Vulnerability Management under the CRA: What the New Reporting Rules Mean for You
The European Union's Cyber Resilience Act (CRA) is rapidly approaching, and for manufacturers of connected products it represents a paradigm shift from a 'buyer beware' to a 'manufacturer is responsible' market. For security and compliance officers, this means a significant overhaul of your vulnerability management and incident response programs.
The days of quietly patching vulnerabilities are over. The CRA mandates aggressive and transparent reporting, backed by the threat of severe fines (up to €15 million or 2.5% of global annual turnover). The core of this change lies in the new, non-negotiable reporting timelines.
The New Clock Starts Now: CRA Reporting Timelines
The most impactful change is the mandatory notification of actively exploited vulnerabilities and severe security incidents. You must now report these to the relevant national Computer Security Incident Response Team (CSIRT) and the European Union Agency for Cybersecurity (ENISA) in a multi-stage process.
| Timeline | Action Required | Details |
|---|---|---|
| Within 24 hours of becoming aware | Initial Notification (Early Warning) | Report the existence of the actively exploited vulnerability or severe incident. This must be without undue delay. |
| Within 72 hours of awareness | General Information | Provide more detail, including the nature of the exploit, any corrective or mitigating measures taken, and the sensitivity of the information. |
| Within 14 days of making a fix available | Final Report | Submit a comprehensive description of the vulnerability, its severity, impact, and the details of the security update or corrective measures provided to users. |
The Critical Takeaway for Your Team
This tight timeframe—especially the 24-hour initial notice—is a complete game-changer. It demands a level of operational maturity and speed that many current vulnerability management programs lack. You can no longer afford to wait until a patch is fully deployed or a detailed investigation is complete before notifying authorities.
Operationalizing CRA Compliance: A Security Officer's Checklist
Compliance with the CRA's reporting rules isn't a checklist; it's a fundamental restructuring of your Security Development Lifecycle (SDL) and post-market processes. Here’s where your focus needs to be:
1. Establish a Coordinated Vulnerability Disclosure (CVD) Policy
The CRA requires manufacturers to have a robust CVD policy. This isn't just a legal document—it's your public-facing process for managing external reports.
Designated Contact Point: Provide a clear, easily accessible channel (e.g., a dedicated email or web form) for users and third parties to report vulnerabilities.
Structured Process: Your policy must specify a structured process for receiving, diagnosing, remedying, and disclosing vulnerabilities in a coordinated manner.
2. Mandatory Proactive Testing and SBOM Generation
You are no longer expected to wait for a security researcher or attacker to find a flaw. The CRA requires you to "apply effective and regular tests and reviews" of your product's security.
Regular Security Testing: Integrate continuous security testing into your CI/CD pipeline. Test of Things is a great service for this.
Software Bill of Materials (SBOM): You must identify and document all components, including third-party and open-source software, by drawing up an SBOM. This is non-negotiable for vulnerability tracking and demonstrating due diligence.
3. Build a High-Velocity Incident Response Workflow
The 24/72-hour deadlines require an immediate, predefined response mechanism.
Define "Awareness": Clearly define the point at which your organization is officially "aware" of an actively exploited vulnerability. This could be upon validation by your security team, not just initial triage.
Dedicated Reporting Team: Assign and train a small, senior team responsible for composing and submitting the mandatory notifications to the CSIRT/ENISA channel, ensuring all legal and technical requirements are met under extreme pressure.
User Notification: Manufacturers must also inform affected users of the vulnerability, the security update, and any immediate mitigating options they can take. This communication must be prompt and clear.
CRA as a Competitive Advantage
While the compliance burden is heavy, view the CRA not as a cost center, but as a catalyst for security maturity. Secure-by-Design and secure-by-default principles are now mandatory, which translates directly into lower long-term maintenance costs and increased consumer trust.
In a crowded IoT market, a publicly verifiable commitment to lifecycle security and transparent vulnerability handling—backed by the rigorous compliance of the CRA—will become a key differentiator. The choice is clear: implement a world-class vulnerability management program now, or face the significant financial and reputational penalties later. Your product’s CE mark now depends on it.
Would you like to see how to set up continuous security testing for your products? Contact us for a free consultation call.
