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The CRA's paperwork layer: which annex holds what, and what's still missing

Current to 26 August 2026 · updates land in the changelog.

By full application, every in-scope product carries a document set — and the CRA's annexes map it precisely. Knowing which annex holds what turns “CRA documentation” from a fog into a checklist of four artifacts.

The map

ArtifactWhereWhat it is
Technical documentationAnnex VIIThe evidence file behind the product: design, development, vulnerability handling, risk assessment — the thing assessments and authorities actually read.
EU declaration of conformityAnnex VThe formal claim of compliance, drawn up per product.
Simplified DoCAnnex VIThe short form that can accompany the product, pointing to the full declaration.
Assessment modulesAnnex VIIIThe conformity procedures (Module A internal control; B+C; H) that your class selects among.

The timeline the paperwork rides

Notified bodies can stand up from 11 December 2026 (the conformity-assessment-body chapter), and the full obligation set — documentation, assessment, CE marking — applies from 11 December 2027. With Class I's self-assessment route closed until harmonised standards are cited, documentation quality is what determines whether a third-party engagement runs in weeks or quarters.

What's still missing — the honest gaps

Two absences worth planning around, both tracked in our updates feed: the Article 33(5) simplified technical-documentation form for SMEs is provided for but not adopted — when it ships, it will reshape how small manufacturers structure the Annex VII file — and SMEs already have a statutory softener in proportionately reduced conformity-assessment fees (Article 32(6)). Documentation built now against the Annex VII headings ports cleanly into whatever the SME form looks like; documentation deferred until 2027 does not.

Related guides

Quick answers

Which CRA annex covers technical documentation?
Annex VII. The EU declaration of conformity is Annex V (simplified form Annex VI), and the conformity-assessment modules are Annex VIII.
Is there a simplified CRA documentation form for SMEs?
Provided for (Article 33(5)) but not adopted at our verification date — the main documentation-shaped gap still open. SMEs do get proportionately reduced assessment fees under Article 32(6).
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General information only — not legal advice, and never a conformity assessment. Whether a specific product falls in a listed category is decided against the binding technical descriptions in Implementing Regulation (EU) 2025/2392, and reporting-platform mechanics are ENISA-published material marked subject to change. Sources are Regulation (EU) 2024/2847 (CELEX 32024R2847; Annex III/IV item texts read verbatim from EUR-Lex) and our audited kit research. © 2026 Kilde.

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