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Product classifierDefaultRegulation (EU) 2024/2847

Is SCADA software covered by the EU Cyber Resilience Act?

The short answer, the Official Journal text behind it, and the judgment calls an assessor will test.

01
Verdict

SCADA / DCS supervisory software

In scope · Default class

Scope
In scope if it has a direct or indirect data connection to a device or network (Article 2(1)) — almost every modern one does.
Class
Default — Not in Annex III or IV.
Route
Self-assessment is available: internal control (Module A, Annex VIII) under Article 32(1). No notified body is needed, but the full Annex I evidence and the Annex VII technical file still are.
Dates
Article 14 reporting has applied since 11 September 2026; the main obligations apply from 11 December 2027 (Article 71).

SCADA and supervisory software placed on the EU market is in scope. It is default class unless its core function is managing the network itself.

02
Why

Why it lands in this class

Software is a product with digital elements in its own right (Article 3(1)). SCADA’s core function is supervising and controlling a process — not a listed category.

The nearest Annex III entry is ‘network management systems’, which the Implementing Regulation describes as managing network elements by controlling ‘their network operations and configuration’. Supervising a process is not that.

“Products with digital elements that manage connected network elements, such as servers, routers, switches, workstations, printers or mobile devices, by monitoring them and controlling their network operations and configuration.”

— Implementing Regulation (EU) 2025/2392, Annex I, point 6 (CRA Annex III, Class I, point 6)

“The integration of a product with digital elements which has the core functionality of a product category set out in Annex III shall not in itself render the product in which it is integrated subject to the conformity assessment procedures referred to in Article 32(2) and (3).”

— Regulation (EU) 2024/2847, Article 7(1)

Source: Regulation (EU) 2024/2847 — Articles 2(1), 7(1), 32; Annexes III–IV. Implementing Regulation (EU) 2025/2392.

03
Edge cases

When the answer changes

  • The product’s primary job is managing switches, routers and network configuration across the plant: that matches network management systems (Class I).
  • The product’s primary job is detecting intrusions in OT traffic: that is an intrusion detection system (Class II).
  • You deliver it as a hosted service: remote data processing designed by you is part of the product (Article 3(1)–(2)); pure SaaS on its own is outside the CRA.
04
Auditor view

What an assessor will ask you to show

Class decides the route. It doesn’t reduce the work: every product needs the full Annex I evidence, an Article 13 risk assessment and an Annex VII technical file.

  • Evidence that the product is being classified on its core function, not on its feature list.
  • An SBOM covering the third-party components (historians, OPC libraries, databases) — Annex I Part II.
  • How security updates are delivered separately from feature updates where technically feasible (Annex I Part II).

Already developing to IEC 62443-4-1? See which requirements map to which CRA obligations in the IEC 62443 ↔ CRA crosswalk, and check your organisation’s footing with the CRA readiness score.

Classification is step one of six.

The CRA Workbench records your core-functionality reasoning the way an assessor will read it, then carries it through risk, Annex I, conformity route, vulnerability handling and the Annex VII file — with the IEC 62443 bridge built in.

See the CRA Workbench →

This page is general information about Regulation (EU) 2024/2847 and Commission Implementing Regulation (EU) 2025/2392, not legal advice. Quoted text is from the Official Journal; the analysis around it is ours. Classification turns on your product’s actual core functionality — document your own determination and confirm it against the current official texts. The CRA Workbench produces draft documentation for expert review; it indicates the evidence needed and does not, by itself, guarantee compliance.