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Language Requirements for Software Technical Documentation

When you compile the Technical Documentation for your app or game, you need to consider the language it's written in. The Cyber Resilience Act (CRA) has rules about this, though they are most relevant when a third-party conformity assessment is involved.

The Official Rule​

Article 31, Paragraph 4, of the CRA specifies the language requirement: "The technical documentation and correspondence relating to any conformity assessment procedure shall be drawn up in an official language of the Member State in which the notified body is established or in a language acceptable to that body".

What This Means for Self-Assessment​

If you are self-assessing your uncritical software (using Module A), you won't be submitting your documentation to a notified body for approval. In this case, there isn't a strict CRA mandate to translate the entire technical file into multiple languages.

However, a market surveillance authority from any EU Member State can request your Technical Documentation. While the CRA doesn't explicitly state you must translate it for them on demand, being able to provide it in a language they can easily understand (often English) is a practical necessity for smooth oversight and to avoid complications. A request from an authority for "all the information and documentation... in a language that can be easily understood by that authority" is mentioned in other articles regarding importer and distributor obligations (Article 19, Paragraph 7, and Article 20, Paragraph 5), suggesting this is a general principle.

Practical Guidance​

  • Default to English: For most software companies operating across the EU, maintaining the primary Technical Documentation in English is a sensible default strategy.
  • Be Prepared: Be aware that a specific national authority might have provisions under their own national law regarding language.
  • If Using a Notified Body: If you choose to use a notified body, or are required to, the rule is clear. You must agree on the language with them beforehand.

Key Takeway​

For self-assessed software, while there's no explicit rule to translate your Technical Documentation into every EU language, maintaining it in a widely accepted business language like English is the most practical approach for dealing with potential requests from any market surveillance authority. If a notified body is involved, their language requirements are binding.