Mobile robot controller CRA Risk Assessment Starter
A pre-filled Cyber Resilience Act risk assessment for a autonomous mobile robot or cobot controller with fleet management, teleoperation and over-the-air updates. 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.
1. Product classification and conformity route
Article 7, Annex III, Annex IV, Article 32Product: [your product name]
Proposed classification: Default class product with digital elements, not listed in Annex III or Annex IV
Justification: A robot controller is not listed in Annex III or Annex IV, so it is a default-class product with digital elements under the Article 32 self-assessment route. The Machinery Regulation applies in parallel; the CRA assessment covers the digital elements and does not displace machinery safety conformity.
Conformity route: Article 32(1), internal control (self-assessment)
Standards to apply: IEC 62443-4-1; ISO 10218; ISO 3691-4
Decision owner: [name, role]
Decision date: [date]
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| Asset | Type | Classification | Why it matters |
|---|---|---|---|
| Robot controller firmware | component | internal | Navigation, motion and safety-adjacent controller software. |
| Teleoperation channel | network | restricted | Remote command and video link used by operators. |
| Fleet management link | network | confidential | Connection to the fleet orchestrator issuing mission assignments. |
| Navigation map data | data | confidential | Site maps and no-go zones that constrain movement. |
| Motion command function | function | restricted | The path that translates commands into physical motion. |
| Shared workspace safety | societal | restricted | Physical risk to people sharing the robot's operating area. |
| Operator account | user related | restricted | Identities permitted to teleoperate or change missions. |
Assets to add: [anything specific to your architecture, such as third-party services, hardware security modules or region-specific data stores]
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)| Threat | STRIDE | Asset | L / I | Annex I ref |
|---|---|---|---|---|
| An attacker exploits known, not fixed vulnerabilities in the product under review. | elevation of privilege | Robot controller firmware | high / high | ANNEX I Part I (2)(a) |
| An attacker exploits a vulnerability for which a security update is available but not installed. | elevation of privilege | Robot controller firmware | high / high | ANNEX I Part I (2)(c) |
| An attacker exploits a weakness in the default configuration of the product under review. | elevation of privilege | Robot controller firmware | high / high | ANNEX I Part I (2)(b) |
| An attacker gains unauthorized access to the product under review. | elevation of privilege | Motion command function | high / high | ANNEX I Part I (2)(d) |
| An attacker tampers with data transferred to or from the product under review. | tampering | Teleoperation channel | medium / high | ANNEX I Part I (2)(f), ANNEX I Part I (2)(m) |
| An attacker tampers stored data in the product under review. | tampering | Navigation map data | medium / high | ANNEX I Part I (2)(f) |
| An attacker impacts the availability of basic or essential functions during an incident. | denial of service | Shared workspace safety | medium / high | ANNEX I Part I (2)(h) |
| An attacker gains unauthorized access to the product under review. | elevation of privilege | Fleet management link | high / high | ANNEX I Part I (2)(d) |
| An attacker performs a security-relevant activity that is not recorded or monitored by the product under review. | repudiation | Motion command function | medium / medium | ANNEX I Part I (2)(l) |
| An attacker exploits a vulnerability introduced after market placement by installing malware removable by a factory reset mechanism. | tampering | Robot controller firmware | medium / high | ANNEX I Part I (2)(b) |
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| Scale | Level | Score | Meaning |
|---|---|---|---|
| likelihood | Rare | 1 | Exceptional occurrence. Highly unlikely during the product lifecycle. |
| likelihood | Unlikely | 2 | Could occur, but only under limited circumstances or with significant effort. |
| likelihood | Possible | 3 | Realistic occurrence under credible attack conditions. |
| likelihood | Likely | 4 | Expected to occur in multiple realistic scenarios or repeated attempts. |
| likelihood | Almost Certain | 5 | Expected to occur frequently or with minimal attacker effort. |
| impact | Negligible | 1 | Minimal operational disruption and no meaningful cybersecurity consequence. |
| impact | Minor | 2 | Limited disruption or localized loss with low recovery effort. |
| impact | Moderate | 3 | Noticeable service disruption, data exposure, or recovery effort requiring management attention. |
| impact | Major | 4 | Severe business disruption, major data compromise, or significant recovery cost. |
| impact | Catastrophic | 5 | Critical operational failure, widespread compromise, safety implications, or major regulatory impact. |
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)- Robot controller firmware: Address known exploitable vulnerabilities before release and maintain an effective vulnerability management process.
- Robot controller firmware: Ensure timely deployment of security updates and monitor update compliance.
- Robot controller firmware: Harden default settings, minimise enabled services, and require secure initial configuration.
- Motion command function: Authenticate every motion command source and reject commands that would exceed the configured safety envelope.
- Teleoperation channel: Integrity-protect teleoperation with replay resistance and a watchdog that halts on link loss.
- Navigation map data: Sign map and no-go-zone data so tampering cannot route the robot into a restricted area.
- Shared workspace safety: Fail to a controlled stop rather than continuing the last commanded motion.
- Fleet management link: Implement strong authentication, least privilege, and access control enforcement.
- Motion command function: Log and monitor security-relevant events by default and protect monitoring evidence.
- Robot controller firmware: Implement trusted reset, malware removal capability, and integrity-protected restore workflows.
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]
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 14Coordinated 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]
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.
Start this assessment in CVD Portal
Create the product and CVD Portal pre-fills this asset inventory, the matching STRIDE threats and your risk criteria, ready to review and adjust.
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