RED Cybersicherheits-Compliance: Schlüsselanforderungen & Zeitplan

The Radio Equipment Directive (RED) 2014/53/EU sets essential safety and performance requirements for radio devices in the EU. Since 2022, it also includes specific cybersecurity obligations. In particular, a Delegated Regulation (EU 2022/30, amended by EU 2023/2444) has activated Articles 3(3)(d), (e) and (f) of the RED. These require that radio equipment (d) must not harm networks, (e) must protect personal data and privacy, and (f) must prevent fraud. In practice, this means manufacturers of Wi‑Fi, Bluetooth, cellular or other radio-equipped products must build in security measures to resist hacking, secure user data, and guard against fake or malicious use. The bottom line: cybersecurity is now a "must-have" for any connected radio device in the EU, not just a best practice.

From Safety to Security

Originally focused on radio performance and EMC, the RED has been supplemented by cybersecurity rules. The new Delegated Act (EU 2022/30) explicitly applies Articles 3(3)(d), (e), (f) to certain devices. In plain terms, if your product is a radio-enabled device, it must be designed to (1) protect the network (no Denial‑of‑Service or resource-hogging behavior), (2) secure data and privacy (no unauthorized access or leaks), and (3) prevent fraud (for example by ensuring software authenticity and integrity). Together these cover the confidentiality, integrity and availability (CIA) of data in transit or at rest, and the safe operation of the device on the network.

By adopting these rules, the EU ensures that "radio equipment is designed and manufactured in such a way that it can resist cyber threats". Put another way, manufacturers must assess and mitigate risks like hacking, malware injection, eavesdropping or man‑in‑the‑middle attacks on radio networks. For example, wireless routers, smart meters, drones, wearables and sensors all need built-in firewalls, authentication, encryption and secure update mechanisms. Protecting personal data (passwords, location, health metrics, etc.) is emphasized: any device that "processes personal data or traffic data" falls under 3(3)(e).

In summary, manufacturers now have explicit cybersecurity duties under RED. Compliance isn't optional: failure to design for network protection, data privacy, and fraud prevention can violate EU law. Notably, these requirements parallel international standards (like ETSI EN 303 645 for consumer IoT and IEC 62443 for industrial IoT). Meeting them means incorporating secure-by-design principles from the outset.

The RED cybersecurity rules apply to a broad range of connected radio equipment. In practice, any device that uses wireless communication (radio, Bluetooth, Wi‑Fi, cellular, etc.) and is able to connect (directly or indirectly) to the internet is in scope. Typical covered products include:

Manufacturers should map their products against these categories. If your device can process personal or financial information over a radio network, the privacy/fraud requirements kick in. Note there are a few exceptions (e.g. equipment already covered by other EU cybersecurity regimes), but in general most wireless, internet‑connected products must comply.

Non-compliance carries serious risks. Because these cybersecurity clauses are essential requirements of the RED, products failing them cannot receive a valid CE marking. National market surveillance authorities can block imports, recall devices or ban sales of non-compliant products. Fines or legal penalties may be imposed, and your company's reputation can suffer if devices are found insecure. In short: ignoring RED cybersecurity is a business risk.

For example, the RED explicitly allows EU regulators to take action "in case radio equipment fails to fulfill the essential requirements" (Article 3(3)). In practice, this means any cyber‑vulnerability or data breach traced to a device can trigger investigations and sanctions. Even before Aug 2025, preparing early is crucial, otherwise you risk costly redesigns, launch delays, or losing market access entirely.

The EU has given manufacturers time to adapt, but the clock is ticking. The Delegated Regulation was adopted in late 2021 and published in early 2022. Initially the new rules were to become mandatory on 1 August 2024, but in 2023 the Commission extended the transition by one year. Now the compliance deadline is 1 August 2025. In other words, any eligible product placed on the EU market after that date must meet all RED cybersecurity requirements.

Looking ahead, after Aug 2025 devices will be subject to normal market surveillance checks under RED (including checks of cybersecurity provisions). Beyond RED, the upcoming EU Cyber Resilience Act may eventually overlap by imposing security rules on digital products, but until it takes full effect, RED is the prevailing law for radio devices.

Use the following checklist to gauge your readiness for RED cybersecurity compliance. Each item corresponds to key obligations in Articles 3(3)(d)-(f):

• Check Scope: Does your product use radio (RF, Wi-Fi, Bluetooth, NFC, cellular, etc.) and connect to the internet (directly or via a hub/gateway)? Does it handle personal or financial data? If yes, RED cyber rules almost certainly apply.
• Risk Assessment: Identify potential threats and vulnerabilities. Consider how an attacker could use the device to harm networks, access data or commit fraud. Classify risks (network attacks, data breaches, spoofing) and estimate their severity. Document this security risk analysis.
• Network Protection: Ensure the device won't "degrade service." Implement firewalls, rate‑limiting, secure boot, up‑to‑date firmware and intrusion detection.
• Data & Privacy Safeguards: Encrypt sensitive data in transit and at rest. Enforce strong authentication and least‑privilege access. Collect only necessary data and anonymize personal data when possible.
• Anti-fraud Measures: Incorporate secure firmware updates (signed code), hardware roots-of-trust or cryptographic chips to prevent software tampering and counterfeiting.
• Standards Compliance: Align with recognized cybersecurity standards such as ETSI EN 303 645, IEC 62443 or the upcoming EN 18031-1/2/3. Perform a self-audit or third-party evaluation.
• Documentation: Prepare a technical file covering your security measures and risk assessment. Include test reports or self-assessment results. Update your EU Declaration of Conformity to note compliance with Articles 3(3)(d)-(f) of RED.
• Maintenance Plan: Have a process to provide security updates and handle vulnerabilities post-launch.

Navigating RED cybersecurity obligations can be complex. Red Comply's AI-driven platform is purpose-built to simplify and accelerate every step of the process:

• Interactive Guidance: An in-app AI coach interprets EN 18031 clauses in real time, explains what evidence is needed, and suggests best-practice controls, no external consultants required.
• Smart Templates & Checklists: Pre-built, clause-by-clause worksheets auto-populate with your product data, turning hours of manual mapping into minutes.
• Risk-Assessment Engine: Upload architecture diagrams or firmware binaries; the platform auto-generates a threat model and risk registry you can fine-tune with a few clicks.
• One-Click Documentation: Instantly export EU-compliant risk reports and Declarations of Conformity (DoCs) ready for CE marking, all stored in a single dashboard for easy version control.
• Continuous Compliance Monitor: Git-integrated tracking flags security impacts of firmware or hardware changes, keeping every release audit-ready without human chasing.

By automating the heavy lifting, Red Comply slashes compliance time and cost, letting your team focus on innovation, not paperwork.

The EU's new RED cybersecurity requirements represent a major shift for wireless product manufacturers. By August 2025, all relevant radio devices must meet strict network, data and anti-fraud safeguards. This means conducting thorough risk assessments, adopting international security standards, and preparing robust technical documentation. The key takeaway is to start now: audit your product portfolio, plug any security gaps, and align with EN 303 645/EN 18031 compliance steps.

Facing these changes alone can be daunting, but you don't have to. Red Comply's team specializes in EU product compliance and can guide you through each step of the RED cybersecurity process. Visit redcomply.com or contact us today to learn how we can help your company meet the RED requirements with less headache and more confidence.