EU Cyber Resilience Act (CRA) Compliance
Maps an open-source toolkit's security and documentation practices to the EU Cyber Resilience Act's requirements for downstream compliance support.
What this file does
Maps an open-source toolkit's security and documentation practices to the EU Cyber Resilience Act's requirements for downstream compliance support.
When to use it
- Your open-source library needs to document CRA alignment for downstream users
- You are preparing a compliance statement for a software toolkit or library
- You want a template mapping security practices to CRA articles 10-14
- You need to communicate user responsibilities for CRA compliance
Assumes this stack
EU Cyber Resilience Act (CRA) Compliance
Overview
This document describes how the ACF-Solutions project complies with the EU Cyber Resilience Act (Regulation (EU) 2024/2847).
Product Information
Product Name: ACF-Solutions - Solutions for ACF Toolkit
Product Type: Software library/toolkit (open-source)
License: GNU Lesser General Public License v2.1 (LGPL-2.1)
Manufacturer: ImagingTools GmbH
Product Category: Software development toolkit
Base Framework: ACF (Application Component Framework)
CRA Requirements Compliance
1. Security Requirements (Article 10)
1.1 Secure by Design
ACF-Solutions follows secure development practices:
- Input Validation: Components include parameter validation mechanisms
- Type Safety: Strongly typed parameter interfaces reduce runtime errors
- Memory Safety: Uses Qt framework's memory management features
- Code Review: Changes undergo review process before integration
- Framework Security: Built on the secure ACF framework foundation
1.2 Security Updates
- Security updates are provided for supported versions
- Critical vulnerabilities are addressed with priority
- Security advisories are published through GitHub Security Advisories
- See SECURITY.md for our security update policy
1.3 Vulnerability Handling
- Documented process for reporting vulnerabilities (see SECURITY.md)
- Response timeline: acknowledgment within 72 hours
- Resolution target: within 90 days based on severity
- Coordinated disclosure with security researchers
2. Vulnerability Management (Article 11)
2.1 Identification
- Regular dependency monitoring
- Security scanning in development workflow
- Community-driven vulnerability reports
- Automated security checks via GitHub tools
2.2 Documentation
- Known vulnerabilities documented in security advisories
- CVE identifiers assigned for critical issues
- Mitigation guidance provided in advisories
- Fixes tracked in release notes
2.3 Remediation
- Security patches released as updates
- Hotfixes for critical vulnerabilities
- Backports to supported versions when feasible
- Migration guidance for deprecated features
3. Transparency Requirements (Article 13)
3.1 Product Documentation
- Component-based architecture extending ACF
- Usage examples and best practices
- Build and installation instructions
- API reference documentation
3.2 Security Information
- Security policy: SECURITY.md
- Supported versions clearly documented
- Known limitations and security considerations
- Safe usage guidelines
3.3 Software Bill of Materials (SBOM)
ACF-Solutions main dependencies:
Runtime Dependencies:
- ACF (Application Component Framework) - ImagingTools GmbH (LGPL-2.1)
- Qt Framework (version 5.x/6.x) - Qt Project (LGPL/GPL)
- Standard C++ library (implementation-dependent)
Build Dependencies:
- CMake 3.x or later (BSD License)
- QMake (part of Qt)
- Doxygen (GPL) - for documentation generation
SBOM can be generated using standard tools:
- For CMake builds: Use
cmake --graphvizor SBOM generation tools - For package distributions: Use platform-specific SBOM tools
3.4 Open Source Compliance
- Full source code available: https://github.com/ImagingTools/AcfSln
- License: LGPL-2.1 (see LICENSE)
- Dependencies are clearly documented
- Build from source instructions provided
4. Support and Maintenance (Article 14)
4.1 Support Period
- Current Release: Full support including security updates
- Previous Release: Security updates for critical issues
- Older Releases: Community support, no official security updates
4.2 End of Support
- When a version reaches end of support, it will be announced in:
- GitHub releases
- Repository README
- Project documentation
- Minimum 6 months notice for planned end of support
4.3 Maintenance Activities
- Bug fixes and security patches
- Compatibility updates for dependencies
- Documentation improvements
- Performance optimizations
5. Conformity Assessment
5.1 Self-Assessment
As an open-source software toolkit under LGPL-2.1:
- ACF-Solutions provides building blocks for applications
- End-product manufacturers are responsible for their own CRA compliance
- ACF-Solutions maintains documentation to support downstream compliance
- Security practices align with CRA requirements
5.2 Third-Party Dependencies
Users must ensure compliance for:
- ACF (Application Component Framework) from ImagingTools
- Qt Framework (from Qt Project)
- Platform-specific system libraries
- Any additional dependencies added by downstream users
5.3 Risk Assessment
ACF-Solutions is designed as a toolkit with:
- Low inherent risk: Toolkit provides tools, doesn't handle sensitive data directly
- User responsibility: Applications built with ACF-Solutions must implement their own security controls
- Extensibility considerations: Users must review security of custom components
6. Incident Response
6.1 Security Incident Handling
In case of a security incident:
- Detection: Through reports or automated scanning
- Assessment: Evaluate severity and impact
- Communication: Notify affected users via GitHub advisories
- Remediation: Develop and release fix
- Disclosure: Publish advisory after fix is available
6.2 Communication Channels
- GitHub Security Advisories
- Release notes
- Project documentation updates
- Direct notification to known affected users when possible
7. Documentation and Records
7.1 Available Documentation
- Security policy: SECURITY.md
- License information: LICENSE
- Build instructions in documentation
- Component usage examples
7.2 Change Management
- Version control via Git
- Release notes for each version
- Change tracking in commit history
- Security-relevant changes highlighted
8. User Responsibilities
When using ACF-Solutions, developers are responsible for:
8.1 Application Security
- Implementing authentication and authorization
- Validating user inputs in their applications
- Securing data storage and transmission
- Following secure coding practices
8.2 Dependency Management
- Keeping ACF-Solutions, ACF, and Qt updated
- Monitoring security advisories
- Testing updates before deployment
- Managing their own SBOM
8.3 Compliance
- Ensuring their products comply with CRA
- Documenting their use of ACF-Solutions in their SBOM
- Implementing their own security measures
- Maintaining their own support processes
9. Limitations and Disclaimers
9.1 No Warranty
As stated in the LGPL-2.1 license, ACF-Solutions is provided "AS IS" without warranty. See LICENSE for full terms.
9.2 Security Limitations
- ACF-Solutions provides tools; security depends on correct usage
- No toolkit can prevent all security issues
- Users must implement application-specific security
- Regular updates are essential for security
9.3 Liability
Liability limitations are defined in the LGPL-2.1 license.
10. Contact Information
Security Issues: See SECURITY.md for reporting procedures
General Questions: GitHub Issues
Project Repository: https://github.com/ImagingTools/AcfSln
11. Updates to This Document
This CRA compliance document is reviewed and updated regularly to reflect:
- Changes in CRA requirements or guidance
- Updates to the project's security practices
- New features or capabilities
- Lessons learned from security incidents
Version: 1.0
Last Updated: February 2026
Next Review: August 2026
References
- EU Cyber Resilience Act - Regulation (EU) 2024/2847
- ACF-Solutions Security Policy
- GNU LGPL v2.1 License
- ACF Framework
- NIST Secure Software Development Framework (SSDF)
Certification Status
Note: As an open-source toolkit, ACF-Solutions is designed to support CRA compliance but does not itself undergo certification. Products incorporating ACF-Solutions must undergo their own conformity assessment as required by the CRA.
What's inside
11 sections covering CRA articles, product info, SBOM, incident response, user responsibilities, and disclaimers.
Change this for your project
- Replace
ImagingTools/AcfSlnwith your repository path in all URLs and references - Replace
ACF-SolutionsandACF (Application Component Framework)with your product and base framework names - Replace
ImagingTools GmbHwith your manufacturer or organisation name - Replace
LGPL-2.1with your actual license identifier
Where it goes
Keep in docs/ or alongside the feature. Agents read it to implement against a defined contract.
Worth borrowing
- Mapping each CRA article to concrete existing practices rather than writing aspirational policies
- Separating user responsibilities from project responsibilities to clarify compliance boundaries
- Including a review schedule and version number to keep the document maintainable
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