RED Cybersecurity Requirements Are Now Enforceable: What Manufacturers Must Do

Since 1 August 2025, the cybersecurity, privacy and fraud-protection requirements of the EU Radio Equipment Directive (Article 3.3(d)(e)(f)) are fully enforceable. Products placed on the EU market must demonstrate compliance with the harmonised standards EN 18031-1/-2/-3 — or be assessed by a Notified Body where standards cannot be applied.

What Changed

Before this date, Article 3.3 was deferred. Now, internet-connected radio equipment must protect networks from harm, safeguard personal data and privacy, and support fraud-prevention features. Toys, childcare equipment and wearable wireless devices are explicitly in scope.

Compliance Paths

Practical Steps for Manufacturers

1. Inventory — list all radio-connected products placed on the EU market and their update mechanisms.
2. Gap analysis — compare firmware security features (secure boot, update signing, credential handling) against EN 18031.
3. Testing — run the RED DA assessment together with RF/EMC/safety in one campaign.
4. Documentation — include the cybersecurity report in the technical file referenced by your DoC.

Products already on the market before the deadline are not retroactively affected, but any new placement on the market now requires compliance.

Frequently Asked Questions

Which products are affected?

Radio equipment that connects to the internet or networks — Wi-Fi, Bluetooth, cellular products. Toys, childcare equipment and wearables are explicitly included regardless of connection type.

Can we self-declare cybersecurity compliance?

Only if EN 18031 standards can be fully applied and the assessment is done by an accredited laboratory. Where the standards cannot be applied, a Notified Body must issue an EU-type examination certificate.

Does this add much time to certification?

The RED DA assessment typically adds one to two weeks when combined with the standard RED campaign, assuming firmware is test-ready.

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