EN 18031 Compliance: How Manufacturers Can Meet the EU RED-DA Cybersecurity Requirements

What is EN 18031 and Why it Matters

In January 2025, the European Union officially adopted EN 18031 as the harmonized cybersecurity standard for RED-DA (Radio Equipment Directive Delegated Act). This regulation mandates that wireless equipment, regardless of device type, meet specific cybersecurity capabilities related to: 

• Data protection
• Unauthorized access prevention
• Secure financial transactions
   

Complying with EN 18031 is no longer optional—it's essential for CE marking and EU market access. Manufacturers that fail to comply risk delayed product launches, blocked imports, or legal penalties.

Key Cybersecurity Requirements Under RED Article 3.3(d)(e)(f)

The RED-DA enforcement activates three crucial clauses under RED Article 3.3:

• 3.3(d): Products with connectivity functions must prevent unauthorized access and misuse of data.
• 3.3(e): Devices that handle personal data must provide privacy-by-design protections.
• 3.3(f): Devices with transaction/payment capabilities (e.g., POS, mobile payments) must use advanced encryption and authentication mechanisms.
   

Important: Compliance is based on device functions, not categories. If your product connects to a network, processes personal data, or supports payments, it must comply.

Two Compliance Pathways: Self-Declaration vs. Third-Party Certification

Most products can follow a self-assessment pathway using EN 18031 as the testing benchmark. Manufacturers can complete the Declaration of Conformity (DoC) and affix the CE mark without involving a third party—speeding up market entry.

However, some high-risk devices require third-party conformity assessment:

When You Need a Notified Body:

• Lacks user/password authentication
• Involves child usage without parental controls
• Handles payment or transaction data

These cases require evaluation from a Notified Body and the issuance of an EU-Type Examination Certificate (EU-TEC) to comply.
 

Proactive Cybersecurity: Leading Brands Are Already Complying

Forward-thinking manufacturers like Google have integrated cybersecurity design and third-party testing into their development lifecycle—even before regulations take effect. By doing so, they not only ensure RED-DA compliance but also build:

• Stronger market trust
• Transparency through published test results
• Faster time-to-market

This “compliance-first” strategy boosts both resilience and competitiveness.
 

Best Practices for Building RED-DA-Compliant Products

To help manufacturers future-proof their products and meet EN 18031 standards, here's what to integrate from day one:
Design Phase:

• Apply the Security by Design principle
• Choose certified modules (Wi-Fi, Bluetooth) to reduce compliance costs
• Document: architecture diagrams, encryption flows, protocols, user auth mechanisms

Development Phase:

• Conduct internal risk assessments
• Incorporate privacy design early
• Use secure coding practices

Launch Preparation:

• Perform self-assessment or third-party testing
• Prepare and archive technical documentation
• Generate the Declaration of Conformity (or obtain EU-TEC if needed)
   

RED-DA is More Than Compliance—It's a Competitive Advantage

RED-DA isn’t just another regulation—it's a turning point for product competitiveness in global markets. Manufacturers who embrace early planning, standardized testing (EN 18031), and cybersecurity integration will:

• Ensure uninterrupted EU market access
• Improve brand trust and user loyalty
• Reduce long-term compliance costs
• Outpace competitors still playing catch-up

In the future, compliance won’t be a checkbox—it will be your product's passport to global success.