Does the CRA apply to developer tools?
Likely yes
Likely yes when sold or monetised. A developer tool is installed software with a network connection, supplied in the course of a commercial activity [[F-005]] [[F-007]]. Non-monetised open-source tooling is not placed on the market [[F-009]].
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| Made available on the EU market | Scope questions continue | Likely out of scope | F-101 |
| Supplied in the course of a commercial activity | Scope questions continue | Likely out of scope (or the open-source light regime) | F-007 |
| Has a direct or indirect connection to a device or network | It is a product with digital elements | Likely out of scope | F-005 |
| Free and open-source, not monetised | Not placed on the market; the steward light regime may apply | Normal manufacturer scope | F-009 |
Check your own product
Start the short scope check with the product type pre-selected. Every legally material fact — EU availability, commercial activity, exclusions, your role — is asked, never assumed.
Example scenarios
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Paid IDE with team licences sold to EU companies
Likely in scope · role: _
Installed software sold commercially in the EU: a product with digital elements in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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Free CLI that only works against your paid cloud service
Likely in scope · role: _ · remote processing in scope
The CLI is an installed component supplied as part of a commercial service, and the service is essential to it, so both form one product in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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Open-source build tool, no paid tier, foundation-governed
Open-source light regime may apply · role: _
Not monetised free and open-source software is not considered placed on the market; the foundation may be an open-source software steward.
Deciding fact: Art. 3(14), Art. 3(48), Art. 24, Art. 64(10)(b), Recitals 18–19
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Open-core tool with a paid enterprise edition
Likely in scope · role: _
The enterprise edition is placed on the market commercially and is a product with digital elements.
Deciding fact: Art. 3(1), Art. 2(1)
Each scenario is a fixture: the shared CEMarque rules engine evaluates its inputs at build time and the page cannot be served if the outcome shown here differs from the engine's.
Edge cases
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Why
Tools are products too
The definition covers any software product with a direct or indirect connection to a device or network [1]. IDEs, CLIs, build systems and linters are installed software that fetch packages, check for updates and call services, so the connection element is met [1]. Supplied in the course of a commercial activity, they are in scope [2].
Commercial models in tooling
Charging a price, charging for support and monetising through a service are all commercial activity [2]. Free-for-individuals, paid-for-teams tools are commercial. Open-core tools are commercial through the paid edition [2]. Free and open-source tools that are not monetised are not placed on the market, and stewards who systematically support them fall under a lighter regime [3]. Monetising later changes that verdict and should trigger a re-check [4].
Clients of a cloud service
A CLI or agent that cannot perform a function without your own backend brings that remote data processing into the product with digital elements [5]. The installed tool and the service are then one product for the Regulation's purposes.
Internal tooling
A tool used only inside your organisation and never supplied to third parties is not made available on the market [6]. Supplying it to customers or partners changes that.
Timing
Article 14 reporting applies from 2026-09-11; full requirements and CE marking apply from 2027-12-11. Dates come from the Facts Table entries cited below, evaluated for the first example; run the check for your own product's dates.
What to do next
CRARequired only answers applicability. CEMarque carries your answers forward and adds your role, class, conformity route, dates, obligations, and a permanent cited verdict.
Check my product Run the full cited determination on CEMarque
Related applicability questions
Sources
- F-005 A product with digital elements is a software or hardware product and its remote data processing solutions, including components placed on the market separately, whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Art. 3(1), Art. 2(1) EUR-Lex ↩
- F-007 The Regulation applies to products made available on the market in the course of a commercial activity; charging a price, charging for support, monetising via advertising or data, or otherwise intending to monetise are commercial activity. Art. 2(1), Art. 3(22), Recitals EUR-Lex ↩
- F-009 Free and open-source software not monetised is not considered placed on the market. Open-source software stewards (legal persons that systematically support free and open-source software intended for commercial activities) have a light regime: a documented cybersecurity policy, cooperation with authorities, and Article 14 reporting only where they are involved in development or where an incident affects their own development infrastructure; they do not affix CE marking and are not subject to fines. Art. 3(14), Art. 3(48), Art. 24, Art. 64(10)(b), Recitals 18–19 EUR-Lex ↩
- F-102 Monetisation or commercial redistribution by you changes a non-commercial verdict; re-check when that happens. Recitals EUR-Lex ↩
- F-107 Where a product depends on your own remote data processing (a backend or API without which it cannot perform one of its functions), that remote processing is part of the product: it is covered by the essential requirements, the technical documentation and market surveillance alongside the client software or device. Art. 3(1)–(2), Annex I, Annex VII EUR-Lex ↩
- F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22) EUR-Lex ↩
CRARequired answers applicability only, using scope logic and cited regulatory facts maintained by CEMarque, which encodes Regulation (EU) 2024/2847 and published guidance as of Facts v2026.09.4 (10 September 2026). Results are "likely" or "conditional" readings of your answers, not a legal opinion and not a conformity assessment. Run the full cited determination on CEMarque before you act. Methodology.