Which of the essential requirements described in Annex I, if any, are in scope for the 'light-touch and tailor-made regulatory regime' of stewards?

None. The essential cybersecurity requirements set out in Annex I do not apply to open-source software stewards under their light-touch regulatory regime.

Stewards are subject only to the specific obligations outlined in Article 24, which focus on facilitating secure development practices rather than meeting the product-level requirements that apply to manufacturers. As Recital 19 explains, the steward regime "should take account of their specific nature and compatibility with the type of obligations imposed" and recognises that stewards "should not be permitted to affix the CE marking" to the products they support—precisely because they are not required to demonstrate conformity with Annex I requirements.

However, stewards may choose to participate in voluntary security attestation programmes established under Article 25. These programmes allow assessment of conformity with "all or certain essential cybersecurity requirements or other obligations laid down in this Regulation." When stewards obtain such attestations, it can help lighten the due diligence burden for manufacturers who integrate the attested open source components into their own products.

For more on steward obligations generally, see What are the obligations of open-source software stewards ?.

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