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Who is an open-source software steward under the CRA?

Light regime

A lighter regime. Free and open-source software that is not monetised is not considered placed on the market, and legal persons who systematically provide support for its development, open-source software stewards, fall under a lighter, tailored regime rather than full manufacturer obligations [[F-009]].

The deciding factors

Factors the rules engine reads for this fact pattern, and what each outcome means.
FactorIf trueIf falseSource
A legal person systematically supports non-monetised open-source softwareOpen-source software steward light regimeNot a stewardF-009
You monetise the softwareManufacturer scope insteadSteward regime holdsF-007
Monetisation starts laterRe-check; verdict changesNo changeF-102
Has a direct or indirect connection to a device or networkIt is a product with digital elementsLikely out of scopeF-005

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Example scenarios

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

Why

The steward role

Free and open-source software that is not monetised is not considered placed on the market. Legal persons, other than manufacturers, that systematically provide support for the development of such software intended for commercial activities are open-source software stewards, and a lighter, tailored regime applies to them rather than the manufacturer's obligations [1]. The regime is a documented cybersecurity policy, cooperation with authorities, and Article 14 reporting only where the steward is involved in development or an incident affects its own development infrastructure; stewards do not affix CE marking and are not subject to fines [1].

Steward or manufacturer

Charging a price, charging for support or monetising the software otherwise is a commercial activity, and a body doing so for the software it supplies is a manufacturer in the ordinary way [2] [3]. A company can steward one project and manufacture another; the check is per product.

When it changes

Monetisation or commercial redistribution by you changes a non-commercial verdict, and the check should be re-run when it happens [4]. An enterprise tier, paid hosting or paid support are the usual triggers.

Individuals

The steward definition speaks of legal persons [1]. An individual maintainer of non-monetised software is outside scope because the software is not placed on the market, not because of the steward regime [1].

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.

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Related applicability questions

Sources

  1. 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 ↩
  2. 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 ↩
  3. F-011 Manufacturer: a natural or legal person who develops or manufactures products with digital elements or has them designed, developed or manufactured, and markets them under their name or trademark, whether for payment, monetisation or free of charge. Art. 3(13) EUR-Lex ↩
  4. F-102 Monetisation or commercial redistribution by you changes a non-commercial verdict; re-check when that happens. Recitals EUR-Lex ↩
  5. 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 ↩

Facts v2026.09.4 · rules v2026.09.1 · page RP-204 v1 · last verified 25 September 2026 · reviewed by Claude (delegated by Ron) on 8 October 2026 · content 1bea23ad72f66d47

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.