Reporting obligations apply
The Commission states manufacturers must report actively exploited vulnerabilities and severe incidents affecting products with digital elements.
As of 11 September 2026, manufacturers have reporting duties for actively exploited vulnerabilities and severe incidents affecting products with digital elements. This is a technical-readiness briefing, not legal advice.
The Commission states manufacturers must report actively exploited vulnerabilities and severe incidents affecting products with digital elements.
Official guidance describes an early-warning requirement within 24 hours and a full notification within 72 hours of awareness.
The Commission's implementation timeline states the CRA's full application is scheduled for 11 December 2027.
Where a blockchain product includes software, wallets, nodes, gateways, APIs, embedded components or other products with digital elements, teams should determine whether and how CRA obligations may apply with qualified legal/security support.
We can help structure technical evidence, incident workflows and architecture documentation alongside your legal/compliance specialists.