EU Cyber Resilience Act reshapes biometric access systems

By Eduard de Knegt, CTO at Recogtech

The European Union’s Cyber Resilience Act (CRA) is often described as a compliance framework. In reality, it is far more disruptive. It challenges how digital products are designed at a fundamental level.

For biometric access control systems, this shift is particularly significant. These systems operate at the intersection of digital identity and physical security, yet many have been built with architectures that prioritise functionality, connectivity and integration over structural resilience. Under the CRA, that balance changes.

Cybersecurity is no longer an additional layer or feature. It becomes an intrinsic property of the product itself, embedded in its design, update mechanisms and vulnerability management throughout the entire lifecycle. Architectural decisions are no longer neutral. They directly determine both risk exposure and regulatory alignment.

Choices around cloud reliance, remote management and network connectivity now carry structural consequences.

A deeper tension underlies many current system designs. For years, the industry has moved toward increasing visibility and control: centralised management platforms, extensive logging, remote configuration and continuous monitoring have become standard practice. From an operational perspective, this makes sense.

From a cybersecurity perspective, however, the logic is fundamentally different. In practice, many systems are still designed in ways that directly contradict these principles.

Every additional interface, service or remote capability expands the attack surface. Systems designed to be continuously accessible, configurable and observable from external environments inherently introduce more entry points. Under the principles of the CRA, this creates a structural conflict: what improves manageability often increases exposure.

This is particularly relevant in biometric systems, where architectures frequently rely on licensing mechanisms, database management and remote service layers. In such models, parts of the system remain dependent, directly or indirectly, on external control. In many cases, this complexity only becomes visible once systems are deployed and operated over time.

These dependencies, whether in update channels, configuration interfaces or backend services, introduce implicit trust that is difficult to fully secure.

As regulatory expectations evolve, this raises a critical question: how much external control should a system actually allow?

Designing for resilience increasingly means limiting that control. Reducing external dependencies, minimising service layers and restricting remote access are not constraints, but deliberate security choices. In this model, the absence of control becomes a feature: fewer interfaces, fewer connections and fewer opportunities for interference.

For manufacturers, this has far-reaching consequences. It challenges established practices around monitoring, remote management and update distribution. Systems that depend on continuous external access or intervention may need to be fundamentally reconsidered.

In this sense, the CRA does not simply introduce new requirements, but also forces a shift in design philosophy. From systems that are always reachable and manageable, to systems that are deliberately constrained, predictable and self-contained.

By contrast, systems designed with limited external dependencies, local decision-making and tightly controlled update mechanisms align more naturally with the direction of the CRA. Reducing the number of external interfaces and maintaining strict control over how and when updates are applied is not just a technical preference. It becomes a strategic requirement.

Despite this, the practical impact of the CRA is still widely underestimated. Across the industry, similar questions continue to surface.

A common point of confusion is who is actually required to comply. The CRA primarily targets manufacturers of products with digital elements placed on the EU market, including providers of access control systems, controllers and embedded solutions. The formal obligation sits with the manufacturer.

However, the implications extend much further. Integrators, distributors and end users are increasingly affected, particularly in environments where cybersecurity requirements are expanding through frameworks such as NIS2. Even organisations without a direct regulatory obligation are beginning to reassess suppliers based on cyber risk and architectural maturity.

This leads to a more fundamental question: how can organisations determine whether a system is prepared for the CRA? In practice, this is not about checking for a label or certification. It is about understanding how a system is built, and what that design exposes.

About the author

Eduard de Knegt is CTO of Recogtech, a company specialising in biometric access control systems and secure system architecture.

Article Topics

access control  |  biometrics  |  cybersecurity  |  digital identity  |  EU  |  Recogtech  |  regulation