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When a manufacturer becomes aware that a vulnerability in a product with digital elements is being actively exploited—or that a severe incident is affecting product security—the Cyber Resilience Act (CRA) reporting clock starts. The first early warning is due without undue delay and no later than 24 hours after awareness. Prepare a record that can be assembled quickly, but do not wait for every detail before filing: ENISA says information requirements vary by report type and stage, and some fields are not required in the early warning.

When does the CRA reporting clock start?

Article 14 reporting is triggered when a manufacturer becomes aware of either an actively exploited vulnerability in a product with digital elements or a severe incident affecting the product’s security. These are separate reporting branches; the existence of a published vulnerability identifier by itself does not establish that a vulnerability is actively exploited.

ENISA defines an actively exploited vulnerability as one for which there is reliable evidence that a malicious actor has exploited it in a system without the system owner’s permission. A severe incident is a different report type and involves a severe impact on product security. Relevant security properties include availability, authenticity, integrity, and confidentiality. See the ENISA CRA Single Reporting Platform FAQ for the definitions.

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The reporting obligations for manufacturers apply from 11 September 2026. The European Commission says they cover products with digital elements made available in the EU, including products already on the market. A separate date applies to open-source software stewards: their reporting obligation under Article 24(3) begins on 11 December 2027. These dates relate to reporting requirements, not the start date for every CRA obligation. See the Commission’s CRA reporting page.

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Whether a particular product, entity, or event falls within the rules depends on its facts. The general reporting workflow cannot determine an individual organisation’s legal scope or the correct coordinator CSIRT without product and establishment details.

What are the deadlines—and what starts each one?

File without undue delay. The outer deadline and its starting point differ by stage, especially for the two final-report branches.

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Stage Trigger and deadline
Early warning Awareness of the reportable event; without undue delay and no later than 24 hours after awareness.
72-hour notification The same awareness point; without undue delay and no later than 72 hours after awareness.
Actively exploited vulnerability final report No later than 14 days after a corrective or mitigating measure becomes available.
Severe-incident final report Within one month after the 72-hour notification.

The vulnerability final-report clock is tied to the availability of a corrective or mitigating measure, not simply to initial awareness. The severe-incident final-report clock instead runs from the 72-hour notification. The Commission sets out the deadlines on its CRA reporting page.

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What information do I need to provide when submitting a notification through the SRP?

ENISA uses that question in its FAQ. The practical answer is to maintain a staged evidence packet: a record of facts that can be updated as the response develops, rather than a form that must be complete before the first warning. ENISA’s FAQ and CRA Single Reporting Platform glossary describe information fields that vary by report type and stage. Some fields are not required for the early warning.

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Keep the common facts ready

  • Product and scope: product name and identifiers, affected releases or versions, EU availability or distribution information, and the responsible manufacturer contact. These details help establish what is affected; they do not, by themselves, settle legal scope.
  • Awareness timeline: when and how the organisation first received a credible signal, validation steps, and the people involved in response decisions. Record timestamps and supporting records as an operational control so the deadlines can be calculated from awareness.
  • Response and updates: actions taken or underway, customer or coordination actions where relevant, and new facts for later notifications and the final report.
  • Submission record: report stage, submission time, selected coordinator CSIRT, and follow-up facts.

Keeping timestamps and source records is practical preparation for a staged process; it is not a claim that these are all statutory fields.

Add the actively exploited vulnerability facts

  • CVE and/or EUVD identifier, if available.
  • A description of the vulnerability and available evidence or general information about exploitation.
  • Severity and impact, plus known malicious actor and general exploit characteristics where applicable or available.
  • Applicable exceptional circumstances.
  • The corrective or mitigating measure and when it becomes available, since that date starts the vulnerability final-report deadline.

Add the severe-incident facts

  • Description of the incident and its impact on product security, including affected security properties where known.
  • Severity and mitigations already applied or underway.
  • The likely threat or a working root-cause account, updated as the investigation develops.

Treat these as preparation categories, not a checklist that must be fully populated before the 24-hour warning. Submit the information available at each stage and update the report as facts emerge.

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Where and how should a manufacturer submit?

Use ENISA’s CRA Single Reporting Platform (SRP) and select the appropriate CSIRT designated as coordinator. In general, that is the coordinator in the Member State where the manufacturer has its main establishment. ENISA specifies fallback rules for cases where the main establishment cannot be determined and where the manufacturer has no EU main establishment; consult its live FAQ for those cases.

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There is one SRP notification per relevant event. The coordinator receives it, it is generally made available to ENISA at the same time, and the coordinator shares it with other relevant CSIRTs. Justified cybersecurity-related grounds can exceptionally delay dissemination; that is not the routine route. The Commission describes the reporting route on its CRA reporting page.

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Organisations can integrate reporting preparation into internal workflows, but ENISA says the platform’s initial release has no API: submission must be made through the SRP interface. Internal automation can help assemble and track evidence, but it does not itself submit the notification. Because platform functionality and field requirements can change, check ENISA’s current FAQ and glossary when preparing a process or filing.

How to make the packet useful under deadline pressure

  1. Keep a standing product record. Maintain identifiers, affected-version tracking, EU availability information, and the responsible contact where response staff can find them.
  2. Start a timestamped event record as soon as a credible signal arrives. Capture the initial awareness time and source, then add validation and decision entries rather than overwriting the original timeline.
  3. Open the correct branch. Record whether the known facts concern reliable evidence of active exploitation, a severe incident affecting product security, or both. Do not treat every CVE as an automatically reportable actively exploited vulnerability.
  4. File with what is available. Meet the early-warning deadline without waiting for later-stage fields or a complete root-cause account.
  5. Track the next clock explicitly. For a vulnerability, record when a corrective or mitigating measure becomes available. For a severe incident, record the 72-hour notification time.
  6. Update through the later stages. Add newly established impact, exploitation details, mitigations, and root-cause information, and submit the applicable notification and final report within their separate deadlines.
  7. Record the route and receipt. Preserve the selected coordinator, SRP submission time, stage, and follow-up information in the event record.

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