Michele Pighi

Michele Pighi

Product Manager

Cyber Resilience Act for machines and HMIs: how Oktima lightens your load

A stylized shield on a blue grid

You have delivered a machine with an HMI. A few months later, a vulnerability is discovered in a library included in the HMI. Which machines are affected? Is an update needed? Who tells the customer?

The Cyber Resilience Act (CRA) makes these checks part of the work on the product: software security has to be looked after even after delivery.

If you are a machine manufacturer, that is, you place machines on the market under your own name, the CRA obligations are yours, towards the authorities and towards your customers, for every digital component included in the product, even those developed by third parties.

  • If you build the HMI in-house by putting together your own code and third-party components, such as a graphics framework and assorted libraries, maintaining the HMI application to resolve vulnerabilities over time is entirely up to you: you have to monitor the vulnerabilities of each component, assess them and fix them where needed.
  • If you build the HMI with a vendor's development tool, it is in your interest to check that the vendor can guarantee you information on the vulnerability status and updates with the timing and completeness the CRA requires of you.

If you choose Oktima to develop your HMI applications, they also include the Oktima runtime and its libraries. We take care of monitoring, assessing and fixing the vulnerabilities in these components. You receive the analysis results, the documentation and the updates to integrate into your product. Oktima's support thus saves you a significant part of the work the CRA requires.

CRA: two dates, two different commitments

The CRA is Regulation (EU) 2024/2847. For those who develop or integrate an HMI, there are two dates to remember:

  • 11 September 2026: reporting obligations. The manufacturer must report actively exploited vulnerabilities and severe incidents affecting the security of the product, even if it was placed on the market before this date.
  • 11 December 2027: product requirements and vulnerability handling. Products subject to the CRA placed on the market from that day must meet its requirements to carry the CE marking. They need secure design, technical documentation and vulnerability handling for the support period.

For new products, the risk assessment must therefore start during design. For those already delivered, you need to be able to tell today whether an exploited vulnerability affects them.

From 11 December 2027, infringements of the essential cybersecurity requirements and of the manufacturer's obligations, reporting included, can lead to fines of up to €15 million or 2.5% of total worldwide annual turnover for the preceding financial year, whichever is higher.

The work continues after the product is delivered

The manufacturer is responsible for the security of the product as a whole, third-party components included. A vulnerability in the HMI can therefore affect the machine that integrates it.

An HMI application or application firmware contains libraries for graphics, communication, cryptography and hardware management. The CRA asks you to look after their security.

  • Know what every released version contains. The SBOM (Software Bill of Materials) lists the software components and their versions.
  • Monitor new vulnerabilities. Comparing the SBOM with public databases identifies the ones to examine.
  • Assess whether the vulnerabilities are exploitable in the product. This is triage: a library may be vulnerable, but the product may not use the affected function. The analysis results must be justified and documented, even when no fix is needed, in what is called a VEX (Vulnerability Exploitability eXchange): it states which vulnerabilities affect the product, which do not, and why.

So the SBOM lists the components, but then the vulnerabilities have to be assessed. The work that takes the most expertise is interpreting the results. When a vulnerability affects the product, you need a fix, guidance for users and, where required, a report to the authorities.

These activities continue for the support period, which is set based on the product's expected period of use: normally at least five years, but potentially longer for an industrial machine. The regulation makes an exception for products with an expected period of use shorter than five years.

There are therefore two scenarios that deserve particular attention:

  • If you develop your application or application firmware in code, for example in C or C++, and/or by integrating third-party libraries and components: you have to continuously monitor and assess vulnerabilities, run tests and release fixes.
  • If you use an HMI tool that the vendor does not update, or if the vendor does not guarantee, for vulnerabilities, information and response times that match the completeness and deadlines the CRA requires: the vendor's shortcomings become your shortcomings as the manufacturer, and you are responsible for them under the CRA.

Secure design and updates

Handling the vulnerabilities of the HMI is part of the broader cybersecurity risk assessment, as defined by the CRA.

Before placing a product on the EU market, the manufacturer has to carry out and document an assessment of the cybersecurity risks associated with the product, taking into account its intended purpose and the context in which it is used. The risk assessment therefore serves to identify vulnerabilities and to minimise the attack surface from the development phase of the product onwards. It defines measures such as protected access, secure configurations, data protection and reliable update mechanisms, based on how and where the product will be used.

The Modbus protocol, for example, in its commonly used forms offers neither authentication nor encryption: the risk has to be addressed in the design, with measures such as network segregation and access control. A vulnerability in a software library, on the other hand, requires assessing its impact and, when needed, updating the software. Both aspects must be documented.

The risk assessment is not a one-off activity: it has to be updated throughout the product's lifecycle, especially whenever a software update changes the risk profile.

When a vulnerability is actively exploited

A known vulnerability and an actively exploited vulnerability call for different actions. In the second case, the manufacturer must report it, according to the deadlines below, to ENISA (European Union Agency for Cybersecurity) and to the national CSIRT (Computer Security Incident Response Team) through the single European SRP (Single Reporting Platform).

  • Within 24 hours: a first alert, or early warning.
  • Within 72 hours: a notification with information on the vulnerability and the measures taken.
  • Within 14 days of a fix or a mitigation becoming available: a final report.

For severe incidents, the final report is due within one month of the incident notification.

Affected users must be informed promptly, without undue delay, with guidance on how to contain the risk even when the update is not ready yet.

To meet these deadlines, you need a process that lets you quickly work out which products are affected and who has to act.

The work we take on

At Oktima we have a team dedicated to the CRA. For the runtime integrated into your HMIs, we track the dependencies and provide you with the analysis results (SBOM, VEX).

The process starts before release and continues on published versions:

  • Before the stable release, we generate the SBOM and check it against vulnerability databases. Every finding goes through triage, and we release the stable version only when no known exploitable vulnerabilities remain.
  • After the stable release, we continuously re-analyze the published versions. When a vulnerability emerges, we assess whether and how it affects the runtime.
  • If action is needed, we notify you with measures to contain the risk and prepare the fix. When it is available, you receive the update and the information to apply it.

In your reserved area you will find the SBOM of every version, the VEX updated daily and a status page:

  • SBOM and VEX are in CycloneDX format. You can import them into your analysis tools and integrate our analysis data into your product's documentation. The VEX keeps the results of our analyses carried out during triage, with their justifications.
  • The status page mirrors the VEX: you can see at any time which vulnerabilities are being triaged and which already have an outcome from our assessment. Security notifications are also sent to the email address you specify.
  1. Us

    Every day we match the SBOMs of the published versions against vulnerability databases. Reports can also come in from researchers or customers.

    You

    When a vulnerability emerges, the status page shows it as "in triage".

From the fix to the machine, with Oktima

When we publish a runtime fix, you update Oktima, generate the application again, test it and install it on the affected devices. Testing the application and rolling it out to the machines remain activities you have to plan.

As manufacturers, you remain responsible for the risk assessment of the whole product, including software components outside the Oktima application, the technical documentation, conformity and CE marking, the reports due to the authorities and informing your customers.

What to do now

Responsibility cannot be delegated. If the machine carries your name, you answer for the software it contains, third-party libraries and the vendor's runtime included. A vendor can take work off your hands, not responsibility. The reporting obligations are already in force, also for machines already delivered. From December 2027, vulnerability handling becomes a condition for CE marking. Who keeps track of what is installed, who assesses the reports and what each supplier guarantees has to be settled and verified beforehand, not when an answer is needed within a few hours.

With Oktima, the part of this work that concerns your HMI's runtime is on us. If you are developing a new HMI or evaluating an alternative to your current workflow or development tool, contact us.

Further reading: the text of the regulation and the European Commission guidance for manufacturers.