The most important quality of a cybersecurity requirement is that it should ideally be objectively testable on an instance of the product. If it can't be tested on the product itself, it is a documentation requirement, in which the manufacturer documents the steps they took to implement the requirement (such as configuration files or written policies used by employees).
The CRA requires the manufacturer to keep all the documentation necessary to show that the tests were conducted. In addition, the CRA explicitly grants the MSA the following rights in Article 13 Rec. 22:
> \"Manufacturers shall, upon a reasoned request from a market surveillance authority, provide that authority, in a language which can be easily understood by that authority, with all the information and documentation, in paper or electronic form, necessary to demonstrate the conformity of the product with digital elements and of the processes put in place by the manufacturer with the essential cybersecurity requirements set out in Annex I. Manufacturers shall cooperate with that authority, at its request, on any measures taken to eliminate the cybersecurity risks posed by the product with digital elements which they have placed on the market.\"
The goal is that when the MSA does a "sweep" or otherwise decides to verify a product's conformance with the CRA, it has enough information that it can do its own independent testing without unnecessary barriers that could be solved by vendor documentation (e.g., does not have to reverse-engineer how to attach a serial console and read logs).
> [!note]
> It is easer for an MSA to evaluate conformance via transparency—reviewing the test output and documentation to evaluate whether a mitigation is implemented—over actually testing the product themselves.
The present document makes the following assumptions regarding requirements and enforcement:
* Manufacturers are already required to provide the ability to enable testing and collect output on the product as placed on the market, and will supply instructions for enabling and collecting test data.
