Smart meter gateway CRA Risk Assessment Starter
A pre-filled Cyber Resilience Act risk assessment for a smart metering gateway aggregating consumption data and mediating access between meters, grid operators and consumers. 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: Critical (Annex IV, point 2: Smart meter gateways within smart metering systems as defined in Article 2, point (23) of Directive (EU) 2019/944 and other devices for advanced security purposes, including for secure cryptoprocessing)
Justification: Smart meter gateways within smart metering systems as defined in Directive (EU) 2019/944 are listed in Annex IV, point 2, making this a critical product. Article 32 requires a European cybersecurity certification scheme or a notified-body route; self-assessment is not available.
Conformity route: Article 32(4). A European cybersecurity certification scheme or a notified-body route is required
Standards to apply: BSI TR-03109; EN 50628; IEC 62443-4-2; Common Criteria
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 |
|---|---|---|---|
| Gateway firmware | component | internal | Gateway firmware and secure boot chain. |
| Consumption data | data | restricted | Metering records, which are personal data and reveal household behaviour. |
| Security module keys | data | restricted | Key material held in the gateway's security module. |
| WAN grid channel | network | restricted | Link to the grid operator's head-end system. |
| LMN meter interface | network | internal | Local metrological network link to connected meters. |
| Tariff and switching function | function | restricted | Tariff application and any controllable-load switching capability. |
| Grid stability | societal | restricted | Aggregate consequence of mass manipulation across a meter population. |
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 | Gateway 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 | Gateway 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 | Gateway firmware | high / high | ANNEX I Part I (2)(b) |
| An attacker discloses confidential data stored in the product under review. | information disclosure | Security module keys | medium / high | ANNEX I Part I (2)(e) |
| An attacker tampers stored data in the product under review. | tampering | Consumption data | medium / high | ANNEX I Part I (2)(f) |
| An attacker discloses confidential data transferred to or from the product under review. | information disclosure | WAN grid channel | medium / high | ANNEX I Part I (2)(e), ANNEX I Part I (2)(m) |
| An attacker tampers with data transferred to or from the product under review. | tampering | LMN meter interface | medium / high | ANNEX I Part I (2)(f), ANNEX I Part I (2)(m) |
| An attacker gains unauthorized access to the product under review. | elevation of privilege | Tariff and switching function | high / high | ANNEX I Part I (2)(d) |
| An attacker impacts the availability of basic or essential functions after an incident. | denial of service | Grid stability | medium / high | ANNEX I Part I (2)(h) |
| An attacker performs a security-relevant activity that is not recorded or monitored by the product under review. | repudiation | Tariff and switching 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)- Gateway firmware: Address known exploitable vulnerabilities before release and maintain an effective vulnerability management process.
- Gateway firmware: Ensure timely deployment of security updates and monitor update compliance.
- Gateway firmware: Harden default settings, minimise enabled services, and require secure initial configuration.
- Security module keys: Confine key material to a certified security module with no export path.
- Consumption data: Integrity-protect metering records end to end so billing data cannot be altered undetected.
- WAN grid channel: Carry head-end traffic in mutually authenticated TLS with per-device certificates.
- LMN meter interface: Authenticate meter readings so injected values cannot enter the billing chain.
- Tariff and switching function: Require authenticated, authorised and logged commands for any load switching.
- Grid stability: Rate-limit and stagger fleet-wide commands so a single instruction cannot swing aggregate load.
- Tariff and switching 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.
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