Smart home security hub CRA Risk Assessment Starter
A pre-filled Cyber Resilience Act risk assessment for a consumer hub integrating smart locks, cameras and alarm sensors, paired to a mobile app and a vendor cloud. 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: Important, Class I (Annex III, Class I, point 17: Smart home products with security functionalities, including smart door locks, security cameras, baby monitoring systems and alarm systems)
Justification: The hub provides security functionality for smart door locks, cameras and alarm systems, which is listed in Annex III, Class I, point 17. The product is consumer-facing, so Annex II user information obligations apply in full.
Conformity route: Article 32(2). Self-assessment requires applying harmonised standards in full, otherwise a notified-body route applies
Standards to apply: ETSI EN 303 645; EN 18031-1; EN 18031-2
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 |
|---|---|---|---|
| Hub firmware | component | internal | Hub application firmware and secure boot chain. |
| Lock and alarm control function | function | restricted | Commands that unlock doors or disarm the alarm. |
| Camera video stream | data | restricted | Live and recorded footage from paired cameras. |
| Local pairing radio | network | internal | Zigbee/Z-Wave/BLE link used to pair and command peripherals. |
| Vendor cloud channel | network | confidential | Remote-access channel between the app, the cloud and the hub. |
| Household member profile | user related | restricted | Resident identities, access schedules and presence data. |
| Pairing keys | data | restricted | Peripheral pairing secrets and cloud device tokens. |
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 | Hub 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 | Hub 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 | Hub firmware | high / high | ANNEX I Part I (2)(b) |
| An attacker gains unauthorized access to the product under review. | elevation of privilege | Lock and alarm control function | high / high | ANNEX I Part I (2)(d) |
| An attacker discloses confidential data stored in the product under review. | information disclosure | Camera video stream | medium / high | ANNEX I Part I (2)(e) |
| An attacker tampers with data transferred to or from the product under review. | tampering | Local pairing radio | medium / high | ANNEX I Part I (2)(f), ANNEX I Part I (2)(m) |
| An attacker discloses confidential data internally processed in the product under review. | information disclosure | Household member profile | medium / high | ANNEX I Part I (2)(e) |
| An attacker uses the product under review to negatively impact the availability of services provided by other devices or networks. | denial of service | Vendor cloud channel | medium / high | ANNEX I Part I (2)(i) |
| An attacker extracts remaining data and/or settings that the user did not delete. | information disclosure | Household member profile | medium / high | ANNEX I Part I (2)(m) |
| An attacker performs a security-relevant activity that is not recorded or monitored by the product under review. | repudiation | Lock and alarm control function | medium / medium | ANNEX I Part I (2)(l) |
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)- Hub firmware: Address known exploitable vulnerabilities before release and maintain an effective vulnerability management process.
- Hub firmware: Ensure timely deployment of security updates and monitor update compliance.
- Hub firmware: Harden default settings, minimise enabled services, and require secure initial configuration.
- Lock and alarm control function: Bind unlock and disarm commands to an authenticated user session and a paired device, never to network position alone.
- Camera video stream: Encrypt stored footage and scope retention to what the user has configured.
- Local pairing radio: Authenticate peripheral commands so replayed radio frames cannot open a lock.
- Household member profile: Minimise presence and occupancy data and keep it out of third-party analytics.
- Vendor cloud channel: Keep local arm/disarm and lock control working when the vendor cloud is unreachable.
- Household member profile: Erase resident profiles, footage and pairing keys on factory reset before resale or disposal.
- Lock and alarm control 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]
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.
Start the assessment