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SaaS Is Not a blanket exemption: Remote Data Processing, SBOMs, and the CRA

11.03.2026

Dr. Andreas Kotulla

SaaS

Software companies often rely on a familiar distinction: they regulate products, but not services. They have viewed cloud delivery models, subscription-based offerings, and remote processing as business innovations. They have also seen them as ways to reduce regulatory exposure. The EU Cyber Resilience Act (CRA) challenges this assumption. Under the CRA, the key question is not whether a company markets

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    • Open Source Management
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