EU Cyber Resilience Act Reporting Duties Now in Effect for Software and Device Makers, with Full Enforcement Set for December 2027
The European Union's Cyber Resilience Act (CRA), Regulation (EU) 2024/2847, is now actively changing how software and connected hardware are built, sold, and supported. The CRA is the first law to set mandatory cybersecurity requirements for nearly every hardware and software product sold in the EU market.
The regulation moves responsibility for product security away from end users and onto the companies that make, import, and distribute digital products. It creates a legal "duty of care" that lasts for the entire life of a product, from design through end of support.
The first deadline has already passed. Since September 11, 2026, manufacturers must report actively exploited vulnerabilities and severe security incidents to the EU's Single Reporting Platform, run by ENISA, with an early warning due within 24 hours. On December 11, 2027, every in-scope product must meet the CRA's essential security requirements, pass a conformity assessment, and carry the CE mark before it can be sold in the EU.
The CRA is not limited to European companies. Any business, including a small U.S. software company or device maker, that places a product with digital elements on the EU market is in scope.
"Security is always too much, until it wasn't enough. The CRA puts a price on 'wasn't enough.' Most of the companies we talk to don't need an army of consultants. They need someone to tell them plainly whether they're in scope, what's missing, and who's going to file the report when the 24-hour clock starts. That's what we do."
ASI's CRA services help organizations confirm scope and product classification, close gaps against the CRA's Annex I security requirements, build the technical file and Software Bill of Materials (SBOM) the law requires, and prepare and submit Article 14 reports on the client's behalf when an exploited vulnerability or severe incident occurs.
