The CRA Countdown: Your 2026-2027 Compliance Roadmap for EU Manufacturers

255 days until the first CRA deadline. 712 days until full enforcement.

We're at the end of December 2025. The clock is ticking, and for EU manufacturers in machinery and industrial equipment, the EU Cyber Resilience Act is no longer distant future music - the first critical deadline is in less than 9 months! Two fixed dates are set, and they're coming faster than most anticipated:

• September 11, 2026: Mandatory reporting of exploitable vulnerabilities to ENISA begins (in 8.5 months!)
• December 11, 2027: Full CRA requirements become enforceable (in 23.5 months)

If your products contain digital elements - and they probably do - you must be ready by these dates. No extensions, no exceptions, no mercy. The question is no longer if, but how you can still achieve compliance in this tight timeframe.

This roadmap shows you the way.

Understanding the Two Critical Milestones

Milestone 1: September 11, 2026 - Vulnerability Reporting Obligation

The first deadline is alarmingly close: only 8.5 months away! From September 11, 2026, manufacturers must report actively exploited vulnerabilities in their products to the European Union Agency for Cybersecurity (ENISA).

What does this mean in practice?

You must have functioning processes to:

• Continuously monitor vulnerabilities in your products
• Identify actively exploited vulnerabilities within 24 hours and submit the initial report
• Provide additional information within 72 hours (if available)
• Create final reports: 14 days for vulnerabilities (after update/workaround) or 1 month for severe incidents
• Monitor your entire supply chain for affected components

The CRA distinguishes between two scenarios:

1. Actively Exploited Vulnerabilities: Security gaps in your products that are already being abused by attackers. After providing a security update or workaround, you have 14 days for the final report.

2. Severe Security Incidents: Significant security events affecting your products. Here, a deadline of one month after the initial report applies for the final report.

These are not recommendations, but legal obligations. Missed reporting deadlines mean non-compliance with the CRA and corresponding consequences (fines up to 15 million euros or 2.5% of annual global revenue).

A practical example: Imagine a critical vulnerability is discovered in an open-source library used in your PLC firmware, and it's being actively exploited. You have:

• 24 hours to determine if your products are affected and submit the initial report to ENISA
• 72 hours to provide additional details (affected product versions, customer count, risk assessment)
• 14 days after providing your firmware update to submit the final report

Without automated systems, well-documented Software Bills of Materials (SBOMs), and structured processes, this multi-stage reporting obligation is virtually impossible to meet.

The hidden complexity: It's not enough to monitor only new vulnerabilities. You must keep track of all already deployed products retrospectively - potentially for decades. For a mid-sized manufacturer with hundreds of installed systems worldwide, this is an enormous challenge.

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CRA Reporting Deadlines Overview

For actively exploited vulnerabilities:

• 24 hours → Initial report to ENISA
• 72 hours → Additional information (if available)
• 14 days → Final report (after providing update/workaround)

For severe security incidents:

• 24 hours → Initial report to ENISA
• 72 hours → Additional information (if available)
• 1 month → Final report (after initial notification)

These deadlines apply from September 11, 2026 - only 8.5 months of preparation time left!

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Milestone 2: December 11, 2027 - Full Enforcement

December 11, 2027, is the day of reckoning. From this date, all new products with digital elements placed on the EU market must be fully CRA-compliant.

What's at stake?

• Market exclusion: Non-compliant products cannot be sold
• Fines: Up to 15 million euros or 2.5% of global annual revenue
• Reputation damage: Loss of trust with customers and partners
• Competitive disadvantage: While you catch up, compliant competitors gain market share

For a typical mid-sized machinery manufacturer with 50 million euros annual revenue, the fine could be up to 1.25 million euros - an existential sum. But the real damage lies in lost orders and damaged reputation as a reliable partner.

Why SMEs Are Particularly Affected

European small and medium-sized manufacturers face unique challenges:

Long Product Lifecycles: A machine tool or manufacturing system often runs for 20-30 years. You must provide security updates for this entire lifespan - a commitment that goes far beyond traditional maintenance contracts.

Limited IT Security Resources: Unlike large corporations, most SMEs don't have dedicated cybersecurity teams. The electrical engineer who handles IT security on the side isn't sufficient for CRA compliance.

Complex Supply Chains: Your products contain components from dozens of suppliers. Every single component must be monitored - a vulnerability in a third-party sensor can affect your entire system.

Legacy Systems: Many SMEs have product families that have been gradually developed over years or decades. Retrofitting Security by Design into these evolved systems is technically challenging and costly.

Your Emergency Roadmap Until September 2026

Until the first CRA deadline, you only have 8.5 months left - time is running out! If you haven't started yet, you must act immediately. Here's your accelerated roadmap to build vulnerability reporting infrastructure in time:

January-February 2026: Inventory and Foundations (Sprint!)

January 2026: Complete Product Inventory

• Catalog all products with digital elements
• Identify all software components and their versions
• Document third-party libraries and dependencies
• Classify products according to CRA risk categories (Standard/Important/Critical)

Practical tip: Start with your best-selling or newest product lines. Don't try to capture 40 years of product history at once.

February 2026: Initiate SBOM Creation & Select Monitoring System

• Choose an SBOM format (SPDX or CycloneDX)
• Implement tools for automatic SBOM generation in your build pipelines
• Create SBOMs for your prioritized product lines
• Establish version control for SBOMs
• In parallel: Evaluate solutions for continuous vulnerability monitoring
• Check integration with your existing systems
• Test pilot solutions with your SBOMs
• Make purchase decision and budget

SME Reality: You probably don't have sophisticated DevOps pipelines. Start with manual SBOMs for your most critical products and automate gradually. Given the time constraints: Consider external support!

Checkpoint End of February 2026: You should know what you have, where your risks lie, and which tools you need.

March-April 2026: Establish Processes and Activate Supply Chain

March 2026: Reporting Processes & Assessment Framework

• Create step-by-step procedures for ENISA reports
• Define processes for all three reporting phases: Initial report (24h), Additions (72h), Final report (14d/1m)
• Define responsibilities and escalation paths for each phase
• Establish communication templates for initial report, additions, and final report
• Identify external support (legal counsel, security experts)
• In parallel: Develop criteria for assessing exploitability
• Define thresholds for reporting obligations
• Create decision trees for quick assessments

Real scenario: A CVE with CVSS score 9.8 is published, but only affects configurations that don't exist in your products. Your framework must help you make this decision in hours, not days.

April 2026: Supply Chain Communication & Team Training

• Contact ALL critical suppliers IMMEDIATELY about CRA requirements
• Request SBOMs from component manufacturers
• Establish processes for vulnerability information from suppliers
• Update supplier contracts with CRA clauses
• Train your team in the assessment framework and reporting processes

Checkpoint End of April 2026: Your processes are defined and documented. Your team knows what to do in an emergency. Only 4.5 months left!

May-July 2026: Implementation, Testing, and Go-Live

May 2026: Monitoring System Implementation

• Full implementation of your vulnerability monitoring solution
• Integration with SBOM repositories
• Configuration of alert mechanisms
• Connection to vulnerability databases (NVD, etc.)
• No time for lengthy testing - choose a proven solution!

June 2026: Intensive Test Runs

• Conduct tabletop exercises with simulated vulnerabilities
• Test reporting processes (without actual ENISA reporting)
• Optimize based on exercise results
• Activate the system for selected product lines

Practice exercise: Simulate a Friday afternoon at 4:00 PM when a critical vulnerability becomes known. Can your team respond by Monday morning? What happens if the main responsible person is on vacation?

July 2026: Pilot Phase and Fine-Tuning

• Monitor false-positive and false-negative rates
• Refine assessment criteria
• Document lessons learned
• Expand to additional product lines

August-September 2026: Final Rollout and Readiness

August 2026: Complete Rollout

• Gradual expansion to ALL affected products
• Continuous process improvement
• Final team training and emergency exercises
• Complete documentation

Early September 2026: Final Countdown

• Last system checks and validations
• Confirmation of all responsibilities
• Finalize emergency contacts and backup plans
• You MUST be ready by September 11, 2026 - there is no postponement!

Critical Reality: If you only start in January 2026, you have NO buffer. Any delay jeopardizes your compliance. If time is tight: Get external help!

Your Extended Roadmap Until December 2027

While building vulnerability reporting, you must work in parallel on full CRA compliance. Here are the additional building blocks:

From Month 1: Implement Security by Design

The most fundamental requirement - and the most time-consuming - is integrating Security by Design into your product development.

Start immediately:

• Introduce threat modeling for new products
• Establish secure coding standards
• Implement security reviews in your development process
• Train developers in secure software development

Realistic timeframe: It takes 12-18 months for Security by Design to truly become anchored in corporate culture. New processes need time to mature.

From Month 6: Build Documentation

Technical documentation for conformity assessment:

• Security architecture documentation
• Risk assessments for each product
• Evidence of secure development process
• Vulnerability management procedures

SME tip: Create templates and examples for your first product, then scale. Don't try to document everything for all products simultaneously.

From Month 12: Secure Update Mechanisms

Critical infrastructure for product lifecycle:

• Secure boot and firmware verification
• Encrypted and authenticated updates
• Automatic notification systems
• Rollback mechanisms for failed updates

For products with 20+ years lifespan, this means: You commit to two decades of security updates. Plan infrastructure and resources accordingly.

From Month 18: Prepare Conformity Assessment

For critical and important products:

• Identify notified bodies for your product category
• Initial contact and requirements clarification
• Prepare technical documentation
• Budget planning for certification costs

Warning: Expect bottlenecks at notified bodies at the end of 2027. Companies that start early get appointments. Late starters wait in the queue.

Practical Implementation: A Machinery Manufacturing Example

Consider Mustermann Machine Tools GmbH, a fictional but typical mid-sized manufacturer:

Starting situation:

• 120 employees, 45 million euros annual revenue
• 3 main product lines: CNC milling machines, lathes, machining centers
• All products have PLC controllers, HMIs, and network interfaces
• About 500 installed systems worldwide, oldest from 2010
• IT team: 2 people (network and ERP)
• No dedicated security expertise

Their roadmap:

Q1 2025: CEO recognizes CRA urgency. External consultant conducts gap analysis. Result: "Critical - act immediately." Budget: 150,000 euros for year 1.

Q2 2025: Hiring a cybersecurity officer (50% position). Start SBOM creation for newest CNC line. Contact PLC suppliers for component SBOMs.

Q3 2025: Implementation of vulnerability monitoring solution (Kunnus platform by Think Ahead). First automated alerts for known CVEs. Training of 5 employees as "Security Champions."

Q4 2025: First complete SBOM for CNC line created. Vulnerability assessment framework defined. First tabletop exercise conducted - insight: processes need refinement.

Q1 2026: Rollout to second product line. Update mechanism implemented for new controllers. Problem discovered: legacy systems from before 2015 cannot receive over-the-air updates.

Q2 2026: Decision for legacy: manual update procedure with USB updates plus proactive customer information. Documentation for all three product lines 70% complete.

Q3 2026: System fully operational. On September 11, 2026, the reporting obligation takes effect - Mustermann is ready. First real ENISA report in October (critical vulnerability in Linux kernel, but not exploitable in their configurations after assessment).

Q4 2026 - Q4 2027: Focus on full CRA compliance. Security by Design integrated into all new projects. Documentation completed. First product receives certification from notified body in September 2027.

December 2027: New CNC line comes to market CRA-compliant. Marketing uses this as USP: "Certified secure machine tools." Two major contracts won because competitors aren't compliant yet.

Total costs: Approx. 400,000 euros over 3 years (personnel, tools, consulting, certification). First ROI through won contracts after just 8 months.

Avoiding the Biggest Pitfalls

From experience with early CRA implementations: Here are the mistakes you should avoid:

Mistake 1: Starting too late "We still have time" - we heard that often. Reality: Until the first deadline, it's only 8.5 months! Your product development cycles are longer than that. Products you design today will come to market in 2027 - and must be fully CRA-compliant.

Mistake 2: Underestimating the supply chain You're only as secure as your weakest component. If your sensor supplier isn't CRA-compliant, neither are you - regardless of your own efforts.

Mistake 3: Seeing SBOMs as a one-time task An SBOM is a living document. Every update, every patch, every configuration change requires an SBOM update. Without automation, this is impossible to manage.

Mistake 4: Seeing only IT security as the problem CRA compliance is a company-wide project. You need buy-in and resources from development, quality assurance, sales, legal, and management. An IT security officer alone can't handle it.

Mistake 5: Postponing documentation "We'll document later" doesn't work. If your developers are supposed to explain in 6 months why they made certain security decisions today, that will be difficult. Document continuously - you have no time for rework!

Mistake 6: Ignoring legacy products "The CRA only applies to new products" is true for market placement. But the vulnerability reporting obligation applies to all products on the market - even the 10-year-old systems still running at customer sites.

Why Kunnus Is the Right Partner

CRA compliance is a marathon task requiring specialized knowledge and continuous attention. For most SMEs, it's neither economical nor practical to build all needed competencies internally.

Kunnus (by Think Ahead) was developed specifically for this challenge:

CSAF-based Vulnerability Detection: Kunnus implements the CSAF standard (Common Security Advisory Framework) from BSI to detect actually exploitable vulnerabilities - not just theoretical CVEs. CSAF data is automatically loaded from your suppliers when available. This is the crucial difference: You're only informed about vulnerabilities that are truly dangerous in your specific context.

Supplier Assessment: Kunnus helps you systematically evaluate your suppliers - their security processes, vulnerability disclosure programs, and CRA readiness. This way you identify supply chain risks before they become problems.

Component Documentation: Capture and classify all components with digital elements according to CRA requirements. Automatic categorization into Standard/Important/Critical based on product characteristics.

SBOM Management: Create, version, archive, and distribute SBOMs (SPDX and CycloneDX) - all from one platform. Integration into your build pipelines for continuous updates.

Vulnerability Management: Continuous monitoring of your SBOMs against vulnerability databases with immediate notification of relevant threats. The system that helps you meet all CRA reporting deadlines (24h initial report, 72h additional information, 14 days final report).

Process and Policy Documentation: Document all CRA-relevant processes, policies, and security measures directly in Kunnus - exactly as notified bodies and regulatory authorities want to see them.

Reporting Process Support: Structured workflows for multi-stage ENISA reports (initial report, additions, final report) with templates, escalation paths, and emergency communication for all deadlines. In an emergency, you and your team know exactly what to do.

Reduced Effort: Our customers report 60-70% time savings in vulnerability management compared to manual processes. This means: Your few security experts can focus on strategic measures instead of administrative routine tasks.

Your Next Steps - Today

The countdown is running. Here's what you should do now:

This Week:

1. Take our free CRA readiness assessment - In 15-20 minutes, you'll receive an individual assessment of your CRA compliance gaps and concrete next steps for your situation.

Start free CRA assessment →

2. Share this article with your management, development lead, and sales director. CRA compliance needs support from the top.

3. Conduct an initial inventory - take 2 hours and list all products with software. This is step 1 of your 8-month emergency plan.

Next Week:

4. Book a free 30-minute consultation with our CRA experts. We will:
   • Assess your specific situation and product portfolio
   • Identify your biggest risks and priorities
   • Show you how Kunnus can reduce your compliance effort by 60%
   • Answer all your questions about CRA, deadlines, and implementation

Schedule consultation now →

Next Month:

5. Create your roadmap - based on this article and your consultation, develop a concrete 18-month plan with milestones, responsibilities, and budget.

6. Contact your suppliers - the earlier you start the conversation about CRA compliance, the better prepared you'll be.

The Competitive Advantage of Early Adopters

Compliance is more than risk minimization - it's an opportunity for differentiation.

Companies that start early benefit:

• Market positioning: "CRA-certified systems" becomes a selling point
• Customer loyalty: Major customers with strict security requirements prefer compliant suppliers
• Higher margins: Security justifies premium prices
• Less stress: No last-minute emergency project at the end of 2027
• Better products: Security by Design leads to more stable, reliable software

Companies that start too late risk:

• Missed deadline and market exclusion
• Overloaded notified bodies with no capacity
• Panic last-minute investments
• Lost contracts to earlier compliant competitors
• Reputation damage as an "insecure" brand

The Time to Act Is Now

255 days until the first deadline. Only 8.5 months left. Every day you wait makes the task harder.

The CRA is non-negotiable. The deadlines are fixed. The requirements are extensive. But the path to compliance doesn't have to be chaotic or overwhelming.

With the right plan, the right tools, and the right partner, you can not only achieve compliance on time - you can transform this regulatory requirement into a real competitive advantage.

The question is: Do you want to be among the winners who are ready on December 11, 2027, and gain market share? Or among those desperately asking for delays that won't come?

Kunnus helps you be on the right side.

Start your CRA compliance journey today →

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About Kunnus & Think Ahead: Think Ahead specializes in CRA compliance solutions for European SMEs in machinery and industrial equipment manufacturing. Kunnus, our platform, implements the CSAF standard for precise vulnerability detection and offers integrated SBOM management, supplier assessment, process documentation, and reporting process support. Developed for manufacturers with long product lifecycles and limited security resources. More than 60% effort reduction with full compliance documentation - that's our promise.