When does the Cyber Resilience Act apply?

The CRA entered into force on 10 December 2024, so it is already law. What changes across the next two years is which obligations are active (Art. 71): **11 September 2026 — the first hard deadline.** From this date, manufacturers must report actively exploited vulnerabilities and severe incidents through the ENISA single reporting platform. This obligation is retroactive in scope: it applies to all products currently available on the EU market, including those placed there before the CRA was adopted. A legacy device that predates the regulation is still subject to the reporting duty if it is actively exploited on or after 11 September 2026. This is the "legacy trap" -- teams that treat the 2027 conformity deadline as the real start line risk being caught by the earlier reporting obligation on products they consider grandfathered. **11 December 2027 — the main implementation date.** All essential requirements from Annex I apply: secure by design and by default, free of known exploitable vulnerabilities at release, vulnerability-handling process, SBOM, support-period updates, technical documentation, conformity assessment, EU declaration of conformity and CE marking. **Products already on the market.** A product placed on the market before 11 December 2027 does not require a full CRA conformity assessment unless it undergoes a substantial modification that changes its risk profile. However, the reporting duty from September 2026 reaches back to existing products. For a product team, the practical sequence is: start the classification and conformity-assessment work now (it takes longer than most teams expect), and build the incident-detection and 24-hour escalation process as a separate track, so it is ready well before September 2026 and covers the legacy product estate.