EU Alerts High-Risk Solar Equipment: Inverter Market Access Tightens Under CRA Rules

Key Updates and Risk Overview

Core Conclusion (Market-Wide Restrictions): The European Commission’s Smart Energy Expert Group (SEEG) has officially released the report *Recommendations on Addressing Cybersecurity Risks in Photovoltaic Power Generation*. For the first time, the scope of restrictions regarding components and software from "High-Risk Suppliers" has been significantly expanded from utility-scale power plants to cover the entire market spectrum, including Commercial & Industrial (C&I), residential, and even plug-in PV systems.

Regulatory Changes (CRA Class II Certification): It is proposed to upgrade PV inverters from the default low-risk category under the Cyber ​​Resilience Act (CRA) to "Class II Important Products." This entails completely eliminating manufacturer self-assessment and mandating independent third-party compliance assessment by a Notified Body.

Technical Red Lines (Strict Operational Controls): Three strict technical requirements are explicitly proposed: prohibiting manufacturers from directly triggering automatic cloud-based firmware updates; restricting outbound connections to servers recognized by the EU or equivalent jurisdictions; and completely disabling SSH services and network interfaces exposed to the public internet.

1. Why is the EU suddenly tightening cybersecurity restrictions on photovoltaics?

1.1 From 86 GW to 406 GW: Security concerns arising from high-penetration PV grid integration

According to SEEG reports, the EU's installed photovoltaic (PV) capacity has surged from 86 GW in 2015 to 406 GW in 2025. With the integration of high levels of renewable energy, PV inverters have evolved from simple power conversion devices into "distributed grid digital hubs" that interface directly with grid dispatching systems. Given the highly concentrated nature of the supply chain, potential threats involving inverters and their critical software have escalated into major risks affecting overall grid stability and national security.

1.2 7,942 exposed systems in the Netherlands: Empirical data reveals security vulnerabilities

A recent investigation by the Dutch security research firm Modat, in collaboration with the National Cyber ​​Security Centre (NCSC) of the Netherlands, has revealed severe vulnerabilities in existing networks: across 34 European countries, 7,942 network systems and SSH services associated with PV parks—which should not have been exposed—were found to be directly accessible via the public internet. This data indicates that a vast number of on-site devices and network interfaces lack basic physical and logical isolation, making them highly susceptible to malicious scanning and unauthorized access by external threat actors.

1.3 Geopolitics and precedents set by member states

Amid escalating geopolitical tensions, EU member states have taken the lead in tightening regulations. In November 2024, Lithuania enacted legislation prohibiting entities from countries deemed "high-risk" from remotely accessing PV, wind, and battery energy storage systems (BESS) with capacities exceeding 100 kW; meanwhile, the Czech National Cyber ​​and Information Security Agency (NUKIB) issued an official warning in September 2025 regarding potential security threats posed by small-scale PV inverters. These precedents set by individual member states have accelerated the development of a unified security framework at the EU level.

2. Deep Dive into Threat Models: Three High-Risk Scenarios Identified by the EU Expert Group

2.1 Concentrated Attacks on Vendor Cloud Platforms

In distributed photovoltaic systems, vast numbers of inverters rely on vendor cloud platforms for centralized monitoring and coordinated dispatch. Once attackers compromise and gain control of the cloud management dashboard, they can issue malicious commands to tens of thousands of connected devices, triggering a massive, synchronized disconnection from the grid or causing abnormal power fluctuations. This centralized attack surface allows risks to propagate instantly across a gigawatt-scale installed base, potentially sparking cross-regional, grid-level chain reactions.

2.2 "Tiered Operational Architectures" and Warnings Regarding Supplier Backdoors

The SEEG report highlights the structural risks inherent in "tiered operational architectures." Although front-end monitoring dashboards are hosted within the EU, critical elements—such as firmware signing, remote control logic, and software updates—remain under the control of entities based in third countries. The expert group emphasizes that, while no actual attacks involving hardware backdoors have been detected to date, the risk of such covert control mechanisms is extremely high—especially given the grid's 3,000 MW threshold for Frequency Containment Reserves (FCR)—necessitating rigorous protective measures.

2.3 Hijacking of Local Area Networks (LANs) at Utility-Scale Power Plants

For ground-mounted, utility-scale power plants, threats primarily stem from infiltration attacks targeting local control networks and SCADA systems. If hackers compromise SCADA or gateway devices via the LAN, they can not only tamper with inverter control parameters and cause physical equipment damage but also disrupt the plant's participation in electricity market operations and peak-shaving ancillary services, thereby directly undermining the commercial viability of major energy infrastructure and compromising regional power supply security.

3. Legislative Storm: How CSA2 and the CRA Reshape Inverter Market Access

3.1 The CRA (Cyber ​​Resilience Act) Paradigm Shift: From "Self-Declaration" to "Class II Mandatory Certification"

Under the current Cyber ​​Resilience Act (CRA) framework, PV inverters fall into the default low-risk category, allowing manufacturers to obtain the CE mark through self-assessment. The SEEG expert group has recommended upgrading them to "Class II Important Products." This means that for products placed on the market after December 11, 2027, manufacturers must undergo independent third-party compliance assessments by Notified Bodies to gain access to the EU market.

3.2 Dual Bans: CSA2 and the Industrial Accelerator Act

The proposed revision to the Cybersecurity Act (CSA2) aims to empower the European Commission to directly designate "High-Risk Suppliers," with restrictions extending to the entire inverter unit as well as its component and software suppliers. In conjunction with the Industrial Accelerator Act, suppliers designated as high-risk would be completely excluded from EU renewable energy auctions, public procurement bids, and government financial subsidies.

3.3 A Note on Supply Chain Balance

While proposing stringent restrictions, the report also offers an objective risk warning: the expert group explicitly notes that forcibly implementing a comprehensive ban without adequate alternative supply chains would severely impact construction costs and the pace of the green energy transition in the EU PV market. Therefore, the implementation of any restrictive measures must be grounded in a comprehensive and rigorous supply chain risk assessment.

4. Implementation Guidelines: Mandatory Technical Standards for European PV Projects

To effectively mitigate supply chain security risks, the report outlines specific, mandatory technical and engineering requirements tailored to different application scenarios:

Technical "Red Lines" for Utility-Scale Plants

Traffic Encryption and Authentication: All internet traffic for PV inverters must be 100% logged, encrypted, and subject to mutual authentication; unauthorized access from outside the local area network (LAN) is strictly prohibited.

Data Residency: Outbound connections are strictly restricted to authorized servers hosted within the EU or in jurisdictions with equivalent regulatory standards.

O&M Requirements for Distributed and C&I Systems

Control of OTA Updates: Automatic firmware updates triggered directly by the manufacturer are prohibited; instead, manual review and offline or authorized deployment by qualified O&M providers are mandatory.

Lowering Compliance Thresholds: It is recommended to lower the applicability threshold to 1 MW across the board for minimum security qualifications under the "Requirements for Generators" (RfG) code, as well as for compliance with the NIS2 Directive and the Network Code on Cybersecurity.

5. Compliance and Response Strategies for Companies Expanding Overseas

In anticipation of the EU's impending regulatory wave, companies exporting inverters and PV energy storage systems must adopt proactive compliance strategies:

5.1 Architectural Restructuring (Data Residency & Local Control)

Data Localization: Accelerate the full migration of cloud monitoring servers and data centers serving European customers to locations within the EU.

Access Localization: Host firmware signing authorization and remote control nodes with compliant local EU entities to eliminate potential compliance risks associated with cross-border remote operations.

5.2 Proactive Certification (Proactive Certification & Penetration Testing)

Standards Alignment: Align closely with the IEC 62443 industrial cybersecurity standard framework (specifically IEC 62443-4-1 regarding the secure development lifecycle and IEC 62443-4-2 regarding technical security requirements for components) and establish a comprehensive Software Bill of Materials (SBOM).

Third-Party Assessment: Engage accredited Notified Bodies early to conduct vulnerability scanning and third-party penetration testing, laying the groundwork for mandatory CRA Class II certification.

5.3 Software and OTA Management (Governance & Version Rollback)

Mechanism Restructuring: Adjust Over-the-Air (OTA) update strategies, shifting from "global forced pushes" to a model requiring "manual confirmation based on O&M authorization."

Secure Rollback: Implement rigorous encrypted firmware signature verification and "version rollback" mechanisms to ensure European O&M providers retain the initiative and control over on-site upgrades.

Cybersecurity has shifted from being a mere "optional add-on" to a "mandatory market access barrier" for photovoltaic and energy storage equipment entering the European market. In response to the increasingly stringent regulatory landscape, forward-looking companies—including PCEnerSys—have long since integrated cybersecurity and data compliance into the full-lifecycle R&D of their entire product portfolios. Within the reshaped European new energy supply chain, system security and compliance capabilities are emerging as core competencies that determine a company's ability to gain a foothold.