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ARTICLE · 16 OCTOBER 2026

Countdown To Compliance: The Cyber Resilience Act Reporting Deadline Has Arrived

Arthur Cox
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The EU's Cyber Resilience Act establishes comprehensive cybersecurity obligations for manufacturers, importers, and distributors of products with digital elements. With reporting requirements now in effect and full compliance required by December 2027, economic operators must navigate conformity assessments, incident reporting protocols, and enforcement mechanisms that include substantial penalties for non-compliance.

IrelandMedia, Telecoms, IT, Entertainment
Colin Rooney
Colin Rooney
Olivia Mullooly
Olivia Mullooly
Ian Duffy
Ian Duffy
Vivian Spies
Vivian Spies
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In 2022, we published a briefing considering the European Commission’s proposed Regulation (EU) 2024/2847, or the Cyber Resilience Act (CRA). Since then, the CRA has come into force with reporting obligations applying since 11 September 2026 and the full regime taking effect on 11 December 2027.

The CRA imposes cybersecurity obligations on manufacturers of “products with digital elements”, which is broadly defined to cover any software or hardware product and its remote data processing solutions, including software or hardware components placed separately on the EU market. This briefing outlines the key elements of the new regime.

Economic operators & their obligations

Manufacturers

A manufacturer is anyone who develops or manufactures a product with digital elements or has a product with digital elements designed, developed or manufactured, and markets them under their own name or trademark whether sold, monetised, or provided free of charge. 

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