Product class
Is an IAM or PAM product an important product under the CRA?
Short answer: Yes, as a category. An IAM or PAM product is listed in Annex III, Class I. Under Article 7(1), a product whose core functionality is that of a listed category is an important product, so whether your product is one depends on its core functionality.
“Identity management systems and privileged access management software and hardware”
Technical description
Commission Implementing Regulation (EU) 2025/2392 gives the technical description of each category in the annexes. It says what the category covers, in the Official Journal's words.
“Identity management systems are products with digital elements that provide mechanisms for authentication or authorisation and that may also provide mechanisms for the lifecycle management of identity credentials of natural persons, legal persons, devices or systems, such as identity registration, provisioning, maintenance, deregistration. These systems include access management systems that control access of natural persons, legal persons, devices or systems to digital resources or physical locations.
Privileged access management software is an access management system that controls and monitors access rights to IT or OT systems and sensitive information within an organisation, including systems enforcing differentiated access control policies for privileged users.
This category includes but is not limited to authentication and access control readers, biometric readers, single sign-on software, federated identity management software, one-time password software, hardware authentication devices such as transaction authentication number (TAN) generators, authentication software and multi-factor authentication software.”
What Class I means for the conformity route
Article 32(2) caveat: self-assessment via internal control remains available only if you apply in full harmonised standards, common specifications or European cybersecurity certification schemes at assurance level at least 'substantial'; where you apply them only in part or not at all, or none exist, EU-type examination followed by production control (module B+C) or full quality assurance (module H) applies.
The wording of Article 32(2) is quoted in the product classes guide.
When it applies
Since 11 June 2026, the rules on notified conformity assessment bodies, Chapter IV (Articles 35 to 51), have applied. The reporting duties of Article 14 have applied since 11 September 2026. The CRA will apply in full from 11 December 2027. The wording of the application clause is quoted in the product classes guide.
Edge cases
- Free and open-source software. Article 32(5) has its own rule for Annex III products. The wording of Article 32(5) is quoted in the product classes guide.
- The core functionality decides. Check your product's core functionality against the annex text quoted above. The wording of Article 7(1) is quoted in the product classes guide.
Questions and answers
Where does an IAM or PAM product sit in the CRA annexes?
See the short answer and the annex quote at the top of this page.
Does an IAM or PAM product need a notified body?
Not in every case: internal control stays open only where the Article 32(2) conditions are met, as the route section above sets out.
When do the CRA rules for an IAM or PAM product apply?
Reporting duties under Article 14 have applied since 11 September 2026, and the CRA will apply in full from 11 December 2027.
Cybiq checks the CRA only. Orientation, not legal advice. Quoted spans come from Regulation (EU) 2024/2847 as published in the Official Journal and are re-verified against the live text by automated tests. Verify before relying on any item; for an assessment of your own product, consult a qualified lawyer.