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EU's Cyber Resilience Act starts the 24-hour vulnerability clock
EU Cyber Resilience Act reporting rules take effect, requiring manufacturers to disclose actively exploited vulnerabilities to ENISA within 24 hours, with fines reaching €15 million.
The Cyber Resilience Act's Article 14 mandatory reporting duties became applicable, requiring makers of products with digital elements sold in the EU — regardless of where they are based — to file an early warning within 24 hours of becoming aware of an actively exploited vulnerability, a detailed notification within 72 hours, and a final report within 14 days of releasing a fix. Reports must be submitted through ENISA's Single Reporting Platform to the designated CSIRT, and non-compliance with these core duties can trigger fines up to €15 million or 2.5 percent of annual turnover. Manufacturers must also inform affected users of available fixes without undue delay, and most remaining CRA provisions, including mandatory SBOMs and security-by-design requirements, become applicable on December 11, 2027.
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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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