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CRA Art. 14 · Reporting obligations from 11 September 2026

24 hours. 27 member states. One report.

From 11 September 2026, manufacturers must report actively exploited vulnerabilities and severe incidents EU-wide — early warning within 24 hours, via ENISA's new Single Reporting Platform (SRP). We get you ready to report before the clock starts for the first time.

11 Sep 2026Reporting obligations start (Art. 14 CRA)
24 hEarly warning after awareness
72 hFull notification
€15 mFine ceiling — or 2.5% of global turnover

What gets real on 11 September 2026

The Cyber Resilience Act does not apply in full until December 2027 — but the reporting obligations under Article 14 start 15 months earlier. From 11 September 2026, manufacturers of products with digital elements must report two types of events: actively exploited vulnerabilities in their products and severe incidents having an impact on product security. The obligation is product-based — it also covers products that have been on the market for years. There is no grandfathering for reporting.

Reports are submitted via the Single Reporting Platform (SRP): a central reporting platform operated by ENISA that automatically forwards each notification to your coordinating national CSIRT, to the CSIRTs of all member states where the product is made available, and to ENISA itself — report once instead of up to 27 times. The platform goes live on 11 September 2026; ENISA published the accompanying documents (factsheet, FAQ and user guides) on 31 July 2026.

The reporting clock: three stages, hard deadlines

All deadlines run from awareness (“becoming aware”) — not from remediation. Weekends count.

24 hEarly warning

Within 24 hours of becoming aware: a brief notification to the coordinating CSIRT and ENISA — so that warnings reach others before the exploitation wave rolls.

72 hFull notification

Within 72 hours: general information and an initial assessment — severity, impact and, where already available, corrective or mitigating measures taken.

14 d / 1 moFinal report

For vulnerabilities no later than 14 days after a corrective measure is available; for incidents one month after the 72-hour notification: root causes, timeline and countermeasures.

What must be reported — and where it goes

Two reportable events, one reporting channel: ENISA's Single Reporting Platform.

01

Actively exploited vulnerability (Art. 3(42))

There is reliable evidence that an attacker has exploited a vulnerability in your product — regardless of whether the attempt was successful. Evidence can come from your own telemetry, reports from CSIRTs, customers or security researchers, or entries in exploit catalogues.

02

Severe incident (Art. 3(44), Art. 14(5))

An incident is severe if it affects — or is capable of affecting — the product's ability to protect sensitive or important data and functions, or if it has led or could lead to the introduction or execution of malicious code. Potential is enough: compromised build servers and update channels are the textbook case.

03

Report once — everyone is informed

The SRP routes your notification to the CSIRT designated as coordinator, makes it simultaneously available to ENISA and disseminates it without delay to the CSIRTs of all member states where the product is available. Market surveillance authorities receive selected information for their oversight.

04

Confidentiality & delayed dissemination

The platform is designed for confidentiality. Dissemination can only be delayed in justified exceptional cases — for instance when a patch is imminent — and at the CSIRT's discretion (Art. 16(2) CRA, Delegated Regulation (EU) 2026/881). There is no opt-out for manufacturers.

The SRP in practice: what manufacturers need to know now

The platform itself is deliberately lean — the real preparation happens on your side.

Access via EU Login

Access to the SRP requires an EU Login account. Set up accounts for at least two people and define deputies — real incidents don't respect holiday schedules.

Validation doesn't block

After first access, your CSIRT validates the designated representatives — according to the ENISA FAQ, in parallel with the reporting process. Submitting a report is not held up by it.

No API at launch

According to the ENISA FAQ, the SRP will not provide an API at this stage: every report is entered manually in the web form — in three stages with common fields plus vulnerability- or incident-specific fields. Prepared text modules and a field mapping are your speed lever.

Informing users (Art. 14(8))

After an incident or an exploited vulnerability, you must also inform impacted users without undue delay — including risk information and remedies. If you fail to do so, the CSIRT can inform your users itself.

ENISA plans a testing phase before go-live and an onboarding webinar around two weeks before the platform enters service. Use both — with prepared reporting packages, 11 September becomes just another working day.

Sources: ENISA “CRA Single Reporting Platform Factsheet” v1.0 and SRP FAQ (as of 31 Jul 2026); European Commission guidance C(2026) 5252 of 27 Jul 2026.

“We already report under NIS2” — not enough

CRA and NIS2 report different things to different bodies. One event can trigger several obligations at once.

CRA: product-based

The manufacturer reports actively exploited vulnerabilities and severe incidents affecting the product — via the SRP to the CSIRT and ENISA, on a 24 h / 72 h / 14 days or 1 month cadence.

NIS2: entity-based

Operators of essential and important entities report significant incidents affecting their organisation via national channels (in Germany: BSI) — on a 24 h / 72 h / 1 month cadence.

One incident, several obligations

Ransomware at a software vendor with an affected update server can trigger CRA, NIS2 and GDPR notifications at once — plus DORA in the financial sector. The SRP only takes the CRA report off your hands: build a reporting map with one shared process.

Your roadmap to 11 September

Six steps that make the 24-hour deadline reliably achievable.

01

Clarify scope

Build a product inventory and assess CRA applicability per product — include legacy products, because the reporting obligation has no grandfathering.

02

Prepare CSIRT & access

Derive your competent CSIRT from your main establishment (Art. 14(7)), create EU Login accounts for at least two people and define deputy rules.

03

Define awareness triggers

Specify internally when “awareness” exists, who determines it and how the timestamp is documented — it anchors every deadline. Arrange weekend availability.

04

Build reporting packages

Map the SRP form fields to internal data sources, prepare text modules for the 24-hour and 72-hour notifications and obtain approvals in advance — no committee loops in an emergency.

05

Rehearse

Run a tabletop exercise against the clock with a realistic scenario — including user communication under Art. 14(8) and the inconvenient Friday-evening case.

06

Connect the supply chain

Set up component monitoring (e.g. the EU vulnerability database EUVD, CISA KEV), keep your SBOM current and contractually secure your suppliers' duty to inform you.

Frequently asked questions on CRA reporting

Concise answers — we cover your specific products in an initial consultation.

Does the reporting obligation also cover products placed on the market before 2026?

Yes. From 11 September 2026, the Article 14 obligation applies product-based — including products already on the market. The remaining CRA obligations, such as CE marking, apply from 11 December 2027.

When does the 24-hour deadline start?

Upon awareness (“becoming aware”): as soon as your company learns of the active exploitation or the severe incident. Not upon remediation, and not after internal sign-off — which is why awareness triggers and the reporting process must be defined and documented in advance.

What exactly does “actively exploited” mean?

There is reliable evidence that an attacker exploited the vulnerability without the system owner's consent, or attempted to — whether the attack succeeded is irrelevant (Art. 3(42) CRA). A credible external report, for instance from a CSIRT or a customer, can start the clock.

Do I have to report if no damage has occurred yet?

For severe incidents, potential is enough: even if the incident is merely capable of affecting the product's ability to protect data and functions, or could enable execution of malicious code, it is reportable (Art. 14(5)). When in doubt: report — a notification is not an admission of fault.

Is there an API for automated reporting?

Not at launch. According to the ENISA FAQ, the SRP will initially operate without an API — reports are entered manually in the web form. That makes prepared text modules, a field mapping to your internal data and rehearsed procedures all the more important.

Which CSIRT is competent for us?

In principle, the CSIRT of the member state of your main establishment — where the essential cybersecurity decisions for your products are taken (Art. 14(7)). Without an EU establishment, the cascade runs via authorised representative, importer and distributor. In Germany, the BSI is the central point of contact; ENISA publishes the official CSIRT list.

What are the penalties for violating the reporting obligation?

Fines of up to €15 million or 2.5% of worldwide annual turnover — whichever is higher — plus market surveillance measures up to and including recalls. And if you fail to inform impacted users yourself, the CSIRT can do it for you — without your tone of voice.

How VamiSec gets you ready to report

From readiness check to a rehearsed 24-hour notification — pragmatic, product-focused, audit-proof.

CRA readiness check

Product portfolio, applicability and gaps assessed compactly: scope, reporting capability and vulnerability management — with a prioritised action plan up to 11 September.

Reporting process & SRP onboarding

Define awareness triggers, roles and escalation paths, prepare EU Login access and CSIRT assignment, create field mappings and text modules for 24-hour and 72-hour notifications.

PSIRT & vulnerability management

Build or sharpen your product security incident response team: CVD policy, vulnerability contact point, SBOM maintenance and exploit monitoring as a reliable source of awareness.

Tabletop & dry run

We rehearse the real case against the clock — including the 72-hour assessment, the final report and user communication under Art. 14(8). Afterwards, every role knows its part.

Incident response & forensics

When it happens: support with assessment, containment and on-time reporting — technical and regulatory from one team.

Full CRA programme to 2027

Reporting obligations today, Annex I requirements and conformity assessment tomorrow: we accompany you all the way to CE marking — as a project or as GRC as a Service.

Ready to report in weeks — not months

In a no-obligation initial consultation we clarify where your portfolio stands, which gaps put the 24-hour deadline at risk and what your roadmap to 11 September looks like.