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ARTICLE · 29 SEPTEMBER 2026

The EU Cyber Resilience Act's Vulnerability And Incident Reporting Requirements Are Now Live

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The EU Cyber Resilience Act introduces mandatory vulnerability and incident reporting requirements for manufacturers of products with digital elements, effective September 2026. With tight 24-hour deadlines for initial reports and penalties reaching €15 million or 2.5% of global turnover, manufacturers must establish robust incident response procedures immediately.

United KingdomTechnology
Louisa Chambers
Louisa Chambers
James Longster
James Longster
Helen Reddish
Helen Reddish
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Mandatory vulnerability and incident reporting requirements under the Cyber Resilience Act (CRA) apply from 11 September 2026. Manufacturers placing products with digital elements on the EU market, ranging from smartphones to industrial IoT, must now comply with these obligations, including in respect of products already on the market. 

1 Background: what is the CRA?

The reporting obligations arrive more than fifteen months ahead of the CRA's full application date of 11 December 2027. The CRA makes cybersecurity a condition of market access for products with digital elements ("PDEs") in the EU. It will require security-by-design and security-by-default, ongoing vulnerability management for at least five years (or the product's expected lifespan if shorter), and a cybersecurity risk assessment maintained throughout the support period. It also requires conformity assessment, CE marking, and the retention of technical documentation for at least ten years.

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