CRA · Article 14 · September 11, 2026

September 11. Twenty-four hours.
We watch your components.
You build your product.

From September 11, manufacturers of connected products must report actively exploited vulnerabilities to ENISA within 24 hours of becoming aware. We set up the process, then run the daily watch — so the first time you hear about a KEV hit, you already have everything you need to respond.

11 Sep CRA Article 14 mandatory vulnerability reporting begins
24 h Early warning to ENISA once you become aware
€15 M Or 2.5% of global turnover — whichever is higher
11 Dec CRA full compliance deadline — SBOM obligations, conformity assessments, CE marking
Book a scoping call → 30 minutes · No commitment · Honest answer even if it is no
PhD Physics · CERN · 15y Regulated Industries · Industrial AI & Cybersecurity · EU Regulatory · RE:MARK · Milan
The reporting cascade you must be ready for
CVE HIT t = 0 EARLY WARNING notify ENISA + CSIRT 24 HOURS VULNERABILITY NOTICE scope · severity · mitigation 72 HOURS FINAL REPORT root cause · fix · patch 14 DAYS AFTER FIX €15 M if missed CLOCK STARTS AT AWARENESS · NOT AT CONFIRMATION · RUNS OVER WEEKENDS

Article 14 CRA — mandatory from September 11, 2026. The 24-hour window starts the moment you become aware of active exploitation — regardless of whether you have confirmed it internally.

The obligation most manufacturers are not ready for
What companies assume

"We have a component list — we're covered"

An SBOM file is the starting point, not the finish line. Article 14 requires that you can query your SBOM against live vulnerability feeds, determine which products are affected, assess whether exploitation is active, and file with ENISA — all within 24 hours. A spreadsheet cannot do this at 2am on a Friday.

What Article 14 actually requires

Awareness triggers the clock — monitoring is not optional

The regulation is explicit: "becomes aware" is a low bar. A market surveillance authority will ask what monitoring process was in place. "We had no process" is not a compliant answer — it is evidence that you could not have become aware, which is itself a violation. The obligation to monitor is implicit in the obligation to report.

What we do about it

We build the process, then we run the watch

Two weeks to set up a documented, tested vulnerability monitoring process — with signed delegation, escalation path, and pre-filled ENISA templates. Then we keep watching: daily automated scans against your component inventory, immediate alerts on actively exploited vulnerabilities, dated evidence for your audit file. You own the process. We operate the watch.

The cost of inaction

One missed deadline costs more than a hundred of these engagements

The fine ceiling is €15 million or 2.5% of global annual turnover. But the operational cost lands first: a crisis-mode legal review of a missed 24-hour window, the scramble to reconstruct what components were in which products, the reputational cost of a late or incomplete filing. This engagement costs less than one hour of that review.

What running every day looks like
06:00 UTC

Daily automated scan

Your component inventory is checked against the OSV vulnerability database and the CISA Known Exploited Vulnerabilities catalogue. Every day. No human in the loop. Results are stored with timestamps for your audit trail.

⚡ KEV hit

Immediate alert

If a component you ship is confirmed as actively exploited, your designated reporter receives an email within minutes — not hours, not days. The email names the affected component, the CVE, which of your products are impacted, and what to do next. Your 24-hour clock starts at the timestamp of that email.

1st

Monthly evidence pack

A dated report covering every scan, every finding, and every assessment for the month. Filed in your shared folder. When a market surveillance authority asks what monitoring was in place, you hand them this.

You install nothing. You run no tools. The watch runs whether you are in the office, on holiday, or asleep.

Before the watch starts — two weeks of setup
You send one file

Your dependency manifest

requirements.txt, package-lock.json, a Yocto manifest, or a spreadsheet — whatever form it currently exists in. If you have nothing, that is also an answer, and we start from there. We generate a machine-readable SBOM and run the first vulnerability scan.

Two short sessions

Map your products, test your process

One scoping call to map your connected products and who handles incidents. One working session to walk through the 2am scenario end to end — detection, triage, 24-hour filing. Around three hours of your team's time across the two weeks.

Review, sign, go live

The watch starts running

Your team reviews the document pack, signs the designated-reporter delegation, and files it in your quality system. Daily monitoring goes live. From that point: you do nothing until something hits — and when it does, everything is already in place.

+ The document pack — nine controlled documents, filed in your quality system 9 ITEMS
D1

Readiness Assessment Report

Dated baseline: what components you ship, which carry known vulnerabilities, which are confirmed as actively exploited. Establishes your starting position on a specific date.

D2

Component Inventory Register (SBOM)

Your SBOM in CycloneDX format, queryable against vulnerability feeds — plus the procedure for keeping it current on every release.

D3

SOP-CRA-01 — Vulnerability Monitoring and Reporting Procedure

The core procedure defining awareness triggers, monitoring inputs, triage decisions, and the full reporting cascade. Written in QMS format with document control and approval signatures.

D4

Authority Matrix and Designated Reporter Appointment

Signed delegation naming who may submit an ENISA notification without further approval, with the limits of that authority stated explicitly. The document that evidences "without undue delay."

D5

Incident Decision Tree

One page, three questions. Is the component in a marketed product? Is it actively exploited? Is it reachable as shipped? Designed to be printed and put on a wall.

D6

ENISA SRP Submission Templates

Three pre-filled templates matching the 24-hour early warning, the 72-hour notification, and the 14-day final report. Your reporter completes a form, not composes one.

D7

Tabletop Exercise Record

Dated evidence that the procedure was tested with the people who would actually run it, including gaps surfaced and how they were closed.

D8

Technical File Annex

A drop-in section for your CRA technical documentation, formatted to sit alongside your existing CE marking evidence.

D9

Monitoring Evidence Log

The running record of every scan, every finding, every assessment. Populated automatically by the daily watch. This is how you demonstrate you had the capability to become aware.

Three ways to start
See where you stand

Exposure Snapshot

Free
Within 24 hours · No obligation
  • Send your dependency manifest or component list
  • We scan it against live vulnerability databases and the CISA KEV catalogue
  • Two-page summary: what you ship, what carries known issues, what would trigger an Article 14 obligation today
After the first three months

Continuous Watch

€290/mo
Per product line · €2,900 prepaid annually
  • Daily automated scan against your component inventory
  • Immediate alert if a component is confirmed as actively exploited
  • Dated monthly evidence pack
  • Annual procedure review and re-issue
  • Incident support when a real ENISA notification is required

Delivery is one engagement at a time. Capacity before September 11 is limited to six engagements.

Who commissions this
CTO · Connected-Product Manufacturer

A process that works before the first real incident

Your team built the product. Nobody built the incident response process. You need a documented, tested reporting workflow and someone watching the feeds — before September 11, not after the first fine.

Head of Engineering · IoT / Industrial / Edge

Know exactly where you stand — before the MSA asks

You have connected products on the EU market. You are not certain your SBOM is queryable or your reporting path is clear. This produces an honest gap assessment, closes the critical ones, and keeps watching after the assessment is done.

CEO · SME Manufacturer

Fixed scope, fixed price, continuous coverage

You need CRA Article 14 readiness before September. You do not have a dedicated PSIRT or security team. This engagement is designed for exactly this situation: a working process delivered in two weeks, with ongoing monitoring so the process stays operational — without building internal capability you don't yet need.

Quality / Regulatory Manager

One engagement, two obligations covered

CRA Article 14 reporting begins September 11. NIS2 incident reporting follows a compatible cascade structure — 24h early warning, 72h notification, final report. A process built for CRA Article 14 satisfies the NIS2 reporting workflow for the same incident. One engagement addresses both.

A cybersecurity consultant maps your gaps against a checklist and tells you what to fix. A legal firm explains what Article 14 requires and what the fines are. Neither builds the process, watches your components every day, and wakes your reporter when something hits.

The combination that makes this work is specific: a physicist who has spent 15 years inside regulated industry development — at the intersection of engineering, compliance, and data infrastructure — and who understands both what the regulation requires operationally and how connected-product engineering actually works. Firmware SBOMs are structurally different from web-application dependency trees. Vulnerability triage for an embedded RTOS is different from patching a cloud service. The process reflects that.

You own the process and the evidence. We operate the daily watch. No lock-in — the procedure, the delegation, and the documents are yours regardless.

Connected products on the EU market and a September 11 deadline?

A 30-minute call to understand your product landscape, your current SBOM status, and whether this is the right next step. No commitment. Honest answer even if this is not the right fit.

Book 30 minutes → Or write directly
Giulio Piana Founder and Principal · RE:MARK giulio.piana@brandcraft.it

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