Cyber Resilience Act (CRA): TLCTC Pain Points & Fixes

TL;DR

CRA is a strong step for secure‑by‑design and lifecycle obligations for products with digital elements. But it lacks a shared, causal threat taxonomy. If implementers stay effect‑oriented ("ransomware incident") instead of cause‑oriented (e.g., #9 → #7 → #4), the Regulation’s reporting, conformity assessment, and market surveillance will struggle to deliver real, measurable risk reduction. TLCTC fixes this with 10 cause‑based clusters and an attack‑path notation you can adopt without changing a single recital.

The TLCTC lens in 30 seconds

• Strategic layer (10 clusters): #1 Abuse of Functions | #2 Exploiting Server | #3 Exploiting Client | #4 Identity Theft | #5 Man‑in‑the‑Middle | #6 Flooding Attack | #7 Malware | #8 Physical Attack | #9 Social Engineering | #10 Supply Chain Attack.
• Operational layer: Every real attack is a sequence of those clusters (attack path), e.g., #10 → #7 → #4.
• Axioms that matter for CRA: Threats are causes (not outcomes), and credentials are control elements (Axiom X), not “just data”.

Main CRA pain points (from the TLCTC perspective)

1. 1) No common, cause‑based threat taxonomy

   Problem:

   CRA obligations talk about vulnerabilities, severe incidents and updates, but they don’t standardize how we classify the initiating threat. This invites heterogeneous labels ("APT", "malware", "ransomware") that mix actor, effect and tool.

   TLCTC impact:

   Without a unified dictionary (#1–#10), incident data isn’t comparable across products, sectors, or Member States.

   Fix:

   Add a one‑line Attack Path (TLCTC) field to manufacturer incident/vuln notifications and market‑surveillance templates.

2. 2) Everything becomes a “vulnerability,” blurring #1 vs. #2 vs. #3

   Problem:

   CRA centers on vulnerability management. But many compromises start with #1 Abuse of Functions (logic/scope misuse) rather than #2/3 (code defects on server/client).

   TLCTC impact:

   Treating logic abuse as a “bug” hides root causes, weakens design reviews, and skews KPIs.

   Fix:

   In design and conformity files, separate logic‑abuse risks (#1) from code‑defect risks (#2/#3) and show distinct mitigations.

3. 3) Credentials framed as data, not control elements (#4)

   Problem:

   Many products still rely on shared secrets, weak device pairing, or recoverable tokens. These are often handled as "data protection" rather than system control.

   TLCTC impact:

   When credentials are stolen or replayed (#4 Identity Theft), the system is already compromised per TLCTC Axiom X.

   Fix:

   Mandate phishing‑resistant, device‑bound credentials and secure key lifecycle in product security design files; ban recoverable tokens for admin paths.

4. 4) Update channels secure in theory, brittle in practice (#5 MitM, #10 Supply Chain)

   Problem:

   CRA requires secure updates, but designs frequently omit pinning, transparency logs, or hardware‑rooted trust.

   TLCTC impact:

   Attack paths like #10 → #7 (supplier build/repo compromise) or #5 → #7 (MitM of update transport) remain practical.

   Fix:

   Prove update authenticity and provenance (signing + transparency + device‑bound verification). Treat update infrastructure as a separate product with its own TLCTC posture.

5. 5) Under‑specified resilience to #6 Flooding Attacks

   Problem:

   DoS/overload scenarios on device APIs, local services, or companion cloud endpoints are common but under‑modeled.

   TLCTC impact:

   Capacity exhaustion (#6) derails availability and can mask lateral movement.

   Fix:

   Include rate‑limit, back‑pressure, fail‑safe and service‑level degradation patterns in essential‑requirements test plans; add abuse‑case testing for traffic storms.

6. 6) Social engineering left to the user (#9)

   Problem:

   CRA focuses on product security controls, not human manipulation.

   TLCTC impact:

   If the user is tricked into unsafe flows (#9) that the product happily executes, you still lose.

   Fix:

   Encode protected workflows (e.g., irreversible actions gated by out‑of‑band confirmation, trusted UI cues, anti‑spoof UX) as part of product requirements; test them.

7. 7) Malware execution pathways not explicit (#7)

   Problem:

   CRA requires secure development and updates but rarely demands a proven execution‑control model (what can run, from where, with what rights).

   TLCTC impact:

   Attackers thrive on environments that execute foreign code or LOLBAS (#7).

   Fix:

   Ship an execution policy: allow‑listing, namespace/jail constraints, signed‑only modules, and runtime egress controls; verify via tamper‑evident attestation.

8. 8) Physical attack surface under‑integrated (#8)

   Problem:

   Tamper resistance, debug port lockdown, and secure erase are often an afterthought.

   TLCTC impact:

   Physical interaction (#8) regularly leads to credential extraction (#4) or unsigned‑code execution (#7).

   Fix:

   Explicitly enumerate physical threats in the risk file and link them to #4/#7 mitigations (e.g., sealed debug, measured boot, hardware‑backed key storage).

9. 9) Supply‑chain exposure not measured as #10

   Problem:

   SBOMs and supplier questionnaires exist, but they don’t score exposure to #10 Supply Chain Attack—build pipelines, signing services, and update CDNs remain opaque.

   TLCTC impact:

   Portfolio risk is dominated by third‑party trust assumptions.

   Fix:

   Add a #10 exposure score: build isolation, signer protection, package provenance, and update distribution integrity; require attestations.

10. 10) Incident reporting without attack‑path means weaker analytics

    Problem:

    CRA reporting asks for severe incidents and actively exploited vulnerabilities—but not the standardized causal chain.

    TLCTC impact:

    ENISA and CSIRTs receive effect‑centric data that’s hard to compare.

    Fix:

    Add the one‑liner Attack Path (TLCTC): e.g., #9 → #7 → #4 to all notifications and final reports; aggregate at EU level by first cluster.

11. 11) Conformity assessment not anchored in threat→control mapping

    Problem:

    Checklists verify presence of controls, not their fit to initiating threats.

    TLCTC impact:

    Two products with the same controls can be wildly different in exposure to #1/#5/#10.

    Fix:

    Require a TLCTC Control Matrix: for each of the 10 clusters, show the top preventive/detective measures and verification evidence.

12. 12) SaaS/service dependencies create gray zones

    Problem:

    Many products depend on companion cloud services or mobile apps for core functions. Regulatory scope and assurance duties become fuzzy at the product/service seam.

    TLCTC impact:

    Real attack paths often traverse device ↔ app ↔ cloud (#5/#6/#10).

    Fix:

    Document and test end‑to‑end attack paths across all components, even if some sit outside strict product scope; contractually flow down TLCTC controls to service providers.

Common CRA attack‑path patterns (ready for your incident forms)

Use these to tag incidents and trend first cluster over time.

Implementation kit (drop‑in, no law changes required)

• Add an Attack Path (TLCTC) line to all internal and external notifications.
• Maintain a TLCTC Risk Register per product: list top 3 initiating clusters, controls, verification artifacts.
• Build a 10×5 TLCTC × NIST CSF control matrix in your technical documentation; mark which are “local” vs “umbrella” controls.
• Annotate your SBOM with supplier #10 exposure and provenance attestations.
• In market surveillance, publish quarterly cluster distributions and targeted advisories (e.g., spike in #5 on OTA updates).

Closing thought

CRA will drive better engineering—if we align around causes. TLCTC supplies the missing common language. Add one line (the attack path) to your reports and one matrix (threat→control) to your conformity files, and watch your analytics—and your actual risk posture—become radically clearer.