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# EU Cyber Resilience Act Vulnerability Reporting

Beyond the Cyber Resilience Act's design requirements sits a time-pressured obligation: when you discover an actively exploited vulnerability or severe incident, the clock starts on a strict, staged reporting timeline to ENISA and CSIRTs -- not a leisurely internal process.

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At a glance

Regulation

(EU) 2024/2847

Early warning deadline

24 hours after becoming aware

Full notification deadline

72 hours after becoming aware

Final report deadline

14 days after a fix is available

Reported to

ENISA / designated CSIRT

## What triggers the reporting clock

### Two distinct trigger events

The CRA's reporting obligations are triggered separately by an actively exploited vulnerability, and a severe incident having an impact on the security of a product with digital elements.

### "Becoming aware" starts the countdown

The deadlines run from the moment the manufacturer becomes aware of the qualifying event, not from when it was first introduced.

### This is a manufacturer obligation, not just a "nice to have"

This is a binding legal reporting obligation tied to specific deadlines -- missing them is a compliance failure independent of how well the vulnerability was eventually fixed.

## The staged reporting timeline

01

Early warning, within 24 hours of becoming aware: a brief initial notification to ENISA via the designated CSIRT.

02

Notification, within 72 hours: a more complete report including a severity and impact assessment.

03

Intermediate status updates as requested by the CSIRT or ENISA for an incident that remains unresolved.

04

Final report, within 14 days after a corrective measure becomes available.

05

In parallel, affected users generally need to be informed of the vulnerability and any corrective measures they should take.

## Building a process that can actually meet these deadlines

### 24 hours is shorter than most internal incident processes

Meeting the 24-hour early warning deadline typically requires a pre-built, on-call escalation path designed specifically for this trigger.

### Know your CSIRT and reporting channel before you need it

Identify the designated CSIRT and reporting mechanism applicable to your products in advance.

### Coordinate security and product/legal teams ahead of time

Decide in advance who is authorized to file the early warning with limited information, so the process doesn't stall waiting for full sign-off.

## Frequently asked questions

### Does every vulnerability need to be reported within 24 hours?

No -- the strict clock applies specifically to actively exploited vulnerabilities and severe incidents, not to every vulnerability discovered through routine testing.

### Who do I actually report to?

Reports go to ENISA, generally via the CSIRT designated for this purpose under the CRA's coordinated vulnerability disclosure framework.

### What happens if I miss the 24-hour deadline?

Missing the deadline is a compliance failure under the CRA in its own right, separate from how the vulnerability is eventually remediated.

### Do I also have to tell my customers, or just the regulator?

Both, generally -- alongside regulatory reporting, manufacturers are expected to inform affected users of the vulnerability and any corrective measures.

**Disclaimer:** This page is an educational resource only and does not constitute legal advice. Cyber Resilience Act reporting mechanisms continue to be finalized as the regulation's obligations phase in -- consult current ENISA guidance and qualified counsel before finalizing an incident-response process.

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