The first part of the EU Cyber Resiliency Act comes into effect on September 11th. Are you Ready?

From September 11, 2026, the EU Cyber Resilience Act’s Article 14 requires manufacturers of covered products with digital elements to report actively exploited vulnerabilities and severe security incidents through ENISA’s Single Reporting Platform, with an early warning due within 24 hours, a notification within 72 hours, and subsequent final reports on defined timelines. The obligation generally covers locally executed software such as installed applications, browser extensions, and Electron apps, while browser-only web apps are generally outside this scope, although related local clients and supporting remote services may be covered. Reports are confidential to ENISA and relevant national CSIRTs, but manufacturers must also directly inform affected customers where appropriate, while broader advisories may serve other users. Penalties for reporting failures can reach €15 million or 2.5% of global turnover, alongside possible sales prohibitions, withdrawals, or recalls, though small firms have limited exemptions and open-source stewards are exempt from administrative fines. Reporting deadlines begin when a manufacturer can reasonably confirm exploitation or a severe incident after a prompt initial assessment, making documented intake, triage, verification, and around-the-clock response processes important. Exploitability must be assessed in the manufacturer’s specific product rather than inferred solely from a third-party CVE, increasing the importance of accurate software inventories, SBOMs, dependency and container reachability analysis, and clear processes ahead of broader CRA conformity, documentation, and vulnerability-handling requirements taking effect in December 2027.

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