Carrier router / CPE CRA Risk Assessment Starter
A pre-filled Cyber Resilience Act risk assessment for a customer-premises or carrier-grade routing equipment with a remote management plane and operator-pushed firmware. 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 12: Routers, modems intended for the connection to the internet, and switches)
Justification: The product is a router intended for connection to the internet, listed in Annex III, Class I, point 12. Conformity therefore follows an Important Class I route under Article 32.
Conformity route: Article 32(2). Self-assessment requires applying harmonised standards in full, otherwise a notified-body route applies
Standards to apply: EN 18031-1; ETSI EN 303 645; IETF RFC 9116
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 |
|---|---|---|---|
| Router firmware image | component | internal | Signed firmware and bootloader delivered through operator update channels. |
| Management plane | function | restricted | TR-069/NETCONF and local admin interfaces used to configure the device. |
| WAN interface | network | internal | Internet-facing interface exposed to unsolicited traffic. |
| Subscriber LAN traffic | data | confidential | Customer traffic traversing the device. |
| Admin credentials | data | restricted | Local admin and remote-management secrets. |
| Routing and NAT function | function | internal | Forwarding, NAT and firewall rule evaluation. |
| Subscriber account | user related | confidential | The end-customer identity bound to the device. |
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 | Router firmware image | 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 | Router firmware image | 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 | Router firmware image | high / high | ANNEX I Part I (2)(b) |
| An attacker gains unauthorized access to the product under review. | elevation of privilege | Management plane | high / high | ANNEX I Part I (2)(d) |
| An attacker exploits vulnerabilities in functionality not required for intended use or core functionality. | elevation of privilege | WAN interface | medium / high | ANNEX I Part I (2)(j) |
| An attacker discloses confidential data transferred to or from the product under review. | information disclosure | Subscriber LAN traffic | medium / high | ANNEX I Part I (2)(e), ANNEX I Part I (2)(m) |
| An attacker impacts the availability of basic or essential functions during an incident. | denial of service | Routing and NAT function | medium / high | ANNEX I Part I (2)(h) |
| An attacker exploits a vulnerability because the user was not aware an update needed to be installed. | elevation of privilege | Router firmware image | medium / high | ANNEX I Part I (2)(c) |
| An attacker performs a security-relevant activity that is not recorded or monitored by the product under review. | repudiation | Management plane | medium / medium | ANNEX I Part I (2)(l) |
| An attacker exploits a vulnerability introduced by a weak configuration because the product cannot revert to its secure default configuration. | tampering | Admin credentials | 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)- Router firmware image: Address known exploitable vulnerabilities before release and maintain an effective vulnerability management process.
- Router firmware image: Ensure timely deployment of security updates and monitor update compliance.
- Router firmware image: Harden default settings, minimise enabled services, and require secure initial configuration.
- Management plane: Disable WAN-side management by default and require per-device unique credentials.
- WAN interface: Ship with unused services and debug ports closed on the WAN side.
- Subscriber LAN traffic: Use secure communication channels with encryption and communication partner authentication.
- Routing and NAT function: Rate-limit control-plane traffic so the device stays manageable under flood conditions.
- Router firmware image: Notify subscribers of security updates and their installation state, including when the support period ends.
- Management plane: Log and monitor security-relevant events by default and protect monitoring evidence.
- Admin credentials: Provide secure factory reset and documented recovery procedures.
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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