EU Cyber Resilience Act reporting obligations began 11 September 2026

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Under the EU Cyber Resilience Act, reporting duties for actively exploited vulnerabilities and severe incidents took effect on 11 September 2026 and apply to all software sold in the EU, including older products, with no transition period. Filings go through a single platform to national CSIRTs and ENISA on 24-hour, 72-hour, and final-report deadlines. Broader requirements such as the SBOM, technical documentation, EU Declaration of Conformity, and CE marking apply from 11 December 2027. The article argues that generating an SBOM is easy with existing tools, while the harder work is depth justification, exploitability assessments recorded as VEX statements, vulnerability-handling and disclosure processes, and a tested incident workflow. It also notes that no harmonised standard is yet cited in the Official Journal, so no presumption of conformity exists.

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