By Madalin Neag, EU Policy Advisor, OpenSSF
Introduction
The software supply chain has reached a level of complexity where manual oversight is no longer a viable strategy for security or regulatory compliance. Modern systems depend on vast, rapidly evolving networks of components, making manual, paper-based approaches to due diligence impractical. Machine-readable, continuously generated security signals are therefore the only realistic way to support Cyber Resilience Act (CRA) due diligence at scale. These signals already exist across open source ecosystems as a natural byproduct of standard development practices, though they remain fragmented across tools, repositories, and pipelines. Crucially, these signals are best understood as mechanisms for transparency rather than assurance: they expose observable characteristics of software development and operational behavior without constituting guarantees, certifications, or transfers of liability.
This shift is driven by a need for technical accuracy. Static documentation and point-in-time attestations cannot reflect continuously evolving software systems. This limitation has been underscored by recent U.S. enforcement actions, such as Department of Justice settlements involving inaccurate cybersecurity compliance certifications, which highlight how formal attestations can later be treated as misleading when they diverge from actual system behavior, significantly increasing legal exposure.
