Position Papers

The successful entry into force of Article 14 of the Cyber Resilience Act1 on September 11th, 2026, is jeopardized by the lack of clarity in the meaning of “actively exploited vulnerability” (AEV) and “severe incident having an impact on the security of a product with...

Recommendations for the Delegated Act under Article 27(9) of the Cyber Resilience Act Download the position paper Core position A valid EUCC certificate should provide a presumption of conformity only for the CRA requirements and product scope that it demonstrably covers. When additional evidence are required to comply...

Cybersecurity Industry Recommendations on the CRA Guidance Strengthening legal certainty and ensuring consistent implementation of Regulation (EU) 2024/2847 Download Executive Summary Industry welcomes the Commission's work on the Guidance on the application of the Cyber Resilience Act (CRA). The Guidance is essential to support manufacturers, importers, distributors, conformity assessment...

Introduction The European Digital Identity Wallet (EUDIW), established by Regulation (EU) 2024/1183, is the cornerstone of the EU Digital Identity Framework. It aims to provide every EU citizen with a trusted, interoperable digital identity solution, based on decentralized identity principles and usable across borders, both online...

A Key Building Block of the Single Market Requiring the Same Level of Security as the EU Digital Identity Wallet The European Business Wallet is set to become a core component of the Single Market’s digital infrastructure. It will enable companies to exchange official documents, prove...

Eurosmart Recommendations on the Proposal Amending Directive (EU) 2022/2555 (NIS2) Eurosmart welcomes the Commission’s proposal to simplify and improve the implementation of Directive (EU) 2022/2555 (NIS2) in line with the CSA 2 proposal and supports the objective of reducing unnecessary regulatory burden while maintaining a high...

Strengthening and Scaling the European Cybersecurity Certification Framework Download Eurosmart's full feedback [pdf] Eurosmart welcomes the European Commission’s initiative to revise the Cybersecurity Act (CSA2) at a time when Europe faces an increasingly complex cybersecurity landscape shaped by rapid technological evolution, growing threat sophistication and rising strategic...