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The EU CRA's Real Question: What Shipped, and When Did You Know?
ActiveState argues the EU CRA's 24-hour ENISA exploit-notification duty, effective September 11, 2026, makes current SBOMs and provenance visibility a legal necessity.
An ActiveState essay warns that the EU Cyber Resilience Act's reporting obligations take effect on September 11, 2026, requiring manufacturers of products with digital elements sold into the EU to notify ENISA within 24 hours of learning a vulnerability is actively exploited, with a fuller report within 72 hours. The law's engineering requirements only apply from December 11, 2027, leaving a visibility-first runway, and Article 13 requires the SBOM to stay current unlike one-time artifacts generated under US Executive Order 14028. The author contrasts the 24-hour notification clock with an industry-average 55 days to remediate high or critical vulnerabilities and recommends automated SBOM regeneration or consuming pre-vetted, attested open source components.
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CMMC Hit Pause, the FAR Council Hit Play
DoD paused CMMC Phase 2 pending a 60-day review while a proposed FAR Council rule would extend NIST 800-171 Rev 3 to all federal contractors.
The Department of Defense suspended CMMC Phase 2 third-party certification requirements, but Phase 1 self-assessments under DFARS 252.204-7021 remain in force since November 2025, and prime contractors are still directing suppliers to proceed. A CMMC Reform Task Force must report recommendations to the DoD CIO within 60 days, likely by September or October 2026. Separately, the FAR Council's proposed CUI rule from June 23 would apply NIST 800-171 Revision 3, 72-hour incident reporting, and flowdown obligations to all FAR-based federal contracts, not just the defense industrial base. False Claims Act exposure grows as DIBCAC assessment teams now cooperate directly with the DOJ.
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