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Annex · Aerodry against CRA Annex I, requirement by requirement

The full conformity report referred to in entry 002. The same format we produce for manufacturers, applied to our own prototype.

Published

This is the report behind entry 002. It is the format we deliver to clients: each essential cybersecurity requirement of Annex I, its status on the prototype, the concrete evidence supporting that status, and the nature of the fix. The last column is usually the one that surprises, because it shows how many requirements are not solved by touching the code.

Status: not met · partially met · met · N/A not applicable.

Part I, security properties of the product

#Requirement (Annex I, Part I)StatusEvidence on the prototypeNature of the fix
1No known exploitable vulnerabilities when placed on the marketFrozen dependencies, no CVE triage processProcess and SBOM
2Secure configuration by defaultFixed, shared access password; services in the clear by defaultFirmware and manufacturing
3Vulnerability fixes through updatesOTA mechanism exists, but no secure channelFirmware and infrastructure
4Protection against unauthorised accessUpdate endpoint and server without authenticationFirmware and infrastructure
5Confidentiality of data, including encryption at rest and in transitPlain HTTP; the home’s Wi-Fi stored without encryptionFirmware
6Integrity of data, commands, configuration and firmwareUnsigned firmware; commands without verificationFirmware and infrastructure
7Collect only the data neededOnly temperature, humidity and relay stateKeep in the design
8Availability of essential functionsSafety cutoffs exist; no network protection against denial of serviceFirmware
9No harm to other devices or the networkSmall surface, no amplification effectKeep in the design
10Minimise the attack surfaceFew services, but the HTTP OTA is always onFirmware
11Reduce the impact of an incidentNo separation between the control function and the network interfaceFirmware
12Log security-relevant activityOperational logs exist, but no security eventsFirmware
13Allow data and settings to be erased at end of lifeNo secure reset; credentials persist on resaleFirmware and documentation

Part II, vulnerability handling

#Requirement (Annex I, Part II)StatusEvidence on the prototypeNature of the fix
1Component inventory (machine-readable SBOM)Dependencies copied into the repository, no SBOMDocumentation and build
2Fix vulnerabilities without delayThe mechanism exists; the response process does notFirmware and process
3Regular security testingNo defined test cycleProcess
4Disclose fixed vulnerabilitiesNo channel and no security history for the productProcess and organisation
5Coordinated vulnerability disclosure policyThe site’s security.txt is an embryo; PGP and a product policy are missingOrganisation
6Make vulnerability reporting easyA generic contact exists; a dedicated security contact is missingOrganisation
7Distribute updates securelyOTA unsigned and without an encrypted channelFirmware and infrastructure
8Security updates available without delay and free of chargeTechnically possible; no committed support periodProcess and infrastructure

The count

There are 21 applicable requirements, 13 in Part I and 8 in Part II. 2 are met, 8 are partially met, and 11 fail.

Entry 002 describes nine flaws: they are the ones with direct consequence for whoever uses the product, and they are spread across both parts. This annex shows the full table, including what the entry does not develop, such as the Part II process gaps, less visible but equally required.

The reading by nature of fix

If we look at the fixes by their nature, instead of requirement by requirement, firmware appears in about eleven requirements, but almost never alone. Infrastructure appears in about six, process in about seven, documentation in about four, and organisation in about four. Manufacturing appears in only one, the per-unit password, but that fix is mandatory and is not solved in code.

Bar chart: firmware appears in about eleven requirements, process in seven, infrastructure in six, documentation and organisation in four each, and manufacturing in a single requirement, whose fix is mandatory and lies outside the code.
The natures of the fix counted over the table: firmware almost never comes alone.

The sum passes 21 because most requirements need more than one nature of fix at the same time. That overlap is what makes the sequencing of the work, the subject of entry 003, the real value of the service, rather than the list itself.