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App-Specific CRA Risk Assessment: A Conceptual Walkthrough

Under the EU Cyber Resilience Act (CRA), conducting a cybersecurity risk assessment for your app is not optional; it's a mandatory step for the "manufacturer" (that's you, the app developer) (Article 13, Paragraph 2). This process helps you systematically identify and address potential security weaknesses in line with the CRA's essential requirements.

Why Your App Needs This​

A risk assessment will help you:

  • Pinpoint what could go wrong with your app's security.
  • Understand the likelihood and potential impact of these issues.
  • Make informed decisions on implementing security measures required by Annex I of the CRA.

Conceptual Steps for an App Risk Assessment​

Let's walk through how you might approach this for a typical mobile, web, or desktop app:

  1. Define Your App's Ecosystem (Asset Identification):

    • App Components: Client-side code (mobile/desktop/web frontend), backend APIs you manage, databases, third-party SDKs/libraries.
    • Data Handled: User credentials, personal information, app settings, user-generated content, payment information (even if passed to a third party).
    • Connections & Interfaces: Authentication systems, data storage, third-party services (analytics, ads, payment gateways), APIs your app consumes or exposes.
    • Consider the app's intended purpose and reasonably foreseeable uses and misuses (Article 13, Paragraph 3).

  2. Identify Threats & Vulnerabilities (App-Focused Threat Modeling):

    • Common App Threats: Data breaches (unauthorized access to user data), insecure data storage (local or remote), insecure communication (lack of TLS), injection vulnerabilities (SQLi, XSS in web apps), broken access control, vulnerable dependencies (outdated libraries).
    • Review Annex I essential requirements: Where might your app fail to meet these? (e.g., lack of encryption for stored data, weak authentication, no secure update mechanism).

  3. Analyze Risks (Likelihood & Impact on App Users/Business):

    • How likely is a specific vulnerability to be exploited in your app's context?
    • What is the impact if it is? (e.g., exposure of all user emails, ability for unauthorized purchases, reputational damage, app takedown).

  4. Plan Risk Treatment (Implementing CRA Requirements):

    • How will you mitigate these risks based on CRA's essential requirements?
    • Examples: Implement MFA for user accounts (supports Annex I, Part I, Point 2d). Encrypt sensitive data in your database (Annex I, Part I, Point 2e). Set up a vulnerability disclosure policy (Annex I, Part II, Point 5). Regularly update third-party libraries (Annex I, Part II, Point 2).

  5. Document Your Assessment:

    • The CRA requires this risk assessment to be documented and part of your technical documentation (Article 13, Paragraph 4; Annex VII). It should justify your security decisions and explain how you address applicable Annex I requirements.

Ongoing Process​

This isn't a one-and-done. Revisit your risk assessment when your app undergoes significant changes or new threats emerge (Article 13, Paragraph 3).

Key Takeway​

A cybersecurity risk assessment is a mandatory, documented process for app developers under the CRA. It involves identifying your app's assets and data flows, pinpointing threats and vulnerabilities, analyzing potential impacts, and implementing mitigations aligned with CRA's essential security requirements.