidence both demand, from one continuous practice. ELTON is an exploitability management platform, delivered as a managed program. Our team runs the testing continuously. You get the platform, the evidence, and a TestLink™ appliance, with no new headcount.

Two regimes

One security case, examined two ways.

The MDR and the CRA overlap but ask different questions. The MDR asks whether your device is safe, and now counts cybersecurity as part of that answer. The CRA asks whether you handle and report vulnerabilities on time. A single, evidenced practice satisfies both.

EU MDR · 2017/745

Security is part of the safety case

Annex I General Safety and Performance Requirements 17.2 require software developed to the state of the art with IT security measures. MDCG 2019-16 makes cybersecurity part of the GSPR, not an optional annex, and Notified Bodies now ask for technical evidence, traceability, and lifecycle management, including at recertification of legacy devices.

EU CRA

Vulnerability handling on a clock

Products with digital elements carry vulnerability-handling duties across their support period, and an actively exploited vulnerability starts a reporting countdown: a 24-hour early warning and a 72-hour notification to ENISA and the national CSIRT. The CRA does not care how old the device is.

The MDR technical file

What a recertification file now has to show.

Under the MDR, manufacturers must demonstrate that software risks are identified, evaluated, and controlled across the lifecycle. MDCG guidance expects documented processes, and Notified Bodies expect the evidence behind them. The gap most files have is continuity, not a single pentest.

01

Vulnerability monitoring and triage

Proof that someone watched the SBOM between the last test and today, and triaged what appeared. ELTON's continuous discovery and finding lifecycle make that a running record, not a reconstruction.

02

Patch management and unmitigated-risk justification

A record of what was fixed and why the rest was accepted. ELTON's VEX-aligned statuses carry the reasoning for every decision, which is exactly the justification MDCG asks for.

03

SBOM and postmarket surveillance

SBOM evidence in the technical file and cybersecurity-specific postmarket surveillance. ELTON generates the CycloneDX SBOM and re-assesses findings as new vulnerabilities surface, per release.

The ELTON mapping

Continuous discovery, verified answers, timed output.

The hard part of both regimes is the same: knowing, quickly and provably, whether a given vulnerability is exploitable on your product. That answer only comes from testing the device itself, and it feeds the MDR file and the CRA clock at once.

Continuity, built in

ELTON builds a digital twin from your quality system documentation and runs continuous discovery across firmware, software, web, mobile, and network. The continuity the MDR wants is how the platform operates, not a project you schedule.

Exploited means verified, not suspected

When a CVE drops or an exploitation report arrives, AI verification attacks the question on the real product. You notify from evidence: exploitable here, or provably not, with the test record attached.

One record, both filings

The same twin, findings, and VEX statuses populate the MDR technical file and the CRA reporting timeline. Evidence is a byproduct of the work, generated as you go.

The CRA clock

CRA deadlines against ELTON output.

The MDR asks for continuity across the whole lifecycle. The CRA compresses part of it into hours. ELTON runs continuously, so when the countdown starts the evidence already exists.

Actively exploited vulnerability: CRA clock vs ELTON outputCRA dutyELTON0haware of exploitation24hearly warning72hnotification14dfinal report4hverified on device24hdetermination72hfull report14devidence ready
ELTON output arrives ahead of each CRA deadline it feeds.
Get started

Put your MDR file and CRA reporting on evidence.

Start with one device. We build the twin, run continuous discovery, and keep the record both the Notified Body and the CRA clock expect, current and ready.

Questions

Common questions about the EU CRA and MDR.

What does the EU Cyber Resilience Act require when a vulnerability is actively exploited?

The CRA starts a reporting countdown. An actively exploited vulnerability triggers a 24 hour early warning and a 72 hour notification to ENISA and the national CSIRT. Vulnerability handling duties run across the product's support period, and the CRA does not care how old the device is.

How is the EU MDR different from the CRA on cybersecurity?

The MDR asks whether your device is safe and now counts cybersecurity as part of that answer, proven in the technical file and re-examined at recertification. The CRA asks whether you handle and report vulnerabilities on time. The two regimes overlap, so a single evidenced practice can satisfy both.

What cybersecurity evidence does an MDR technical file need?

Annex I General Safety and Performance Requirements 17.2 require software developed to the state of the art with IT security measures, and MDCG 2019-16 makes cybersecurity part of the GSPR. Notified Bodies ask for the technical evidence behind that: vulnerability monitoring and triage, patch management with justification for unmitigated risk, SBOM, and cybersecurity specific postmarket surveillance.

Does the CRA apply to products already on the market?

CRA vulnerability handling duties apply to products with digital elements across their support period, and the regulation does not care how old the device is. A product certified years ago carries the same handling and reporting obligations as one launched this quarter, which is why legacy recertification and CRA reporting are usually the same evidence problem.

How does ELTON support both the MDR file and the CRA clock?

ELTON builds a digital twin from your quality system documentation and runs continuous discovery across firmware, software, web, mobile and network. The same twin, findings and VEX statuses populate the MDR technical file and the CRA reporting timeline, so the evidence is a byproduct of the work rather than a separate project.

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