The Cyber Resilience Act's first deadline hits in September
- 2026-08-11 15:34On 11 September 2026, the Cyber Resilience Act starts requiring "manufacturers" to report any actively exploited vulnerability in their products within 24 hours. A full notification follows within 72 hours, then a final report within fourteen days. The obligation is not limited to future products: it covers the installed base, including a device shipped five years ago and still running at a customer site.
Which leaves the real question: who counts as a manufacturer? The word covers far more people than you would think. Whoever sells a plugin or a module. Whoever assembles a box with embedded software. Whoever ships an image or an appliance under their own brand. Hosting providers, integrators and end users do not qualify, and non-commercial open source falls outside the scope entirely. Here is the test that settles it, the situations where it applies, and what can still be done before the deadline.