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Annex III, Class II, point 1

Is a hypervisor Class I or Class II under the CRA?

Class II. Annex III Class II point 1 covers hypervisors and container runtime systems that support virtualised execution of operating systems and similar environments. Class II means third-party assessment by a notified body is mandatory.

ClassImportant - Class II
What that class requiresThird-party (notified body) assessment mandatory

The category, quoted in full:

Hypervisors and container runtime systems that support virtualised execution of operating systems and similar environments

Annex III, Class II, point 1, Regulation (EU) 2024/2847

Container runtimes are named alongside hypervisors, so the category is not limited to full machine virtualisation.

Frequently confused with:

  • Operating systemsImportant - Class I

    Operating systems are Class I point 11 - one class below the hypervisors that run them. Which applies is decided by the core functionality of the product being placed on the market, not by taking the stricter of the two: a hypervisor product is Class II, and an OS that happens to include virtualisation is still an operating system.

Obligations that apply to every product in scope, whatever its class:

  • Essential requirements (Annex I) - secure by design & default
  • Machine-readable SBOM
  • Coordinated vulnerability disclosure policy
  • Security updates across support period (~5 yrs)
  • Technical documentation (Annex VII)
  • Conformity assessment (route depends on class)
  • CE marking + EU Declaration of Conformity
  • 24h / 72h reporting to ENISA + CSIRT (from Sep 2026)

What a manufacturer is assessed against:

  1. Cybersecurity risk assessment Art 13(2)
  2. Secure-by-design essential requirements Annex I Pt I
  3. Vulnerability-handling process Annex I Pt II
  4. Software bill of materials (SBOM) Annex I Pt II §1
  5. Coordinated vulnerability disclosure policy Art 13 · Annex I Pt II
  6. Security updates & support period Art 13(8)
  7. Technical documentation (Annex VII) Annex VII
  8. Conformity assessment & EU Declaration of Conformity Art 28 · Annex V
  9. CE marking Art 30
  10. Vulnerability & incident reporting readiness Art 14 (from 11 Sep 2026)
  11. Economic-operator & market-surveillance obligations Art 13/19–24 · Annex II

The dates that matter:

  • 11 September 2026 - reporting obligations for actively exploited vulnerabilities and severe incidents apply.
  • 11 December 2027 - full compliance applies.
  • Market-surveillance authorities can order corrective action, withdrawal or recall, and fines reach €15 million or 2.5% of global annual turnover.

Check your own products against this

The same rulebook that produced this page runs the free check. It reads your products, classifies each one against Annex III and IV, and gives you an indicative verdict with the reasoning and citation for every product.

All categories
Operating systemsOperating systems are named in Annex III Class I with no qualifier, so a general-purpose, embedded or real-time OS is an important product.Product classificationWhich class each Annex III and IV category falls in, quoted from the regulation, with the conformity route it carries and the categories it is most often confused with.MethodologyThe versioned methodology behind every verdict: the six-step scoping flow, the four product classes, the eleven readiness checkpoints, and the Article each rests on.

Indicative assessment - not legal advice and not a conformity assessment.