CRA vs NIS2 — when both apply and how to handle the overlap

CRA reporting concerns product vulnerabilities and severe product-security incidents. NIS2 reporting depends on covered entity/service scope and its significant-incident rules and national implementation. GDPR concerns personal-data breach risk. One event may trigger more than one regime, but a CRA report does not automatically satisfy the others. Assess each trigger and deadline separately; the CRA vulnerability 14-day final deadline is not the severe-incident deadline.

Two reporting paths and final triggers

Manufacturers report actively exploited vulnerabilities and severe security incidents through the Single Reporting Platform. Both have 24-hour early warnings and 72-hour notifications from awareness. Article 14(2)(c): vulnerability final report within 14 days after a corrective or mitigating measure becomes available. Article 14(4)(c): severe-incident final report within one month after the 72-hour notification. Severity criteria are Article 14(5), not Annex VI. Do not invent a fixed monthly progress-report duty. Manufacturer reporting applies from 11 September 2026. The ENISA platform is operational.

Personal-data breach notification

A controller notifies the supervisory authority without undue delay and where feasible within 72 hours after awareness, unless unlikely to result in a risk to rights and freedoms. This is distinct from CRA product reporting and NIS2 incident obligations. Document assessment; do not state every security or personal-data incident must automatically be reported.

Evidence to keep with the product

Record the intended purpose, responsible economic operator, target market, first placing date and exact hardware/firmware configuration. For each applicable requirement, link the actual test or assessment record, dated standard/specification, scope and reviewer decision. Proposed controls and supplier marketing statements are not evidence that the final configuration has passed an assessment.

Separate an open question from a completed assessment. A report outside the laboratory's relevant scope, a different firmware build or an unverified exemption needs a reasoned decision before it supports a declaration. Keep original evidence and the issued declaration alongside any AI-assisted working draft.

Using Cenitia for this work

Cenitia assists with a limited regulatory catalogue and draft documents. The manufacturer must confirm applicability, actual applied specifications and completed assessment procedures. AI scores are quality signals, not a probability of conformity. Source monitoring raises a review prompt when validated source text changes; it does not automatically verify amendments, update the corpus or monitor every national rule and OJ standard edition. Public QR verification records issuance, not product certification.

Review status

This guide was substantively corrected by Cenitia on 2 October 2026 using the primary references below. It is an editorial summary, not an authoritative legal quotation or an independently signed expert opinion. Product-specific and licensed-standard questions remain subject to a real technical review.

Primary references

• Primary source 1
• Primary source 2