Free first conversation
What you need, and whether building it is the right answer at all.
Under the Cyber Resilience Act, whoever places a product on the market under their own name is its manufacturer — with CE marking, five years of updates and a 24-hour reporting duty. Settle that before anyone writes code.
Who is the manufacturer, who runs the reporting channel, and who pays for the support period. Written down before development begins.
Establishing in writing which party carries the manufacturer's duties on what is about to be built.
See the programBuilding the application, integration or tool a business needs, documented as it is built.
See the programAdvice to an owner or a board on a technology decision, a supplier, a quotation or a build-or-buy question.
See the programSecurity updates, vulnerability handling and a disclosure route, for a stated period at a stated price.
See the programEach engagement begins by settling in writing who the manufacturer of the result will be, who operates the reporting channel and who carries the support period, and only then moves on to scope, build and handover.
What you need, and whether building it is the right answer at all.
Who is the manufacturer, who reports, who maintains, and at what price.
In increments, documented, with every component and licence listed.
A written support period, or a clear statement that there is none.
Quoted per project or per engagement. A support period is quoted separately, because it is a multi-year commitment and hiding it inside a build price serves nobody.
A scope, a deliverable and a date.
Built, then maintained for a stated period.
Said plainly, because it protects you too.
Every engagement is quoted after a free consultation. No subscription.
TROY is a company incorporated under Belgian law, registered with the Crossroads Bank for Enterprises under enterprise number 0730.891.535, based at Guldensporenlaan in Westerlo in the province of Antwerp, and trading since July 2019. Eddy Aerts has been its director since incorporation. The registered activities are management consultancy at the registered office and computer programming at the establishment that trades as TROY.
The reason this site leads with a regulation rather than a portfolio is that the regulation has quietly changed who carries the risk in a software project. The Cyber Resilience Act makes the business that places a product with digital elements on the market under its own name the manufacturer of it, and the manufacturer's duties are substantial and long-lived: conformity with essential security requirements, CE marking, a software bill of materials, a coordinated disclosure policy, security updates across a support period measured in years, and a report to the authorities within twenty-four hours of learning that a vulnerability is being exploited. Reporting duties already apply; the main obligations follow on 11 December 2027. A company that commissions software and brands it as its own has taken those duties on, usually without being told. So the allocation is settled here in writing before development starts.
Not necessarily, and this is the misunderstanding worth clearing up before money is committed. Under the Cyber Resilience Act the manufacturer is the operator that places the product on the market under its own name or trade mark. If you commission software and then supply it to your customers as your product, that is you. The duties that follow are real work and real cost: conformity with the essential requirements, CE marking, a bill of materials, a disclosure policy, security updates over a support period usually running to at least five years, and a report within twenty-four hours once a vulnerability is known to be exploited. Which party does each of those things, and who pays, belongs in the contract.
That is exactly the boundary that is not settled uniformly, and we would rather say so than give you a confident answer that turns out to be wrong. The Regulation applies to products with digital elements made available on the market; a one-off deliverable supplied to a single business is argued both ways, and the position can turn on how it is supplied and what the client then does with it. Our approach is practical: we decide for your project, record it in writing, and allocate the duties on that basis. If you need a legal opinion on the scope of the Regulation, you need a lawyer, and we will say so.
Two. Since 11 September 2026 the reporting obligations apply: an actively exploited vulnerability or a severe incident has to be notified to the competent CSIRT and to ENISA, starting with an early warning within twenty-four hours. From 11 December 2027 the main body of obligations applies, including the essential cybersecurity requirements, conformity assessment and CE marking. The second date sounds distant and is not, because a product being specified now will still be on the market then, and retrofitting conformity is the expensive way to arrive.
Because it is a different kind of commitment and burying it in a build price misleads everybody. A support period runs for years and carries a cost every one of them: monitoring for vulnerabilities in your own code and in every component you depend on, issuing updates within the expected timescales, and keeping a channel open for anyone who reports a problem. Quoting it separately lets you see the real cost of ownership and decide who should carry it. It also means that where we have not quoted it, there is no doubt that nobody is doing it.
It is an accurate inventory of the third-party and open source components a product contains, with versions and licences. It matters because a vulnerability in a widely used component becomes everybody's vulnerability overnight, and the first question is always which products contain it. Without a list, answering takes days. With one, it takes minutes. We build the inventory as development proceeds rather than reconstructing it at the end, which is also when uncomfortable licence surprises turn up.
No, and be wary of anyone who says yes. What can be committed to is the discipline around it: proportionate measures applied, components tracked, updates issued within agreed times, a route by which a researcher can report something, and prompt disclosure of anything we learn. A guarantee of invulnerability is not a thing that exists, and offering one discourages exactly the precautions that make a real difference.
A free first conversation, with no obligation. We will tell you where the duties land before you commit a budget.