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No. The EU Cyber Resilience Act (CRA) does not ban manual vulnerability triage or require automated triage software. It does require manufacturers to assess suspicious events promptly and, when they become aware of qualifying events, meet strict reporting deadlines. The practical change is a need for disciplined, time-sensitive triage—not the end of human judgment.
What the CRA changes—and what it does not
The CRA is an EU product-security law for products with digital elements placed on the EU market. Its requirements are being phased in: the reporting duties in Article 14 apply from 11 September 2026, while the main cybersecurity requirements apply from 11 December 2027, according to the European Commission’s CRA reporting page.
The reporting rules do not turn every vulnerability alert into a report. They apply when a manufacturer becomes aware of an actively exploited vulnerability contained in its product, or a severe incident affecting that product’s security. The Commission’s implementation guidance says suspicious events should be assessed immediately. Awareness is reached when that initial assessment produces reasonable certainty that active exploitation or a severe incident affecting product security has occurred.
That is why “completely kills” overstates the effect. Triage remains necessary to determine what happened, whether the product is affected, and whether the legal reporting threshold is met. The sources describe deadlines and reporting duties; they do not prescribe an automated triage tool.
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Which events trigger reporting?
Actively exploited vulnerabilities in the manufacturer’s product
The trigger is not simply that a vulnerability exists somewhere in a product or its software bill of materials. The relevant question is whether it is actively exploited in the manufacturer’s product. A vulnerability in an integrated component that cannot be exploited in that product, or has not been exploited in it, does not meet that manufacturer’s mandatory reporting trigger on that basis alone. Other vulnerability-handling duties may still apply.
Severe incidents affecting product security
A severe incident is a separate reporting trigger. It concerns an incident that has compromised the security of the product with digital elements. The initial assessment therefore needs to distinguish this case from routine alerts and from vulnerabilities that have not been actively exploited in the product.
Users may need to be informed
After becoming aware of a qualifying event, a manufacturer should inform impacted users and, where appropriate, all users. Commission guidance describes disclosure as risk-based and proportionate; it does not require indiscriminate public disclosure in every case.
CRA reporting deadlines and where to submit
The deadlines have different starting points and should not be treated as one single response window. The Commission sets out the following reporting sequence:
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| Submission | Deadline | What starts the clock |
|---|---|---|
| Early warning | Within 24 hours | When the manufacturer becomes aware of the reportable event |
| Full notification | Within 72 hours | When the manufacturer becomes aware of the reportable event |
| Final report: actively exploited vulnerability | No later than 14 days after a corrective measure is available | Availability of the corrective measure |
| Final report: severe incident | Within one month of the 72-hour notification | The 72-hour notification |
These are the Commission’s stated CRA deadlines, not estimates of how quickly organizations typically respond. The Commission says notifications are submitted through ENISA’s Single Reporting Platform (SRP) to the designated CSIRT. They are addressed to the CSIRT in the country where the manufacturer has its main establishment and are ordinarily made available to ENISA at the same time. ENISA says the SRP supports a single submission to the relevant authorities. ENISA announced the platform’s launch on 11 September 2026 in its launch notice.
When the reporting rules apply
For manufacturers, Article 14 reporting applies from 11 September 2026. Commission guidance says this includes in-scope products placed on the market before 11 December 2027; the later date for the main cybersecurity requirements does not postpone the reporting start for those products. Reporting obligations also continue after a product’s support period ends. By contrast, the CRA’s Part II Annex I vulnerability-handling duties are tied to the support period and have a different temporal reach.
Open-source software stewards are a distinct case: the Commission identifies 11 December 2027 as the start date for their Article 24(3) reporting obligations. Do not assume that every open-source maintainer has the same reporting start date as a manufacturer.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What this means for manual and automated workflows
The law makes timely, defensible assessment more important; it does not determine whether a person, software, or a combination performs the work. An automated workflow can help organize intake and track clocks, while human review may be needed to establish product context and interpret evidence. Those are operational choices, not CRA-mandated categories or a Commission endorsement of a particular tool.
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| Workflow question | What a sound process needs to establish | Potential role for automation |
|---|---|---|
| Is this reportable? | Whether the event concerns an actively exploited vulnerability in the manufacturer’s product or a severe incident affecting its security | Sort and correlate incoming alerts; it cannot remove the need to assess whether the legal threshold is met |
| When did the reporting clock start? | When the initial assessment reached reasonable certainty of a qualifying event, rather than simply when an unverified alert arrived | Record intake, assessment milestones, decisions, and deadlines |
| Does a dependency affect this product? | Whether the component vulnerability is exploitable in the relevant product and whether it has been exploited there | Connect component and product-version records for investigation |
| How is the report delivered? | The correct CSIRT route and a complete submission through the official SRP | Prepare or track workflow steps; the official reporting route remains the SRP |
| Who should be told? | Which users are impacted and whether broader communication is appropriate and proportionate | Support communication tracking without replacing the risk-based decision |
This is an operational way to think about the work, not an official certification checklist or a comparison of commercial products. The key is to preserve enough context to explain the assessment and act within the relevant deadline.
What smaller organizations should take from the rules
The Commission recognizes that micro, small and medium-sized enterprises may lack the knowledge and expertise needed for implementation. Its MSME information page, last updated 31 July 2026, lists EU-funded support projects including OCCTET, CONFIRMATE, CRACY and OSCRAT. These are support initiatives, not proof that a particular commercial triage product is required or effective.
The official material does not establish how many manufacturers currently rely on manual triage, how prepared the market is, or whether automation improves compliance. Organizations should assess their own product scope and response process rather than treating the CRA as a blanket mandate to buy triage software.
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