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Making Your Software's DoC Accessible: Permalinks & Websites

So you've decided to use a simplified EU Declaration of Conformity (DoC) for your app or game, as allowed by Article 13, Paragraph 20, of the Cyber Resilience Act (CRA). This means you need to provide an "exact internet address" where the full DoC can be found. Making this work smoothly is key.

The Importance of the "Exact Internet Address"​

This isn't just any link. It needs to be:

  • Direct: The link should take users or authorities straight to the full DoC, ideally a PDF or a dedicated, stable webpage. Don't make them hunt through your entire website.
  • Stable (Permalink): This URL should be a permalink – a permanent, unchanging address. If this link breaks, your simplified DoC becomes non-compliant because the full information is no longer accessible.
  • Easily Accessible: Article 30, Paragraph 1, notes that for software, if the CE marking (which is linked to the DoC) is on a website, that section must be "easily and directly accessible to consumers". The same logic applies to accessing the DoC itself.

Best Practices for Software Developers​

  1. Dedicated Compliance Section: Consider creating a specific "Compliance," "Legal," or "Regulatory Information" section on your official product website or company website.
  2. Host as PDF: Hosting the full, signed DoC as a PDF is a common and good practice. It preserves the signature and formatting.
  3. Versioning: If your DoC needs updates (e.g., for new software versions or changes in standards), ensure your linking strategy accounts for this. You might link to a page that then lists DoCs by version, or have version-specific permalinks. Ensure the simplified DoC provided with a specific software version links to the correct full DoC for that version.
  4. Test Your Links: Regularly check that the URLs provided in your simplified DoCs are still working and pointing to the correct documents.

Accessibility isn't just about having the document; it's about ensuring the intended audience can actually find and retrieve it without a fuss.

Key Takeway​

If using a simplified DoC for your software, ensure the internet address for the full DoC is direct, stable (a permalink), and easily accessible on your website. This is crucial for meeting CRA transparency requirements.