Bottom line: With the non-binding, four-part Technical Guideline TR-03183, the BSI provides guidance on SBOM, vulnerability management and conformity assessment for the Cyber Resilience Act.
The German Federal Office for Information Security (BSI) has published Technical Guideline TR-03183, a non-binding orientation aid for manufacturers of networked products who must prepare for the requirements of the Cyber Resilience Act. For compliance officers, the document provides concrete guidance on SBOM, vulnerability management and evidence of conformity, but it does not replace a formal declaration of conformity.
The Cyber Resilience Act (CRA) obliges manufacturers of networked products to meet security requirements throughout the entire product lifecycle, to manage vulnerabilities, to comply with reporting obligations, and to document all software components used. The regulation takes full effect from 11 December 2027. With Technical Guideline TR-03183, the BSI has now published a starting aid intended primarily to give orientation to manufacturers without mature IT security processes in development and vulnerability handling. TR-03183 is explicitly not a binding standard and cannot be used as proof of CRA conformity; it is intended to be replaced in the medium term by harmonised European standards.
The guideline is divided into four parts. Part 1 (“General Requirements”, version 1.0.0) consolidates the general requirements for manufacturers and products along the CRA articles and annexes. Part 2 (version 2.1.0) addresses the Software Bill of Materials (SBOM) and includes, among other things, a mapping recommendation between required data fields and the SPDX and CycloneDX formats, a revised licensing section, and newly introduced virtual and referenced components. Part 3 (version 1.0.0) describes how to handle incoming vulnerability reports as a core component of the CRA reporting obligations. Part H (version 1.1.0) governs conformity assessment under Module H based on an ISO/IEC 27001-compliant information security management system, for example in line with IT-Grundschutz — manufacturers with an existing ISMS can use it to extend their processes to product development and vulnerability handling.
Following a comment period, Part 1 is additionally available as interim version 0.10.0, which includes a risk-based approach for selecting IT security measures as well as an initial collection of generic measures in the machine-readable OSCAL format. This content is additionally available on Github; access can be requested via the functional mailbox tr03183@bsi.bund.de. For SBOM creation under Part 2, the BSI has also set up its own, officially registered namespace for CycloneDX, whose taxonomy is publicly available on the BSI’s Github account.
For compliance teams, the document primarily provides a structured checklist that can guide the development of CRA-relevant processes, without this being able to serve as a basis for deriving a formal conformity status. Given the transition period until the end of 2027, early engagement with SBOM processes, vulnerability management, and the question of whether an existing ISMS can be used as evidence under Module H is advisable.
Source: www.it-daily.net · Published 14 August 2026
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