Trusted Connectivity Alliance Welcomes Eurosmart Paper on Scaling CRA Conformity Assessment Through ISO 9001 and Module H

Trusted Connectivity Alliance (TCA) welcomes a new position paper from Eurosmart outlining a scalable approach to EU Cyber Resilience Act (CRA) conformity assessment.

The paper explores the use of Full Quality Assurance (Module H) as a conformity assessment route under the CRA and how existing ISO 9001-based Quality Assurance Systems (QAS) can provide a strong foundation for integrating CRA-specific cybersecurity requirements. This reflects the need for conformity assessment approaches that are both robust and scalable, particularly for manufacturers managing large product portfolios and product families.

Towards a Path to Compliance for Telecommunications Products

While TCA fully supports the objectives of the CRA, its members have significant concerns about the lack of a clear and reliable conformity assessment pathway for telecommunications products (e.g. SIM and eSIM) within the current implementation timeline.

TCA therefore welcomes the approach set out by Eurosmart in “CRA Full Quality Assurance – Leveraging ISO 9001 for Module H Conformity Assessment” as one potential route to practical and timely CRA compliance that reduces unnecessary duplication and makes efficient use of Notified Bodies’ capacity, while maintaining the required level of cybersecurity assurance.

In parallel, TCA is closely following the development of CRA-related standardisation activities to support a practical and effective compliance framework for telecommunications products. This includes recognising or leveraging established security assurance frameworks, such as GSMA eSA and SAS-UP, that have successfully supported telecommunications security for many years.

As work progresses, TCA remains fully committed to supporting the successful implementation of the CRA and stands ready to contribute its technical expertise and industry experience to this ongoing dialogue.

About Trusted Connectivity Alliance

Trusted Connectivity Alliance (TCA) is a global industry association working to enable trust in a connected future.

The organisation evolved from the SIMalliance, reflecting the continued expansion of the global SIM industry and the need for broader collaboration. Its members are leading providers of secure connectivity solutions for consumer, IoT and M2M devices. This spans Tamper Resistant Element (TRE) technologies including SIM, eSIM, integrated SIM, embedded Secure Element (eSE) and integrated Secure Element (iSE), as well as hardware and software provisioning and other personalisation services.

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