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ARTICLE · 25 SEPTEMBER 2026

Ready, respond, report: the Cyber Resilience Act’s reporting regime is here

CMS Wistrand
CMS Wistrand
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CMS Wistrand

CMS Wistrand

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The EU's Cyber Resilience Act introduces mandatory vulnerability and incident reporting obligations for manufacturers of digital products starting 11 September 2026, well before the broader regulatory framework takes effect. Manufacturers must navigate tight reporting deadlines, determine when they become "aware" of security events, and establish governance structures to comply with 24-hour early warnings and subsequent detailed notifications through a platform that is not yet operational.

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The reporting obligations included in Regulation (EU) 2024/2847 on horizontal cybersecurity requirements for products with digital elements (the Cyber Resilience Act or CRA), enter into application on 11 September 2026 with the broader CRA framework entering into application on 11 December 2027.

The CRA is an EU regulation that establishes mandatory cybersecurity requirements for certain products with digital elements placed on the EU market. These reporting obligations apply to certain vulnerabilities and incidents affecting product security.

CRA reporting regime applies from Friday, 11 September

As of 11 September 2026, the CRA’s vulnerability and incident reporting regime applies to manufacturers of relevant products with digital elements placed on the EU market, including relevant products that were already placed on the EU market before that date.

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