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(CRA, NIS2, DORA)European cybersecurity regulation is converging around a single, unambiguous message: security must be designed into products, not retrofitted after incidents occur. With the Cyber Resilience Act (CRA), NIS2 Directive, and DORA now in force or applicable, software companies face a materially different compliance landscape—one that extends beyond IT operations into product design, supplier governance, and executive accountability.The CRA is particularly significant because it introduces horizontal cybersecurity obligations for products with digital elements, regardless of sector. This means that many software vendors who previously operated outside sector-specific regimes must now demonstrate secure development practices, vulnerability management, and incident reporting capabilities. The obligation is not simply to “be secure,” but to prove that security has been systematically addressed throughout the product lifecycle. Software bills of materials (SBOMs), coordinated vulnerability disclosure processes, and documented secure development lifecycles are becoming baseline expectations rather than best practices.NIS2 reinforces this shift by expanding the scope of regulated entities and elevating governance requirements. Boards and senior management are now explicitly accountable for cybersecurity risk management, incident response, and third-party security controls. For software vendors selling into essential or important entities, NIS2 obligations flow through contracts, procurement processes, and customer assurance demands. Security posture is increasingly assessed not only by regulators, but by customers acting under regulatory pressure themselves.DORA adds a further layer for software companies operating in or supplying the financial sector. While DORA formally applies to regulated financial entities, its operational resilience requirements cascade into contracts with ICT providers. Audit rights, incident reporting support, resilience testing participation, and subcontractor controls are no longer negotiable edge cases; they are structural contract terms. Vendors unprepared to support these obligations risk exclusion from regulated supply chains.Taken together, these regimes redefine cybersecurity as a product attribute with legal, commercial, and reputational implications. The open-source dimension underscores this point. Regulatory guidance increasingly recognizes the role of open-source software and introduces tailored expectations for maintainers and stewards. However, this does not eliminate responsibility; it reframes it. Organizations must understand where open-source components sit within their products and how associated risks are governed.Strategically, the most effective response is integration. Security, legal, product, and procurement teams must align around shared controls, evidence frameworks, and response playbooks. Organizations that fragment responsibility—treating cybersecurity as an isolated technical concern—will struggle to meet overlapping regulatory expectations.In contrast, companies that embed security-by-design into development and supplier management not only reduce regulatory risk, but also strengthen trust with enterprise customers. In an environment where security failures quickly become commercial failures, demonstrable resilience is becoming a prerequisite for sustainable growth.
