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CRA Vulnerability Reporting: Step-by-Step Guide

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CRA Vulnerability Reporting: Step-by-Step Guide

CRA Article 14 reporting is already applicable as of 11 September 2026. It is separate from the main product-conformity requirements due on 11 December 2027. Manufacturers of products within the CRA’s scope need a process that works when an event is discovered, not only when a patch is ready.

Identify the reporting trigger

Report an actively exploited vulnerability contained in the product, or a severe incident affecting its security, under the definitions and conditions in Article 14. A new CVE, a scanner finding or a high CVSS score alone does not establish active exploitation. They still require triage and vulnerability handling.

Severe incidents have their own legal criteria; do not reduce them to any outage or any suspected attack. Record the available evidence, affected versions, impact and the time the organisation became aware. Do not wait for every technical detail to be confirmed before meeting the early-warning deadline.

The three-stage reporting timeline

EventEarly warningDetailed notificationFinal report
Actively exploited vulnerabilityWithin 24 hours of awarenessWithin 72 hours of awarenessNo later than 14 days after a corrective or mitigating measure becomes available
Severe security incidentWithin 24 hours of awarenessWithin 72 hours of awarenessWithin one month of the detailed notification

Both early deadlines start from awareness: the 72 hours do not start after the first 24-hour report. A mitigating measure can trigger the vulnerability final-report deadline; it is not limited to a firmware patch. Record submission receipts and follow the required contents for each stage. The Commission’s reporting guidance explains the platform and recipients.

Submit through the Single Reporting Platform

Use the CRA Single Reporting Platform (SRP). The notification goes to the coordinating CSIRT determined under the regulation and, subject to exceptional dissemination provisions, to ENISA. Choose the correct main establishment or applicable fallback criteria; a convenient office location does not necessarily determine the recipient.

Prepare access, authorised submitters, an alternate contact and an internal escalation route. Follow the current ENISA platform guidance rather than relying on a hard-coded national-email list. Store evidence securely and mark sensitive technical information appropriately.

Existing products and users

Article 69 makes Article 14 applicable also to products placed on the market before the main application date. Do not limit the inventory to new models or products still actively advertised. Map installed versions and the relevant scope and transition conditions.

Inform affected users as required by Article 14, including the vulnerability or incident and available corrective or mitigating actions. Coordinate disclosure and security updates with suppliers, CSIRTs and customers without confusing regulatory reporting with public disclosure of exploit details.

Build a repeatable response

  1. Maintain a product/version inventory and dependency information to identify affected releases.
  2. Assign a response owner and backup with authority to escalate and submit.
  3. Keep an incident record with awareness time, evidence and decision rationale.
  4. Prepare 24-hour and 72-hour templates and rehearse out-of-hours handling.
  5. Track mitigation availability, final-report deadlines and customer notifications.
  6. Test the fix, preserve release evidence and check for related affected products.

Penalties and overlapping obligations

Article 64 sets an upper tier of €15 million or 2.5% of worldwide annual turnover, whichever is higher, for infringements including Article 14. These are legal maxima, not automatic fines for every event. Microenterprises and small enterprises have the specific Article 64(10)(a) exemption from fines for missing the early-warning deadline; this does not remove the reporting duty or all other penalties.

NIS2 concerns covered entities and their incidents, while CRA concerns products and manufacturers. One event may need both processes if both scopes apply. A CRA submission is not automatically a substitute for NIS2 or personal-data-breach notification.

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Frequently asked questions

When did CRA Article 14 reporting start?

It has applied since 11 September 2026. The main product-conformity requirements have a different application date, 11 December 2027.

Do the 72 hours run after the early warning?

No. Both the 24-hour early warning and the 72-hour notification are measured from awareness of the relevant vulnerability or incident.

When is the final vulnerability report due?

No later than 14 days after a corrective or mitigating measure becomes available. For a severe incident, the final-report deadline is one month from the detailed notification.

Are old products excluded from reporting?

No. Article 69 extends Article 14 to products placed on the market before the main application date. Check the product scope and transition provisions, not only whether the model is still on sale.

Are small companies exempt from Article 14?

No. The specific exemption from fines for microenterprises and small enterprises missing the early-warning deadline does not abolish their reporting obligations.

Primary sources

Technical and regulatory references checked on 1 October 2026.

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