Markdown Editor

CRA Vulnerability Handling and Reporting Procedure Template

EU CRA procedure: scope, RACI, Annex I Part II, SBOM, CVD, support period, Article 14 24h/72h/final reports via ENISA platform, user notices, timeline

Sicherheits-EngineeringVollständigRegulation (EU) 2024/2847 (Cyber Resilience Act) Art. 13, 14, Annex I Part IIcravulnerabilityhandling

Anleitung: Use it when you place products with digital elements on the EU market and must report actively exploited vulnerabilities and severe incidents, which applies since 11 September 2026. Fill the product list, the roles with deputies and the definition of awareness first, then rehearse the 24-hour path. The main pitfall is waiting for a fix or a full analysis before sending the early warning.

Vorschau

CRA Vulnerability Handling and Reporting Procedure: [Manufacturer] [product family]

Procedure for a manufacturer of products with digital elements to handle vulnerabilities and to report actively exploited vulnerabilities and severe incidents under the EU Cyber Resilience Act (Regulation (EU) 2024/2847). It covers the vulnerability handling requirements of Annex I Part II, the software bill of materials, coordinated vulnerability disclosure, security updates and the support period, and the Article 14 reporting clocks (24 hours, 72 hours and final report) through the ENISA Single Reporting Platform. Article 14 applies from 11 September 2026, also to products placed on the market before 11 December 2027; the rest of the Regulation applies from 11 December 2027. Check the consolidated text on EUR-Lex for the dates and wording that apply to you. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice.

Document control

FieldValue
Document ID[CRA-VH-001]
Manufacturer[Legal name, address, main establishment Member State]
Products covered[Product names, types, versions; or reference to the product register]
Coordinator CSIRTExample: CSIRT designated as coordinator in [Member State of main establishment]
Single Reporting Platform account[Organisation account ID; named submitters in section 3]
Version[0.1]
Status[Draft / In review / Approved / Superseded]
Owner[@product-security-lead]
Approvers / reviewers[@ciso], [@legal-regulatory], [@head-of-engineering]
Last updatedYYYY-MM-DD
Classification[Internal]
Related documents[CRA technical documentation], [Coordinated vulnerability disclosure policy], [Incident response plan], [SBOM policy], [Security policy]

Approvals

RoleNameDecisionDate
Product security lead[@name][Approved / Changes requested]YYYY-MM-DD
Chief information security officer[@name][Decision]YYYY-MM-DD
Legal and regulatory affairs[@name][Decision]YYYY-MM-DD
Accountable executive[@name][Decision]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]First draft
1.0YYYY-MM-DD[@name]Example: Approved before 11 September 2026 reporting start
1.1YYYY-MM-DD[@name]Example: Updated after tabletop exercise EX-2026-02

Contents

1. Scope and applicability

1.1 Products

Product IDProduct and versionsCategoryPlaced on the marketIn scope reasonSupport period end
PRD-001 (Example)[Router model X] firmware 3.xImportant product, Annex III class I2025-03Hardware with software, network connection2031-03
PRD-002 (Example)[Desktop app] 5.xDefault category2024-06Software placed on the market commercially2029-12
PRD-003 (Example)[Cloud companion service]Remote data processing solution of PRD-0012025-03Remote processing needed for a product functionSame as PRD-001
[PRD-nnn][Product][Default / Annex III class I / class II / Annex IV]YYYY-MM[Reason]YYYY-MM

1.2 Other regimes that may apply

RegimeRelevanceCoordination rule
Example: NIS2 (Directive (EU) 2022/2555)Our own network and information systems if we are an essential or important entityIncident response plan decides whether both regimes apply; one incident record, two reports
Example: GDPR (Regulation (EU) 2016/679)Personal data breach in the companion serviceData protection officer assesses notification to the supervisory authority
Example: Sector legislation[Medical devices, vehicles, aviation or other][Rule]
[Regime][Relevance][Rule]

2. Key dates and legal basis

ProvisionSummary in own wordsApplies from
Article 71(2)General date of application of the Regulation11 December 2027
Article 71(2)Reporting obligations of manufacturers (Article 14)11 September 2026
Article 71(2)Rules on notification of conformity assessment bodies (Chapter IV, Articles 35 to 51)11 June 2026
Article 69(3)Article 14 applies also to in-scope products placed on the market before 11 December 202711 September 2026
Article 13(6)Report vulnerabilities found in integrated components to the component maintainer and remediate them11 December 2027
Article 13(8)Handle vulnerabilities effectively for the support period; support period normally at least five years11 December 2027
Article 13(9)Keep each security update available for at least ten years or the rest of the support period, whichever is longer11 December 2027
Article 13(17)Single point of contact for users, including for vulnerability reports11 December 2027
Article 15Voluntary reporting of vulnerabilities, threats, incidents and near misses11 December 2027
Article 16ENISA Single Reporting Platform, national notification end-pointsPlatform operated by ENISA; reporting through it applies from 11 September 2026 (check ENISA for the current entry point)
Annex I Part IIEight vulnerability handling requirements11 December 2027

3. Roles and responsibilities

3.1 Roles

RoleHolderDeputyResponsibilities
Product security incident response team (PSIRT) lead[@name][@name]Owns this procedure, runs triage, decides whether a case is reportable
Reporting officer[@name][@name]Submits early warning, notification and final report on the platform
Product owner[@name] per product[@name]Fix planning, release, user communication content
Engineering lead[@name][@name]Root cause, fix, test
Legal and regulatory[@name][@name]Applicability, wording of reports, contact with authorities
Communications[@name][@name]Advisories, user notices, press
Executive sponsor[@name][@name]Escalation, resources, disclosure decisions with business impact

3.2 RACI

R = responsible, A = accountable, C = consulted, I = informed.

ActivityPSIRT leadReporting officerProduct ownerEngineeringLegalCommsExecutive
Intake and acknowledgementA, RIIC
Triage and severityA, RICRC
Decide "actively exploited" or "severe incident"ACCCRI
Early warning (24 h)ARICCI
Notification (72 h)ARCCCI
Fix and security updateCAR
Advisory and user informationARCCRI
Final reportARCCCI
Records and lessons learnedA, RCCCCI

4. Vulnerability handling requirements (Annex I Part II)

PointRequirement (summary)How we meet itEvidence
(1)Identify and document vulnerabilities and components, including a machine-readable SBOM covering at least top-level dependenciesSection 5; SBOM generated in every release buildSBOM archive, build logs
(2)Address and remediate vulnerabilities without delay in relation to the risk, including through security updates; where technically feasible, ship security updates separately from feature updatesSections 7 and 8; remediation targets by severity; separate security release trainCase records, release notes
(3)Apply effective and regular security tests and reviewsExample: SAST and dependency scanning per commit; annual penetration test per product; fuzzing of parsersTest reports
(4)After a security update is available, publicly disclose information on fixed vulnerabilities (description, affected products, impact, severity, remediation guidance); publication may be delayed in justified cases until users could patchSection 10; security advisories in CSAF and on the websiteAdvisory archive
(5)Put in place and enforce a coordinated vulnerability disclosure policySection 6Published CVD policy
(6)Facilitate sharing of information on potential vulnerabilities in the product and its third-party components, including a contact address for reportsSection 6.2; security.txt; reporting to upstream maintainers (Article 13(6))Contact page, upstream report log
(7)Provide mechanisms to distribute updates securely so vulnerabilities are fixed or mitigated in a timely manner, automatically where applicableSection 8.2; signed updates, automatic installation by defaultUpdate architecture, signing records
(8)Disseminate available security updates without delay and, unless agreed otherwise for a tailor-made product with a business user, free of charge, with advisory messages for usersSections 8 and 10Release and notification records

5. Software bill of materials

ItemDecision
FormatExample: CycloneDX 1.7 JSON (ECMA-424, 2nd edition); SPDX 3.0.1 on request
Minimum depthAt least top-level dependencies as required; Example: we include all transitive dependencies
Generation pointExample: Release build, from lockfiles and final firmware image
BindingExample: SBOM signed and linked to the release artefact digest
StorageExample: SBOM archive for every released version, kept for the documentation retention period
Use in handlingExample: Daily matching of all supported versions' SBOMs against vulnerability databases and the EU vulnerability database
SharingExample: Provided to market surveillance authorities on reasoned request; to customers under NDA; not published
Exploitability statementsExample: VEX statements published with advisories for "not affected" decisions

See the supply chain security assessment (security/supply-chain-security) for the full SBOM and VEX policy, and the AI-BOM template (ai-data/ai-bom) if the product contains machine learning models.

6. Coordinated vulnerability disclosure

6.1 Policy commitments

CommitmentValue
Public policy location[URL of the CVD policy and security.txt]
Acknowledgement of a reportExample: Within 2 business days
Initial assessment shared with the reporterExample: Within 10 business days
Status updatesExample: At least every 30 days until closure
Target disclosureExample: Coordinated with the reporter; default 90 days after report or on release of a fix, whichever is earlier
Safe harbourExample: Good-faith research within the policy is authorised; no legal action
CreditExample: Reporter credited in the advisory unless they decline
CVE assignmentExample: We are a CVE Numbering Authority for our products / we request IDs from [CNA]
Use of a CSIRT as coordinatorReporters may report to a national CSIRT acting as coordinator for CVD under NIS2 Article 12(1)

6.2 Intake channels

ChannelAddressMonitoredNotes
Single point of contact (Article 13(17))[[email protected] and web form]24/7 by on-call PSIRTUsers choose their channel; not limited to automated tools
Encrypted email[PGP key fingerprint]24/7
Bug bounty platform[Platform]Business hoursOptional
CSIRT or ENISA forwardingVia coordinator CSIRT24/7Article 15(4): CSIRT informs us of third-party reports
Internal findingsTicket queue [name]Business hoursTests, audits, monitoring
Upstream and supplier advisoriesFeeds [list]AutomatedComponent vulnerabilities

7. Handling workflow

7.1 Severity and remediation targets

SeverityTypical criteriaRemediation targetMitigation guidance to users
Critical (Example)CVSS 4.0 base 9.0 to 10.0, or any actively exploited vulnerability7 daysWithin 24 hours if fix not yet available
High (Example)CVSS 4.0 base 7.0 to 8.930 daysWith the fix
Medium (Example)CVSS 4.0 base 4.0 to 6.990 daysWith the fix
Low (Example)CVSS 4.0 base below 4.0Next scheduled releaseWith the fix

7.2 Case record fields

FieldContent
Case IDVH-YYYY-NNN
Source and date and time receivedChannel, reporter, timestamp with time zone
Awareness timestampWhen the criteria in 9.2 were met (starts the Article 14 clock)
Affected products and versionsPRD IDs and version ranges; SBOM components
Severity and vectorCVSS 4.0 vector and score; exploitation evidence
ReportableActively exploited vulnerability / severe incident / neither, with reasoning
RemediationFix description, release, date
DisclosureAdvisory ID, CVE ID, publication date
Reports submittedPlatform reference numbers and timestamps

8. Security updates and support period

8.1 Support period

ProductSupport periodBasis for the period (Article 13(8))End date shown to usersEnd-of-support notice
PRD-001 (Example)6 years from placing on the marketExpected use time of home routers; competitor practice; chipset vendor support until 2032Product page, packaging, admin UI (month and year)Admin UI banner and email at end date
PRD-002 (Example)5 years per major versionMinimum period; users get the latest major version free (Article 13(10))Download page, About dialogIn-app notice
[PRD-nnn][Period][Basis][Where shown][Notice]

8.2 Update delivery

ItemPractice
Separation from feature updatesExample: Security fixes released on a separate patch line where technically feasible
Automatic updatesExample: Enabled by default for security updates, with a clear opt-out and the option to postpone
IntegrityExample: Updates signed; device verifies signature and version before install; rollback protection
AvailabilityEach security update kept available for at least ten years or the rest of the support period, whichever is longer (Article 13(9))
CostFree of charge, unless otherwise agreed with a business user for a tailor-made product

9. Reporting under Article 14

9.1 What must be reported

CaseDefinition (summary)Article
Actively exploited vulnerabilityA vulnerability with reliable evidence that a malicious actor has exploited it in a system without the owner's permission (Article 3)14(1)
Severe incident having an impact on the security of the productAn incident that negatively affects, or can affect, the product's ability to protect availability, authenticity, integrity or confidentiality of sensitive or important data or functions; or that has led or can lead to malicious code in the product or in a user's systems14(3), 14(5)

Notifications go simultaneously to the CSIRT designated as coordinator and to ENISA, through the Single Reporting Platform, using the electronic notification end-point of the coordinator CSIRT of the Member State of the main establishment (Article 14(7)). Main establishment means the Member State where cybersecurity decisions for the products are mainly taken; if that cannot be determined, the establishment with the most employees in the Union. Manufacturers without a main establishment in the Union follow the order set out in Article 14(7): authorised representative, then importer, then distributor, then the Member State with the most users.

9.2 When the clock starts

[Define awareness. Example: "We are aware when the PSIRT lead or a deputy has information giving reasonable grounds to believe that the criteria in 9.1 are met, for example a credible third-party report with indicators of exploitation, our own telemetry, or a CSIRT notification. Triage to reach that judgement must not exceed [4] hours from receipt. The awareness timestamp is recorded in the case record."]

9.3 Reporting stages

StageDeadline (from awareness)Content (summary)Owner
Early warning, vulnerabilityWithout undue delay, at most 24 hoursNotice of the actively exploited vulnerability; Member States where we know the product is availableReporting officer
Vulnerability notificationWithout undue delay, at most 72 hours, unless already providedGeneral information on the product, the nature of the exploit and vulnerability, corrective or mitigating measures taken and measures users can take; how sensitive we consider the informationReporting officer
Final report, vulnerabilityAt most 14 days after a corrective or mitigating measure is available, unless already providedDescription with severity and impact; information on the malicious actor where available; details of the security update or other corrective measuresReporting officer
Early warning, severe incidentWithout undue delay, at most 24 hoursNotice of the incident; whether unlawful or malicious acts are suspected; Member States where the product is availableReporting officer
Incident notificationWithout undue delay, at most 72 hours, unless already providedNature of the incident, initial assessment, measures taken and measures users can take; sensitivity of the informationReporting officer
Final report, severe incidentWithin one month after the incident notification, unless already providedDetailed description with severity and impact; type of threat or likely root cause; applied and ongoing mitigationReporting officer
Intermediate reportWhen requested by the coordinator CSIRTStatus updates on the vulnerability or incident (Article 14(6))Reporting officer

9.4 Submission checklist

StepDone
Case ID and awareness timestamp recorded[ ]
Product identification (name, type, versions, identifiers) ready[ ]
Member States where the product is made available listed[ ]
Sensitivity of the information stated, including any request to delay dissemination for justified cybersecurity reasons (Article 16(2))[ ]
Mitigation users can apply now described in plain language[ ]
Submitted on the Single Reporting Platform; reference number recorded[ ]
Next deadline entered in the case and the on-call calendar[ ]
Coordination with NIS2, GDPR or sector reports checked (section 1.2)[ ]

10. Informing users

SituationAudienceChannelContentTiming
Actively exploited vulnerability, no fix yetImpacted users, or all users where appropriateExample: Admin UI notice, email, advisory pageRisk, mitigation steps, expected fix dateExample: With or before the 72-hour notification
Security update availableAll users of affected versionsUpdate notification, advisory in CSAF and HTMLDescription, affected products, impact, severity, remediationWith the update
Severe incidentImpacted usersDirect noticeWhat happened, impact on them, measures to takeAs soon as measures are known
Delayed publication (justified)PublicAdvisoryPublished after users could apply the patchDocumented decision

Provide user information, where appropriate, in a structured, machine-readable format that tools can process automatically, for example CSAF 2.0 advisories with VEX status.

11. Records

RecordContentRetentionLocation
Case recordsFields in 7.2, decisions, timelineExample: 10 years after the last affected version was placed on the market or the support period, whichever is longer[System]
Platform submissionsCopies of each report and platform referencesSame[System]
Advisories and VEXPublished versionsSame[System]
SBOMsPer released versionSame[System]
Component vulnerability reports to maintainersArticle 13(6) reports and shared fixesSame[System]
Exercise reportsSection 125 years[System]

12. Exercises and review

IDExerciseScenarioMeasuredDateResult
EX-2026-01 (Example)TabletopExploited authentication bypass in PRD-001 firmware reported on a SaturdayTime from intake to early warning draftYYYY-MM-DD9 h; deputy lacked platform access, fixed
EX-2026-02 (Example)Technical drillMalicious update pushed through compromised build serverDetection, incident classification, user noticeYYYY-MM-DD[Result]
[EX-nnn][Type][Scenario][Measure]YYYY-MM-DD[Result]

Review this procedure after every reportable case, after each exercise, when the Commission adopts implementing or delegated acts on reporting or SBOM format, and at least annually.

13. Worked timeline

Example: A researcher reports on Monday at 10:00 that an authentication bypass in PRD-001 firmware 3.4 is being used against routers on the internet. The PSIRT confirms indicators of exploitation at 13:00, which is the awareness time.

TimeActionDeadline met
Mon 13:00Awareness recorded in VH-2026-014Not applicable
Mon 20:00Early warning submittedYes (24 h deadline Tue 13:00)
Wed 16:00Vulnerability notification submittedYes (72 h deadline Thu 13:00)
FriSecurity update released (corrective measure available)Not applicable
Following WedFinal report submittedYes (14 days after the update)

14. Glossary and references

TermMeaning in this document
Product with digital elementsSoftware or hardware product and its remote data processing solutions, including separately placed components
ManufacturerPerson who develops or manufactures the product, or has it designed or made, and markets it under its name or trademark
CSIRT designated as coordinatorNational computer security incident response team designated for coordinated vulnerability disclosure under NIS2
Single Reporting PlatformPlatform run by ENISA through which Article 14 notifications are submitted
Support periodPeriod during which the manufacturer must handle vulnerabilities effectively in line with Annex I Part II
SBOMSoftware bill of materials: a formal record of the components in the product's software and their supply chain relationships
CVDCoordinated vulnerability disclosure

References:

Standard and licence note

Based on Regulation (EU) 2024/2847 (Cyber Resilience Act), Articles 3, 13 to 17, 69 and 71 and Annex I Part II, as published in the Official Journal of the European Union on 20 November 2024; EU legislative texts are free to reuse. The provisions are summarised in original wording and no text of the Regulation is reproduced. Check the consolidated text on EUR-Lex, Commission implementing and delegated acts, and ENISA guidance for the current requirements. This is a documentation format, not legal advice. Template licence: MIT.

Ähnliche Vorlagen