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Cyber Resilience Act
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Cyber Resilience Act

EU regulation imposing cybersecurity requirements on connected hardware and software products.

The EU's Cyber Resilience Act began its first live enforcement obligation on 11 September 2026, requiring manufacturers to report an actively exploited flaw within 24 hours or risk fines of up to €15 million.

Last refreshed: 2 October 2026 · Appears in 2 active topics

Key Question

If the UK ICO is already enforcing NCSC baseline guidance under GDPR, what does the CRA add?

Timeline for Cyber Resilience Act

#14 30 Sept
#16 11 Sept

Took effect, requiring 24-hour vulnerability reporting

European Tech Sovereignty: Cyber Resilience Act starts its clock
#13 31 Aug

ENISA updates its single-reporting platform FAQ

Cybersecurity: Threats and Defences
#6 3 Jun

Mentioned in: Magento RCE forces 9-day patch race

Cybersecurity: Threats and Defences
View full timeline →

Background

The Cyber Resilience Act (CRA) was adopted by the European Parliament in March 2024, introducing mandatory cybersecurity requirements for any hardware or software product placed on the EU market that contains digital elements: IoT devices, operating systems and connected industrial equipment. It treats cybersecurity as a product characteristic rather than an optional ADD-on, requiring vulnerability assessment, security-by-design principles and five-year vulnerability disclosure obligations.

Application is staggered. The Act entered into force on 10 December 2024. The conformity-assessment-body framework applied from 11 June 2026. Reporting obligations under Article 14 applied from 11 September 2026. The bulk of the regulation, including essential cybersecurity requirements and CE marking, applies in full from 11 December 2027, after which products with digital elements must complete conformity assessment before sale in the EU. Penalties for non-compliance reach up to 2.5% of a company's global annual turnover.

Key Issues
CRA enforcement

CRA reporting duty goes live

The Cyber Resilience Act's Article 14 reporting obligation began applying on 11 September 2026: manufacturers must WARN authorities within 24 hours of becoming aware of an actively exploited vulnerability, and file a full notification within 72 hours, with fines of up to €15 million. The duty already covers legacy products, not only new ones, and lands on the commercial vendor rather than the open-source code many products contain.

That distinction was settled in March 2026, when the European Commission's draft implementation guidance placed compliance responsibility on whoever 'puts software into service', not volunteer maintainers, the outcome open-source groups had lobbied for. The Act's bulk, including CE marking and full conformity assessment, still does not apply until 11 December 2027.

Common Questions

CRA reporting duty goes live

Does the Cyber Resilience Act apply to open source software?
Open source software developed commercially is covered. Draft March 2026 guidance confirmed liability falls on the entity that 'puts it into service': the commercial publisher or deployer, not the volunteer maintainer community. Purely voluntary open source contributions are largely excluded.Source: European Commission CRA open-source guidance, March 2026

Reference

What is the EU Cyber Resilience Act and who does it affect?
The CRA requires any hardware or software product with digital elements sold in the EU to meet mandatory cybersecurity requirements throughout its lifetime, from design through to end-of-support. It affects device makers, software publishers, and importers worldwide selling into the EU market.Source: European Commission CRA proposal
Is the Capita ICO fine a preview of what the CRA will enforce?
The Capita £14m fine and South Staffordshire Water £963,900 fine both enforced NCSC baseline guidance as a proxy for adequate security under UK GDPR Article 32, the same security-of-processing standard the CRA will codify at product level for EU manufacturers. The enforcement pattern confirms the regulatory baseline is moving before the CRA reaches the statute book.Source: ICO / Lowdown analysis
When does the full Cyber Resilience Act apply?
The essential cybersecurity requirements and CE marking apply in full from 11 December 2027, after a 36-month transition from the Act's entry into force.
When do the Cyber Resilience Act's reporting duties start?
Article 14 incident and vulnerability reporting obligations applied from 11 September 2026, covering both new and legacy products already on the EU market.Source: European Commission, digital-strategy.ec.europa.eu
How does the CRA relate to NIS2 and the AI Act?
The CRA covers product security from design to end-of-life. NIS2 covers operational security for critical infrastructure operators. The AI Act covers AI system risk. All three are part of the EU's overlapping digital regulation stack.Source: European Commission digital regulation briefing
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