Guide
The CE technical file under the Cyber Resilience Act
Before a product with digital elements carries the CE marking, the CRA requires technical documentation, Annex VII says what goes in it. Here is what authorities expect to find, how long you must keep it, and how to keep it true between releases.
Yes, it is a hard requirement: no file, no CE marking
Article 31 of the Cyber Resilience Act requires manufacturers to draw up the technical documentation before the product is placed on the EU market, and Annex VII defines exactly what it must contain. This is the document a market surveillance authority asks for first: it is your proof that the essential cybersecurity requirements are actually met. Around 90% of products fall into the "default" category and self-assess conformity, which makes the file even more important, because there is no notified body certificate to hide behind. The file IS the assessment.
What Annex VII actually asks for
Seven blocks: (1) a general description of the product, intended purpose, software versions affecting compliance, hardware, user instructions; (2) a description of your design, development, production and vulnerability-handling processes, including the SBOM and your coordinated vulnerability disclosure policy; (3) the cybersecurity risk assessment required by Article 13; (4) the information used to determine the product's support period; (5) the harmonised standards you applied, or a description of the solutions you adopted instead; (6) test reports verifying the essential requirements; (7) a copy of the EU declaration of conformity. Most of it is information your team already has, scattered across wikis, tickets and heads. The work is assembling it into one defensible document.
It must live as long as the product
The technical documentation must be kept at the disposal of authorities for at least ten years after the product is placed on the market, or for the support period, whichever is longer, and it must be kept up to date throughout. A new software version, a change of dependencies, a revised risk assessment: each one invalidates yesterday's file. Treating it as a one-off PDF written for launch day is the most common compliance failure mode, because the document that gets audited is rarely the version that was written.
The practical path
Generate, don't write. The bulk of the file, component inventories, SBOM, vulnerability-handling evidence, version history, already exists as structured data if your compliance tooling tracks it. The right workflow produces the Annex VII structure from your real product data at every release, flags the sections only a human can complete (intended purpose, risk acceptance decisions), and versions each generation so you can show an authority the file as it stood at any date. That turns a weeks-long documentation project into a review task.
The file starts with knowing what's inside your product
Paste a dependency manifest, get a CycloneDX SBOM plus the known vulnerabilities in your components, the first building block of your Annex VII documentation.
Run the free scan →This guide is general information, not legal advice. Sources: Regulation (EU) 2024/2847, Articles 13 and 31, Annexes I, V and VII.