EU Cyber Resilience Act Reporting for Industrial Equipment

Last reviewed: September 5, 2026

EU Cyber Resilience Act reporting for industrial equipment starts September 11

Regulation (EU) 2024/2847, known as the Cyber Resilience Act or CRA, creates horizontal cybersecurity requirements for products with digital elements made available on the EU market. The European Commission explains that the framework covers hardware and software products and can include components placed separately on the market.

Article 14 applies from September 11, 2026. For an in-scope product, a manufacturer must notify two defined types of occurrence through the Single Reporting Platform established and maintained by the European Union Agency for Cybersecurity, ENISA:

• an actively exploited vulnerability, where reliable evidence shows that a malicious actor has exploited the vulnerability; and
• a severe incident having an impact on the security of the product with digital elements.

The first notification is an early warning due within 24 hours after the manufacturer becomes aware. A fuller notification follows within 72 hours. The Commission's current reporting guidance states that the final report for an actively exploited vulnerability is due no later than 14 days after a corrective or mitigating measure becomes available. For a severe incident, the final report is due within one month after the 72-hour notification.

Article 14 places these reporting duties on the manufacturer. The buyer should identify the legal manufacturer, security contact and escalation route rather than assume that a purchaser, installer or distributor is the reporter.

Three CRA dates buyers should keep separate

The Commission summary also states that Article 14 reporting applies to in-scope products with digital elements already made available on the EU market, including products placed before December 11, 2027. Buyers should therefore not treat 2027 as permission to ignore reporting readiness for an installed or previously supplied connected product.

Does the CRA apply to every item of industrial equipment?

No. The phrase "industrial equipment" does not decide CRA scope. Article 2 focuses on products with digital elements made available on the EU market whose intended or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. The Regulation also contains exclusions and interactions with other Union legislation.

A buyer can begin a scope review with five questions:

1. Does the exact product include hardware or software with a digital function?
2. Does its intended or reasonably foreseeable use include a direct or indirect data connection?
3. Is that product or a separately marketed digital component being made available on the EU market?
4. Which company is the legal manufacturer, and which importer or distributor roles exist in the supply chain?
5. Does a specific exclusion, sector rule or other Union act change how the CRA applies?

These questions are a screening tool, not a legal conclusion. Do not classify a conventional component as a product with digital elements merely because it operates in an automated plant. Review the exact hardware, software, connectivity and intended-use documents.

CRA, ATEX, IECEx and machinery rules answer different questions

The MMAIATEX guides to ATEX and the EU Machinery Regulation and ATEX 114 and ATEX 153 responsibilities explain why overlapping EU regimes and workplace duties must be assessed separately. Buyers can also review ATEX versus IECEx and the checklist for verifying IECEx certificates and ATEX documents.

None substitutes for a CRA scope decision. A CRA process also does not establish an Ex marking, certificate scope or hazardous-area suitability.

A procurement checklist before September 11

For a product that may be in scope, industrial buyers can ask the manufacturer for a concise, auditable response to the following points:

• the exact product, version and connected functions covered by the response, together with the manufacturer's CRA scope rationale;
• the named route for customers and field personnel to report a suspected vulnerability or product-security incident;
• the team responsible for determining whether an occurrence is an actively exploited vulnerability or severe security incident;
• readiness to submit the 24-hour early warning, 72-hour notification and applicable final report through the Single Reporting Platform;
• the process for issuing corrective or mitigating measures and communicating them to users; and
• the documented responsibilities of the manufacturer and other economic operators in the actual transaction.

The answer should identify controlled documents and responsible organisations. A general statement such as "cyber secure," a CE mark, an ATEX document, an IECEx certificate or a product photograph is not evidence that the Article 14 workflow is operational.

What buyers should record after delivery

Keep the exact product and version identity, supplier security contact, installation location, updates and corrective measures. Report suspected product-security issues through the manufacturer's published contact. ENISA guidance can change during implementation, so use the current Commission and ENISA pages instead of an undated third-party checklist.

Current MMAIATEX certification status and CRA boundary

This guide also makes no claim that a current MMAIATEX product is a product with digital elements, is within CRA scope, has completed CRA conformity assessment or is ready for Article 14 reporting. Buyers must request current written information for the exact configuration and intended EU transaction.

Safety and legal disclaimer

Official sources

• Regulation (EU) 2024/2847, official EUR-Lex text
• European Commission CRA reporting obligations
• European Commission summary of the Cyber Resilience Act
• European Commission implementation guidance
• ENISA Single Reporting Platform