Does the EU Cyber Resilience Act apply to my game?
Short answer (it depends): Commercially sold games with a data connection (online play, launchers, anti-cheat, updates) can be PDEs. Single-player offline titles have a thinner connection but updates and launchers usually connect.
What it means for a game
- Launchers, anti-cheat drivers and multiplayer clients are the biggest attack surface.
- Store distribution (Steam, consoles, mobile stores) to EU players = making available.
- Free-to-play with in-game purchases is generally commercial activity.
- Platform holders don’t take over your manufacturer duties for your game.
Key dates
- 11 Sep 2026: reporting of actively exploited vulnerabilities and severe incidents (ENISA Single Reporting Platform) — applies to products already on the market.
- 11 Dec 2027: main obligations (security requirements, vulnerability handling, support period, CE marking).
FAQ
- I’m based outside the EU? Making your game available to EU users can still bring you in scope.
- What docs would I need? Typically a CVD policy, security.txt, intake page, reporting runbook, support-period statement, risk assessment.
Related: 24h reporting for games
Not legal advice. Templates + software. Verify against the CRA text (Regulation (EU) 2024/2847), Commission guidance C(2026)5252 or a qualified advisor.
Last reviewed: 2026-10-30