Cyber Resilience Act (CRA) for smart home security products: Guide to EN 304 632

08/09/2026

    In this article, we examine the draft of the vertical standard CRA EN 304 632, its scope, requirements and how to use this standard to achieve compliance. 

    What Is the EN 304 632 Standard and Its Role in CRA Compliance

    EN 304 632 is a product-specific cybersecurity standard for smart home security products that supports compliance with the Cyber Resilience Act (CRA). The draft standard provides guidance for identifying cybersecurity risks, implementing appropriate security controls, and generating evidence that may support future CRA conformity assessments.

    By translating general CRA obligations into requirements tailored to residential security products, EN 304 632 helps manufacturers address the specific cybersecurity challenges associated with this category of products and their particular threat landscape.

    EN 304 632 Scope and Applicability

    Which Products Does EN 304 632 Apply To?

    The scope of EN 304 632 standard covers smart home products with security functionalities (SHPSF), as defined in Commission Implementing Regulation (EU) 2025/2392, category number 17. These products protect the physical security of consumers in a residential setting and can be controlled or managed remotely from other systems, as well as hardware and software that centrally control such products:

    Smart door locking devices

    products with digital elements that control physical access to a residence, including exterior locks, interior locks, and object locks for securing valuables.

    Baby monitoring systems

    products with digital elements that monitor the presence or activity of persons (especially infants) in a residential setting, using audio/video input, motion detection, or fall detection.

    Alarm systems

    products with digital elements that detect hazardous situations (intrusion, fire, gas, hold-up) and notify users or trigger actuator responses (sirens, lights).

    Home security cameras

    products with digital elements that capture video and/or audio for residential physical security purposes.

    Central control hardware and software

    gateways, mobile applications, and cloud-based Remote Data Processing Solutions (RDPS) that centrally control or manage the above products.

     

    Some examples of products included but not limited to are:

    • Smart lock with mobile app and cloud backend
    • Wireless alarm system with sensors, siren, and monitoring app
    • IP camera for home surveillance with cloud recording
    • Smart doorbell with video/audio and remote access
    • Smoke/CO detector with network-connected notification
    • Smart window/door sensor integrated into an alarm panel

    Which products are NOT covered?

    It is important to notice that smart home products are only covered when they provide a residential physical security function as defined in clause 4. Products with digital elements that do not provide such functions — for example, a generic smart speaker without security functionality — are not in scope.

    How is 304 632 structured?

    Main sections of the EN 304 632 standard

    The structure can be understood through the following key blocks:

    Clause 1 — Scope: defines which products fall within scope and which are excluded.

    Clause 2 — References: normative references (prEN 40000-1-3 for vulnerability handling, Agreed Cryptographic Mechanisms) and informative references (CRA Regulation, implementing regulations, etc.).

    Clause 3 — Definitions: extensive glossary of architecture-related terms, asset categories, communication types, data asset types, function asset types, interface types, operational environments, and user categories — all specific to smart home security products.

    Clause 4 — Product context: describes the product functions (residential physical security functions and supporting functions), product architecture (hardware/software architectural components), operational environments (fully controlled, partially controlled, mobile), interfaces (human, machine, logical, physical), and user categories (consumers, service providers, manufacturers).

    Clause 5 — Requirements specifications: the core technical requirements for the product, organized into 12 requirement groups.

    Clause 6 — Assessment criteria: detailed compliance verification procedures for each requirement.

    Annexes:

    • Annex A: mapping between the document and the requirements of the CRA Regulation (EU) 2024/2847.
    • Annex B: guidance for applying the document.
    • Annex C: methodology for cybersecurity risk assessment, including impact class determination.
    • Annex D (normative): relationship between specific data/function assets and impact classes.
    • Annex E (normative): detailed protection measures — authentication strength levels, integrity protection levels, confidentiality protection levels.
    • Annex F: relationship between the document and covered/not covered cybersecurity risks.
    • Annex G: relationship between the document and ETSI EN 303 645 / ETSI TS 103 701 (consumer IoT security).

    Cybersecurity requirements in EN 304 632

    EN 304 632 covers 12 groups of technical requirements for smart home security products:

    • No Known Exploitable Vulnerabilities: products must have no insufficiently mitigated known exploitable vulnerabilities at market launch. They must support secure software update mechanisms covering every software component (except immutable parts), and must support automated updates and update notifications when connected to a public network.
    • Secure by Default Configuration: products must ship with authentication mechanisms enabled at the appropriate strength level (basic, normal, enhanced, or strong — depending on the impact class of the function), automated updates enabled by default, update notifications enabled, and a factory reset mechanism that restores all settings and deletes user data.
    • Authentication and Access Control: products must enforce access control and authentication for functions whose use can cause harm. The required authentication strength is determined by a matrix of impact class (low/medium/high) × attack surface (physical environment × communication type × interface type). Authorization policies must follow least privilege, and granted permissions must be revocable.
    • Integrity Protection: products must verify the integrity and authenticity of software packages before installation, and must protect the integrity of communicated integrity-relevant data. Protection strength levels scale with the impact class of the data/function.
    • Confidentiality Protection: products must use confidentiality-protecting secure storage for persistently stored confidential data, and confidentiality-protecting communication mechanisms for transmitted confidential data. Strength levels scale with the confidentiality impact class and the physical operational environment.
    • Data Minimization: products must only process confidential data according to their intended purpose, with documented justification.
    • Availability Protection: products must restore connectivity after power loss, support local operation when network is unavailable for time-sensitive functions, reconnect cleanly after network loss, warn users before or during non-availability of medium+ impact functions, notify users of upcoming power limitations, prioritize network and power resources for critical functions, prevent amplification attacks, rate-limit incoming packets, and support scheduling of updates.
    • Impact Minimization: products must minimize the impact of security incidents on affected data and functions.
    • Limit Attack Surface: products must validate and sanitize external data input, provide only necessary physical and logical interfaces by default, install only necessary apps by default, and use secure boot where high-impact functions are provided.
    • Logging and Monitoring: products must create audit events at levels appropriate to their risk class — low risk products log configuration changes and errors; medium risk adds failed authentication and access attempts; high risk logs all authentication events and access attempts. High-risk products must use real-time timestamps and automatic log backup to a separate physical location.
    • Deletion Mechanisms: products must allow users to permanently remove their data and installed applications, including subsets thereof.
    • Other Technical Requirements: products must notify users when security functions are unavailable, use clear and distinct security-related notifications, visually distinguish security configuration in GUIs, use only state-of-the-art cryptography (as listed in Agreed Cryptographic Mechanisms or providing minimum 112-bit security strength), and ensure preinstalled and generated passwords and cryptographic keys meet minimum complexity and length requirements.

    prEN40000-1-3 Vulnerability Handling Conformity

    Vulnerability Handling Conformity for smart home security products is based on the baseline requirements referenced from the horizontal standard plus product-specific considerations.

    The harmonized standard dictates that the product manufacturer is expected to implement vulnerability handling processes according to CEN/CLC JT013090:2026 (prEN 40000-1-3) "Cybersecurity requirements for products with digital elements – Vulnerability Handling", so this document shall also be consulted.

    The standard requires compliance with prEN 40000-1-3 for the SHPSF, and additionally specifies that products must have no known exploitable vulnerabilities at the time of market launch (NKEV-MKAV). Vulnerabilities that emerge after launch are subject to the ongoing vulnerability handling processes defined in prEN 40000-1-3.

    How to use the EN 304 632 standard?

    The EN 304 632 standard has been created to comply with the CRA and understand the essential cybersecurity requirements for smart home products with security functionalities. The requirements in this document follow a risk-based approach, applying conditionally to ensure that security measures are appropriate to the deployment context and level of threat exposure.

    Smart home products with security functionalities must comply with the standard when they provide residential physical security functions. Products without security functionality are not in scope.

    To determine which requirements are applicable to a specific product, the standard provides a structured approach based on impact classes:

    • Determine the impact class for each data and function asset: using Annex D, classify each data asset (e.g., video input data, intrusion detection data, cryptographic keys) and each function asset (e.g., lock functions, alarm functions, detection functions) into impact classes for confidentiality, integrity, and availability. For example, video data from a security camera has high confidentiality impact; a lock function has high availability impact.
    • Determine the attack surface: for each architectural component, consider the communication type (public, adjacent, local, strict local, physical), the interface type (human, machine, logical, physical), and the physical operational environment (fully controlled, partially controlled, mobile). These three dimensions define the attack surface.
    • Map impact class × attack surface to required protection levels: using the tables in clause 5 (Tables 1–6), determine which requirements apply and at which protection strength level. For example, a smart lock communicating over public networks with a high impact class requires AUTH.Enhanced authentication.
    • Verify against Annex A: check that all CRA Annex I, Part I requirements are addressed. Annex A provides a mapping between the technical requirements and the CRA.
       

    Example: Battery-powered door sensor

    It would be reasonable to determine that a battery-powered door sensor (low confidentiality impact, local communication only, fully controlled environment) requires lower protection levels than a cloud-connected security camera (high confidentiality impact, public communication, mobile deployment).

    When the risk assessment has been determined, the next step is analyzing which cybersecurity requirements are applicable. Tables with a mapping between impact classes and requirements are included to understand which requirements have to be applied. Some of the requirements have been defined specifically for smart home security products while others — such as no known exploitable vulnerabilities and state-of-the-art cryptography — are addressed by applying the requirements described in horizontal standards.

    Impact on stakeholders

    All the stakeholders related with smart home products with digital elements will be impacted directly or indirectly by CRA requirements:

    Product teams

    shall establish roadmaps to ensure that the products are designed, developed, and produced considering the necessary cybersecurity requirements. This includes implementing secure update mechanisms, access control, integrity/confidentiality protection, logging, and secure boot. They shall also establish procedures to enforce all the necessary requirements for the product, including those related to documentation, default configurations, and vulnerability management. Products with time-sensitive functions (e.g., real-time alarm transmission) must carefully balance update scheduling against availability requirements.

    Security teams

    from product companies shall now ensure a secure lifecycle for every product with digital elements, including vulnerability handling and enforcement of security requirements throughout all the product lifecycle. They must ensure that preinstalled passwords and cryptographic keys are unique per device, that logging mechanisms capture appropriate events at the correct impact level, and that log files are backed up to a separate physical location for high-impact products.

     

    Legal and compliance teams

    will have to elaborate the EU declaration of conformity as well as many other obligations, such as providing related manufacturer information (name, trademark, contact details) and declaration of conformity (original or simplified), or keeping the technical documentation and the EU declaration of conformity at the disposal of the market surveillance authorities for at least 10 years or for the support period, etc.

     

    The most significant impact for users

    is that it improves a better understanding and access to information related to the cybersecurity of a product. Users must carefully read Annex II of Regulation (EU) 2024/2847 to verify that all the elements that shall accompany the product are provided. These elements include unique identification information about the product, contact points to receive and report vulnerabilities, security properties information, how updates are received and installed, etc. Users will also benefit from clear, distinct security notifications and visual indicators for security-related configuration changes.

     

    EN 18031 Reuse and Test Plan

    EN 304 632 requirements overlap significantly with the horizontally applicable EN 18031 series (ICT product cybersecurity). Of the 51 technical requirements, approximately 15 (29%) can largely reuse EN 18031 test methods and results, 24 (47%) require partial supplementation, and 12 (24%) demand entirely new testing capabilities.

    Three representative examples illustrate the reuse model:

    Example 1 — [AUM-FH] Authentication (Basic Coverage, reuse ~80%)

    EN 304 632 requires authentication for functions whose use can cause harm, with strength levels determined by a matrix of impact class × attack surface. EN 18031 AUM-1 through AUM-6 provide comprehensive coverage of authentication mechanisms across all three parts. The core test methodology — conceptual assessment, functional completeness, functional sufficiency — is directly reusable.

    What's new in EN 304 632: a four-tier strength classification (Basic / Normal / Enhanced / Strong) with specific attack-type coverage per tier (e.g., Enhanced must resist person-in-the-middle attacks, Strong must resist elaborate security token spoofing). The test plan reuses EN 18031 authentication test cases as the baseline, then supplements with Annex E attack-type-specific tests for each applicable strength level.

    Example 2 — [SDC-AUM-FH] Default Authentication Configuration (Partial Coverage, reuse ~50%)

    EN 304 632 requires that products ship with authentication mechanisms enabled at the appropriate strength level by default. EN 18031 AUM-2 requires that authentication mechanisms exist and are properly implemented, but does not mandate that they be enabled in the factory default state.

    The test plan reuses EN 18031's authentication mechanism verification, but adds a mandatory default-state inspection step: restore the product to factory defaults, then verify that (1) authentication is active, (2) the strength level matches the required matrix entry, and (3) no configuration bypass is available without authentication. This supplementary step requires approximately 4 additional test hours per product variant.

    Example 3 — [AVAI-TIME-RECO-POW] Restoration After Power Loss (No Coverage, 0% reuse)

    EN 304 632 requires that hardware architectural components resume connectivity and functionality as soon as power supply is restored after a loss of power. EN 18031 has no equivalent requirement — this is specific to smart home security products where power interruptions directly impact physical security (e.g., a smart lock must re-establish its functions after a power outage).

    The test plan requires entirely new capability: a controlled power-cycling test rig, measurement of recovery time from power restoration to full operational state, and verification that all time-sensitive security functions (lock control, alarm transmission, sensor polling) resume within acceptable bounds. Estimated development: 16 person-hours for test procedure + 4 hours per product test execution.

    Example: Smart Door Lock

    Consider a smart door lock with the following characteristics:

    • Exterior lock function (high impact class for availability — IMP.AVAI.TIME.High)
    • Communicates via Wi-Fi to a cloud RDPS (public communication)
    • Mobile app for remote access (logical human interface)
    • Battery-powered hardware component
       
    Requirement Applicable Control Evidence
    [AUM-FH] Authentication AUTH.Enhanced authentication for remote unlock via public communication Test: attempt unlock without authentication; verify rejection. Test: verify authentication strength meets Enhanced level (see Annex E.1.1.4)
    [SDC-AUM-FH] Default config Authentication enabled by default in factory state Inspection: inspect product in default configuration; verify authentication is required
    [NKEV-SUM-AUTO] Auto updates Automated security update mechanism Test: connect to internet; verify updates are downloaded and installed without user intervention
    [AVAI-TIME-OUTA-NOT] Non-availability notification Warn user before/during unavailability of lock function Test: simulate power loss; verify notification is sent to user
    [AVAI-TIME-RES-PRIO] Power prioritization Prioritize lock function during low battery Test: simulate low battery; verify lock function is prioritized over non-critical functions
    [LOG-HIGH] Logging Log all authentication attempts and access attempts Inspection: verify log files contain timestamps, authentication events, and access attempts
    [INT-SWPCK] Software integrity Verify integrity and authenticity of software packages before installation Test: attempt to install unsigned package; verify rejection
    [CONF-SSM] Secure storage Confidentiality-protecting storage for cryptographic keys Test: verify cryptographic keys are stored using mechanisms meeting CONF.SSM.Normal strength (partially controlled environment)

    How Applus+ Laboratories can support CRA compliance

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