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Vehicle telematics backend CRA Risk Assessment Starter

A pre-filled Cyber Resilience Act risk assessment for a connected-vehicle telematics service and its backend, covering the digital elements an OEM or supplier places on the market outside type approval. It covers the Annex III/IV classification and the conformity route that follows from it, a starter asset inventory, a STRIDE threat analysis mapped to Annex I Part I essential cybersecurity requirements, and the likelihood and impact scales those threats are scored against. Treat it as a first draft to challenge and replace with your own product's specifics before it becomes a technical file.

ForProduct, engineering and compliance leads at manufacturers in automotive starting a CRA self-assessment, and the consultants who onboard them.
CRA Articles
Article 13Article 32Annex I Part IAnnex V

1. Product classification and conformity route

Article 7, Annex III, Annex IV, Article 32

Product: [your product name]

Proposed classification: Default class product with digital elements, not listed in Annex III or Annex IV

Justification: Products covered by UNECE R155/R156 type approval are excluded from the CRA under Article 2. This template therefore scopes the digital elements outside that exclusion, such as the companion service and backend, as a default-class product. Confirm with your homologation team exactly which components sit inside type approval before relying on this scope.

Conformity route: Article 32(1), internal control (self-assessment)

Standards to apply: ISO/SAE 21434; ISO 24089; IEC 62443-4-1

Decision owner: [name, role]
Decision date: [date]

Note

Classification drives everything downstream, so settle it before writing the assessment. Check whether any component of your product is separately listed, and record who signed the decision and when. If your product is marketed with a function listed in a higher class, that class wins.

2. Asset inventory

Annex I Part I (1), Article 13(3), Annex VII
AssetTypeClassificationWhy it matters
Telematics backend servicecomponentinternalCloud services receiving vehicle telemetry and issuing commands.
Vehicle-to-cloud channelnetworkconfidentialMobile-network link between the vehicle and the backend.
Vehicle location historydatarestrictedPosition and journey data, personal data under GDPR.
Remote command functionfunctionrestrictedRemote lock, climate and immobiliser-adjacent commands.
OTA update distributionfunctionrestrictedDelivery path for software updates to the fleet.
Driver accountuser relatedrestrictedOwner and driver identities linked to the vehicle.
Fleet availabilitysocietalconfidentialConsequence of a backend outage across many vehicles at once.

Assets to add: [anything specific to your architecture, such as third-party services, hardware security modules or region-specific data stores]

Note

An asset is anything an attacker would want to reach, break or abuse. Delete rows that do not exist in your product and add the ones that make yours different, since generic inventories produce generic threats. Classify each asset by the harm its exposure would cause rather than by where it happens to be stored.

3. Threat analysis (STRIDE)

Annex I Part I (2), Article 13(2)
ThreatSTRIDEAssetL / IAnnex I ref
An attacker exploits known, not fixed vulnerabilities in the product under review.elevation of privilegeTelematics backend servicehigh / highANNEX I Part I (2)(a)
An attacker exploits a vulnerability for which a security update is available but not installed.elevation of privilegeTelematics backend servicehigh / highANNEX I Part I (2)(c)
An attacker exploits a weakness in the default configuration of the product under review.elevation of privilegeTelematics backend servicehigh / highANNEX I Part I (2)(b)
An attacker gains unauthorized access to the product under review.elevation of privilegeRemote command functionhigh / highANNEX I Part I (2)(d)
An attacker discloses confidential data stored in the product under review.information disclosureVehicle location historymedium / highANNEX I Part I (2)(e)
An attacker discloses confidential data transferred to or from the product under review.information disclosureVehicle-to-cloud channelmedium / highANNEX I Part I (2)(e), ANNEX I Part I (2)(m)
An attacker tampers with data transferred to or from the product under review.tamperingOTA update distributionmedium / highANNEX I Part I (2)(f), ANNEX I Part I (2)(m)
An attacker uses the product under review to negatively impact the availability of services provided by other devices or networks.denial of serviceFleet availabilitymedium / highANNEX I Part I (2)(i)
An attacker extracts remaining data and/or settings that the user did not delete.information disclosureDriver accountmedium / highANNEX I Part I (2)(m)
An attacker performs a security-relevant activity that is not recorded or monitored by the product under review.repudiationRemote command functionmedium / mediumANNEX I Part I (2)(l)
Note

Each threat is tied to an asset and to an Annex I Part I essential requirement, which is what an authority will ask you to evidence. Likelihood and impact here are starting values from the CRA threat catalogue. Re-score them against your own deployment: an interface that is unreachable in your architecture is not a medium risk just because the catalogue says so.

4. Risk criteria

Annex I Part I (1), Article 13(3), Annex VII
ScaleLevelScoreMeaning
likelihoodRare1Exceptional occurrence. Highly unlikely during the product lifecycle.
likelihoodUnlikely2Could occur, but only under limited circumstances or with significant effort.
likelihoodPossible3Realistic occurrence under credible attack conditions.
likelihoodLikely4Expected to occur in multiple realistic scenarios or repeated attempts.
likelihoodAlmost Certain5Expected to occur frequently or with minimal attacker effort.
impactNegligible1Minimal operational disruption and no meaningful cybersecurity consequence.
impactMinor2Limited disruption or localized loss with low recovery effort.
impactModerate3Noticeable service disruption, data exposure, or recovery effort requiring management attention.
impactMajor4Severe business disruption, major data compromise, or significant recovery cost.
impactCatastrophic5Critical operational failure, widespread compromise, safety implications, or major regulatory impact.
Note

Document the scales before you score anything, otherwise the scoring is unfalsifiable. These are the default five-by-five scales. Adjust the wording so it reflects consequences your organisation actually recognises, and state your risk acceptance threshold explicitly.

5. Risk treatment and mitigations

Annex I Part I (2), Article 13(1)
  • Telematics backend service: Address known exploitable vulnerabilities before release and maintain an effective vulnerability management process.
  • Telematics backend service: Ensure timely deployment of security updates and monitor update compliance.
  • Telematics backend service: Harden default settings, minimise enabled services, and require secure initial configuration.
  • Remote command function: Bind remote commands to a verified owner session and the specific vehicle, with anomaly limits on command rate.
  • Vehicle location history: Encrypt and minimise location history, and honour erasure requests across backups.
  • Vehicle-to-cloud channel: Mutually authenticate the vehicle and backend with per-vehicle certificates.
  • OTA update distribution: Sign update packages and verify signatures on the vehicle before installation.
  • Fleet availability: Ensure vehicles retain core function when the backend is unreachable.
  • Driver account: Erase driver profiles and paired accounts on vehicle resale.
  • Remote command function: Log and monitor security-relevant events by default and protect monitoring evidence.

For each risk, record: treatment (accept / mitigate / transfer / avoid), the control that implements it, the residual score after treatment, and the owner.

Accepted risks: [list, with the justification and who accepted them]

Note

A mitigation that is not implemented is not a mitigation. Point each line at a real control, a configuration default or a design decision you can evidence. Accepted risks are legitimate, but they need a named accepter and a reason that survives scrutiny.

6. Vulnerability handling and reporting readiness

Annex I Part II, Article 13(8), Article 14

Coordinated vulnerability disclosure contact: [security.txt URL, security contact]

Support period: [end date, per Article 13(8)]

SBOM: [format, where it is maintained]

Article 14 reporting: actively exploited vulnerabilities and severe incidents are reported to ENISA and the CSIRT within 24 hours (early warning) and 72 hours (notification).

Named responsible person: [name, role]

Note

The risk assessment is one half of Annex I. Part II obligations run for the whole support period, so the reporting path has to exist before you place the product on the market, ready ahead of your first exploited vulnerability.

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