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ARTICLE · 14 SEPTEMBER 2026

The EU Cyber Resilience Act: Reporting Obligations Take Effect

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The EU Cyber Resilience Act introduces mandatory vulnerability and incident reporting obligations for products with digital elements starting September 2026. Economic operators developing, importing, or distributing such products in the EU face strict compliance deadlines, substantial penalties for non-compliance, and must implement security-by-design principles throughout product lifecycles.

European UnionMedia, Telecoms, IT, Entertainment
Davinia Brennan
Davinia Brennan
Marie McGinley
Marie McGinley
Sarah Jayne Hanna
Sarah Jayne Hanna
Stephanie McCarthy
Stephanie McCarthy
Stephanie Ryan
Stephanie Ryan
Marie Lynch
Marie Lynch
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The mandatory reporting obligations under the Cyber Resilience Act (Regulation (EU) 2024/2847) (the “CRA“) are due to take effect on 11 September 2026. Accordingly, entities developing, importing or distributing products with digital elements (“PDEs“) in the EU have a narrow window left to ensure their vulnerability and incident reporting processes are ready for compliance with these new obligations.

The CRA complements the NIS 2 Directive by introducing mandatory cybersecurity requirements for PDEs to provide a more comprehensive security framework in the EU. It shifts product security to a proactive obligatory framework, requiring security by default and design as well as product security lifecycle obligations. By making cybersecurity an essential component of product safety, the CRA forces businesses to view cybersecurity as a gateway requirement for a product’s entry into the EU market.

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