As OEMs navigate Europe’s evolving cybersecurity requirements, the relationship between Machinery Regulation, the Cyber Resilience Act (CRA) and NIS2 becomes increasingly central. Once that relationship is understood, a practical question quickly follows: How should engineering teams and internal processes evolve to support it?
For many OEMs, the foundations are already in place. Cybersecurity is discussed during design reviews. Vendor hardening guidance is applied. Software updates are tested before release. These activities are not new.
What is often missing is structure, clear ownership, and traceability. This gap can feel like another layer added to already constrained engineering timelines. But the objective is not to turn machine builders into cybersecurity companies. It is to make existing engineering discipline visible, repeatable, and defensible when customers, auditors, or authorities ask for evidence.
What this looks like in everyday engineering terms
Under the CRA, manufacturers must be able to demonstrate that cybersecurity considerations were integrated during design, that known exploitable vulnerabilities were not ignored when products were placed on the market, and that there is a defined approach for managing vulnerabilities and delivering security updates throughout the product lifecycle.
In practice, this requirement usually exposes gaps in how information is organized, not a lack of activity. One OEM, for example, already had design reviews and release testing in place, but cybersecurity evidence was spread across multiple tools and teams.
Instead of redesigning the entire process, the team created a controlled cybersecurity evidence pack for a single flagship machine family. It included a maintained digital component inventory, a concise record of security‑relevant design decisions, such as interface exposure and remote access assumptions, and a simple vulnerability‑handling workflow with named owners. Crucially, this information was explicitly linked to the technical documentation for that machine family.
None of these elements were new. The value came from making them structured, traceable, and reusable.
Once this work was completed once, the team found it significantly easier to respond to questions under the Machinery Regulation, the CRA, or NIS2 without rebuilding the narrative each time.
Why structure matters for CRA reporting timelines
The CRA introduces demanding reporting timelines. For actively exploited vulnerabilities and severe incidents, manufacturers are required to issue an early warning within 24 hours, followed by more complete notification within 72 hours.
This is one of the key reasons OEMs are formalising processes now. When vulnerability handling is informal or distributed across teams without clear ownership, meeting these timelines becomes extremely difficult, especially under pressure, when decisions must be made quickly and consistently.
A fully mature system is not required on day one. But a defined system must exist.
Seen through real machine environments
These challenges are not theoretical. An HVAC OEM supplying equipment to data centers may now face detailed questions around connectivity, software update policies, component tracking, and security support periods, because cooling availability has become mission critical.
A packaging OEM integrating machines into a discrete manufacturing line may encounter scrutiny around access control, software versions, and update governance, particularly when the end customer operates under NIS2 obligations and must justify how supply‑chain cybersecurity risks are managed.
In both cases, the conversation shifts rapidly from “Is it secure?” to “How can you demonstrate that it is?”
A grounded perspective
Schneider Electric is navigating this same transition. As a manufacturer of connected products, we are aligning product lifecycle practices and technical documentation with the CRA. As an organization operating across Europe, we are also addressing NIS2 obligations at entity level where applicable. At the same time, we work closely with OEMs and understand the practical constraints they face:
- Compressed engineering schedules
- High product variant complexity
- Long support periods
- Increasing customer scrutiny
What is clear is that cybersecurity, safety, and documentation can no longer evolve independently.
A practical starting point
For many OEMs, the current state is best described as “not yet” or “only partially.” What matters is establishing a solid foundation, whether as a targeted initiative or as the first phase of a wider transformation.
A practical way forward is to start with a clearly defined scope: one product family, one pilot technical file, and one cross‑functional team. From there, a small number of focused actions can deliver immediate value. Establish clear ownership for product cybersecurity, even if initially part‑time. Formalise a digital component inventory with basic change control.
Put in place a simple vulnerability‑handling workflow with defined responsibilities and documented decisions. Then integrate this cybersecurity evidence into the technical documentation for one or two flagship machines before extending the approach further.
These steps are deliberately pragmatic, but they are also strategic. They establish a reusable foundation that can support the Machinery Regulation, the CRA, and NIS2 in parallel today, while also providing a solid baseline for a broader transformation program where scale or ambition requires it.
The key question for OEMs
The objective is not to address the Machinery Regulation, the CRA, and NIS2 as separate compliance exercises. It is to establish a single, coherent operating model that supports all three.
The question for OEMs is therefore a practical one: Have engineering practices, documentation, and internal processes been structured in a way that consistently demonstrates how safety, cybersecurity, and lifecycle responsibilities are connected?
For many, the honest answer today may still be “not yet” or “only partially.” In that case, now is the right moment to begin with a limited and controlled scope, build clarity and traceability, and use that foundation to evolve with confidence as expectations continue to rise.
This is less about reacting to regulation, and more about strengthening the way machines are designed, delivered, and supported in an increasingly connected world. Discover how Schneider Electric Advisory Services can help achieve your goals with cybersecurity regulations.
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