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Annex III, Class I, point 11

Is an operating system an important product under the CRA?

Yes. Operating systems are named in Annex III Class I, with no qualifier. A general-purpose OS, an embedded OS and a real-time OS are all important products with digital elements.

ClassImportant - Class I
What that class requiresSelf-assessment only if harmonised standards applied; else notified body

The category, quoted in full:

Operating systems

Annex III, Class I, point 11, Regulation (EU) 2024/2847

There is no size or purpose threshold in the category, so an RTOS in a small device is in it on the same basis as a desktop OS.

Frequently confused with:

  • Is a hypervisor Class I or Class II under the CRAImportant - Class II

    Hypervisors and container runtimes are Class II, one class above the operating systems they run. An OS that ships virtualisation is not thereby promoted to Class II: classification follows the core functionality of the product as placed on the market, and recital 4 of Implementing Regulation (EU) 2025/2392 rejects reading a component category onto the whole.

  • Boot managersImportant - Class I

    Boot managers are point 8. Shipping them together does not merge the categories.

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
Hypervisors & container runtimesHypervisors and container runtimes are Annex III Class II, so third-party assessment by a notified body is mandatory rather than optional.Boot managersBoot managers are Annex III Class I. A bootloader is firmware rather than an application, which does not remove it from the category.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.