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    5. Aerospace & the CRA

    Aerospace & the CRA: Why SBOM will be your biggest challenge

    You have the world's strictest safety standards, but the CRA demands something different.

    want to explore your CRA readiness?

    You're already ahead

    If you're developing aerospace systems, you already operate under the most rigorous safety standards in any industry. DO-178C, ARP4754A, DO-326A, you know structured processes better than anyone. Your requirements-to-code-to-test traceability is seamless. Your verification and validation processes are at the highest level. Your configuration management is impeccable, your tools are qualified, and your independent reviews are thorough.

    This discipline gives you a foundation most industries can only dream of.

    But the EU Cyber Resilience Act introduces challenges that even aerospace's rigorous standards don't fully address, particularly around Software Bills of Materials and long-lifecycle vulnerability management.

    Three gaps between Aerospace Standards and CRA Compliance

    1. The SBOM Generation Gap
      DO-178C requires traceability from requirements to object code. You can demonstrate this flawlessly. The CRA asks something different: which third-party components are in your compiled binary, in machine-readable format?

      The challenge is that aerospace often uses proprietary toolchains, Ada, SCADE, Simulink, that standard SBOM tools like SPDX and CycloneDX don't support out-of-the-box. How do you generate a compliant SBOM for SCADE-generated code? Most aerospace teams haven't solved this yet.

    2. The Dynamic Vulnerability Management Gap
      DO-326A requires security risk assessment during development. You perform this thoroughly. The CRA requires continuous monitoring of CVEs for all components throughout the product lifecycle.

      Here's where aerospace's long lifecycles create a unique problem: your products remain in service for 20-30 years. How do you monitor CVEs for a library integrated in 2005? Your risk assessment is static, performed once at development. The CRA requires dynamic monitoring over the entire lifecycle, including for components that may be decades old.

    3. The Third-Party Component Monitoring Gap
      DO-178C requires tool qualification, proving that your development tools won't introduce errors. The CRA requires monitoring of all third-party libraries, not just tools. This includes Commercial Off-The-Shelf (COTS) software components.

      How do you ensure your COTS suppliers will inform you about newly discovered vulnerabilities in components they delivered years ago? Most aerospace supplier contracts don't contain CRA-compliant notification obligations. This gap becomes critical when you need to respond to vulnerabilities in certified systems.

    The infrastructure challenge

    You need automated SBOM generation that works with specialized aerospace toolchains, continuous vulnerability monitoring that spans product lifecycles of 20-30 years, integrated supplier systems that provide real-time notification of component vulnerabilities, and searchable audit trails that connect ancient components to currently deployed systems. This requires new infrastructure designed specifically for aerospace's unique combination of proprietary toolchains, long lifecycles, and safety-critical certification requirements. Standard commercial SBOM and vulnerability management tools don't address aerospace's specific needs.

    Test your readiness with three questions:

    1. Can you generate a machine-readable SBOM for SCADE or Simulink-generated code on demand? If this isn't automated, there's a gap.
    2. Do you have continuous CVE monitoring for all third-party components in your deployed systems, including those certified 10+ years ago? If you rely on manual checking, there's a gap.
    3. Can you trace a newly discovered vulnerability in a third-party component to all affected aircraft and systems within 48 hours? If this requires weeks of investigation, there's a gap.

    These capabilities will determine whether you can meet CRA requirements while maintaining your existing certification obligations.

    What you should do now

    The gap between aerospace safety standards and CRA compliance is real, but it's solvable. The key is addressing SBOM generation for proprietary toolchains and building vulnerability monitoring infrastructure that spans your products' entire lifecycles.

    Start by assessing your current SBOM capabilities for your specific toolchain, evaluating your vulnerability monitoring approach for long-lifecycle products, and reviewing your supplier contracts for CRA-compliant notification obligations. The earlier you address these gaps, the less disruptive the transition will be.

    want to explore your CRA readiness?

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