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Analysis Regarding the European Commission's Cyber Resilience Act Proposal

The Data Innovation Center (Transparency Register ID: 367682319221-26) is delighted to provide feedback on the European Commission's consultation and call for evidence concerning the Cyber Resilience Act project. This initiative aims to collaborate with existing legislation to enhance cyber...

Comments Regarding Cyber Resilience Act Proposal by the European Commission
Comments Regarding Cyber Resilience Act Proposal by the European Commission

Analysis Regarding the European Commission's Cyber Resilience Act Proposal

The European Commission is taking a proactive stance in combating the growing threat of cybersecurity incidents, with a focus on the Cyber Resilience Act (CRA) initiative. The CRA aims to work alongside existing legislation such as the Cybersecurity Act and the Directive on the security of Network Information Systems, to improve cybersecurity by addressing gaps in the existing regulatory framework for digital products and services.

The CRA is considering five policy options, each with potential benefits and drawbacks.

  1. Harmonized mandatory cybersecurity requirements for digital products: This option ensures consistent security standards across all connected products in the EU market, improving overall cyber resilience. However, it could impose significant compliance costs, especially for small and medium enterprises (SMEs).
  2. Scope limitation and prioritization of significant or critical products: By reducing the number of product categories under strict regulation, resources can be focused on products with the highest cybersecurity risks. However, a narrow scope risks leaving many digital products less regulated, creating security blind spots.
  3. Mandatory reporting of significant cybersecurity incidents to national Computer Security Incident Response Teams (CSIRTs): This policy improves situational awareness and coordination in incident response across the EU. However, it could lead to overreporting or administrative overload if thresholds are not clear.
  4. Requiring impact assessments before imposing compulsory certification: This ensures evidence-based decisions on certification, but could delay the introduction of important certification requirements.
  5. Support mechanisms for small companies: This option helps SMEs comply with the CRA without disproportionate costs, but could create loopholes if exemptions are too broad.

The European Commission should ensure stakeholder consultation, provide technical guidance, implement risk-based flexibility, and coordinate closely with national authorities (e.g., CSIRTs) to balance security goals with innovation and market dynamics.

The CRA aims to make digital products more secure throughout their lifecycle with harmonized rules, mandatory risk assessments, and continuous vulnerability reporting. Regular review and adaptation to technological evolution will be key to maximizing benefits and mitigating drawbacks in implementing the CRA initiative.

In 2020, global cybercrime cost €5.5 trillion, a figure predicted to reach $10.5 trillion by 2025. The EU can play an important role in bolstering cybersecurity practices due to the growing cybersecurity vulnerabilities. The Center for Data Innovation has submitted feedback on the European Commission's consultation regarding the CRA initiative, offering insights into the potential outcomes of each policy option.

The EU is focusing on this issue to combat the increasing costs of global cybercrime and can play a pivotal role in improving cybersecurity practices across the continent.

  1. The European Commission's focus on the Cyber Resilience Act (CRA) initiative includes the consideration of mandating AI and data-related regulations for digital products, aiming to enhance cybersecurity and address gaps in the existing regulatory framework.
  2. Under the CRA, certain digital products may face mandatory reporting of cybersecurity incidents to national Computer Security Incident Response Teams (CSIRTs), with the aim of improving situational awareness and coordination in incident response across the EU.
  3. As part of the CRA initiative, the EU is proposing support mechanisms for small and medium enterprises (SMEs) in complying with cybersecurity requirements, to ensure innovation and market dynamics are balanced with security goals.

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