Open-source software steward

The deliberately lighter role for foundations and similar open-source stewards.

An open-source software steward is a legal person, other than a manufacturer, that systematically and on a sustained basis supports the development of specific free and open-source products intended for commercial activities, and ensures their viability — for example certain foundations, or entities that develop and publish free and open-source software in a business context, including not-for-profits F-009.

A distinct, lighter regime

Article 24 gives stewards their own regime rather than the manufacturer's: the Regulation treats stewardship of non-monetised open source differently from placing a product on the market F-009. Free and open-source software that is not monetised is not considered placed on the market at all F-009.

The line that matters

The steward role sits on the non-monetised side of the line. Charging for the software or for support, or otherwise monetising it, is commercial activity and moves the picture toward the manufacturer role F-007. Projects sitting near that line should trace it deliberately, not discover it in an audit.

Verified facts this page relies on

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
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

Facts are maintained and human-verified in the CEMarque Facts Table (v2026.09.4, verified 2026-09-10).

Editorial review: Claude (AI reviewer, delegated by the editor), 2026-10-08. Methodology and correction process: how this site works.

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