---
title: "Vulnerability Handling and Disclosure"
canonical_url: "https://www.sorena.io/artifacts/eu/cyber-resilience-act/vulnerability-handling-and-disclosure"
source_url: "https://www.sorena.io/artifacts/eu/cyber-resilience-act/vulnerability-handling-and-disclosure"
author: "Sorena AI"
description: "Build a CRA vulnerability handling system that covers SBOM, intake, triage, remediation, coordinated vulnerability disclosure, secure updates."
published_at: "2026-03-04"
updated_at: "2026-03-11"
keywords:
  - "CRA vulnerability handling"
  - "CRA disclosure"
  - "CRA Annex I Part II"
  - "CRA coordinated vulnerability disclosure"
  - "CRA security updates"
  - "CRA integrated components"
  - "EU compliance"
  - "Cyber Resilience Act"
  - "CRA compliance"
  - "Vulnerability Handling and Disclosure"
  - "Products with digital elements"
---
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---

# Vulnerability Handling and Disclosure

Build a CRA vulnerability handling system that covers SBOM, intake, triage, remediation, coordinated vulnerability disclosure, secure updates.

*Artifact Guide* *EU*

## EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure

Grounded implementation guidance for legal, product, and engineering teams.

Use official CRA sources to translate obligations into owners, evidence, and shipping decisions.

The CRA turns vulnerability handling into a regulated product function. Annex I Part II expects manufacturers to know their components, handle vulnerabilities during the support period, maintain a coordinated vulnerability disclosure process, distribute updates securely, and tell users what was fixed and what action they should take.

## The mandatory CRA vulnerability-handling operating model in Annex I Part II

Part II is a live operations requirement. It asks manufacturers to identify components and vulnerabilities, address and remediate vulnerabilities without delay, perform regular security tests and reviews, disclose fixed vulnerabilities, run coordinated vulnerability disclosure, provide a reporting contact, and distribute security updates securely and without delay.

This model needs real tooling, roles, and decision records.

- SBOM plus component and vulnerability visibility
- Triage and remediation linked to product risk, not only scanner output
- Public information on fixed vulnerabilities with justified delay only in limited cases
- Secure update distribution and free security updates unless a tailor made business arrangement says otherwise

## How to interpret "without delay" in CRA vulnerability handling practice

The Commission FAQ says the CRA does not require a patch for every vulnerability, but it does require manufacturers to assess the risk and ensure remedies are put in place without delay. That means you need a documented method for deciding whether the correct response is a patch, another corrective measure, a mitigation, or if necessary a withdrawal or recall.

A good program separates speed from guesswork. Fast response should still be traceable.

- Define service levels by severity, exploitability, and exposure
- Record risk acceptance or no patch decisions with technical reasoning
- Escalate actively exploited vulnerabilities immediately into the Article 14 track
- Treat recurring deferrals as a governance issue, not a normal state

## CRA integrated components and upstream coordination

Component risk is still product risk. Article 13(6) requires manufacturers to report vulnerabilities in integrated components to the component maker or maintainer and, where appropriate, to share the security fix upstream. The March 2026 draft guidance adds practical limits: the duty concerns the integrated version of the component and the vulnerability must exist in the component itself, not only in the way the manufacturer combined it with other code.

The draft guidance also explains that manufacturers do not have to report upstream where the component no longer has a maintainer or where the manufacturer maintains an independent fork and no longer relies on upstream for new versions or security fixes. Where a fix is shared upstream, it should be in a form the maintainer can assess and integrate, but the CRA does not require the maintainer to accept it.

- Track which version of the component is integrated into each shipped product version
- Differentiate a component vulnerability from an integration defect in your own product architecture
- Store maintainer status, fork status, and the rationale if upstream reporting is not required
- Share upstream fixes in a verifiable machine-readable form where appropriate and keep the submission record

## What a good CRA vulnerability disclosure package contains

Once a security update or other corrective or mitigating measure is available, the CRA expects information about fixed vulnerabilities to be shared publicly with enough detail for users to identify the affected product, understand the impact, and remediate. If publication would create greater security risk, publication may be delayed, but that decision needs a documented and time bounded justification.

Use the same identifiers across the advisory, support content, and any Article 14 reporting.

- Affected product and version identifiers
- Description, impact, severity, and exploitation status where known
- Fix availability, mitigation steps, and customer action
- Publication date and links to update artifacts and support content

## Useful external process baselines for CRA vulnerability handling

The CRA does not mandate ISO or ENISA process models, but ISO/IEC 29147 and ISO/IEC 30111 are useful fair use reference points for disclosure and handling workflow design. ENISA guidance is also useful for building a disclosure policy that researchers can actually use.

Use these sources as process references, not as a substitute for the CRA text.

- Use ISO/IEC 29147 for public disclosure structure
- Use ISO/IEC 30111 for intake, verification, triage, and remediation workflow
- Use ENISA material for policy design and stakeholder communication
- Always map the final workflow back to Annex I Part II and Article 13

*Recommended next step*

*Placement: near the end of the main content before related guides*

## Turn EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure into an operational assessment

Assessment Autopilot can take EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure from turning this guidance into an operational assessment workflow to a reusable workflow inside Sorena. Teams working on EU Cyber Resilience Act, CRA Product Security and CE Marking can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

- [Open Assessment Autopilot for EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure](/solutions/assessment.md): Start from EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure and turn the guidance into owned tasks, evidence requests, and review checkpoints.
- [Talk through EU Cyber Resilience Act, CRA Product Security and CE Marking](/contact.md): Review your current process, evidence gaps, and next steps for EU Cyber Resilience Act, CRA Product Security and CE Marking Vulnerability Handling and Disclosure.

## Primary sources

- [Regulation (EU) 2024/2847, Cyber Resilience Act, Official Journal](https://eur-lex.europa.eu/eli/reg/2024/2847/oj/eng?ref=sorena.io) - Primary legal text for scope, manufacturer duties, reporting, conformity assessment, technical documentation, market surveillance, and penalties.
- [European Commission FAQ on the Cyber Resilience Act, version 1.2, January 2026](https://ec.europa.eu/newsroom/dae/redirection/document/122331?ref=sorena.io) - Practical implementation clarifications on scope, open source, support period, conformity assessment, reporting, and transition issues.
- [Draft Commission guidance on the application of the Cyber Resilience Act, March 2026 draft](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16959-Draft-Commission-guidance-on-the-Cyber-Resilience-Act_en?ref=sorena.io) - Draft Commission guidance with additional interpretation on Article 13(6) upstream reporting, independent forks, maintainer status, and vulnerability handling expectations.
- [ENISA vulnerability disclosure topic page](https://www.enisa.europa.eu/topics/vulnerability-disclosure?ref=sorena.io) - Practical supporting material for coordinated vulnerability disclosure design.
- [ISO/IEC 29147:2018, Vulnerability disclosure](https://www.iso.org/standard/72311.html?ref=sorena.io) - Process reference point for disclosure design, used here only as fair use background.
- [ISO/IEC 30111:2019, Vulnerability handling processes](https://www.iso.org/standard/69725.html?ref=sorena.io) - Process reference point for intake, triage, and remediation design, used here only as fair use background.

## Related Topic Guides

- [Applicability Test | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/applicability-test.md): Use this CRA applicability test to confirm product scope, exclusions, remote data processing boundaries, operator role, product classification.
- [Checklist | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/checklist.md): Use this Cyber Resilience Act checklist to assign owners, deadlines, evidence, and release gates for scope, Annex I controls, support period operations.
- [Compliance Program | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/compliance.md): Build a CRA compliance program that covers product scope, governance, engineering controls, support period operations, Article 14 reporting.
- [Conformity Assessment and CE Marking | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/conformity-assessment-and-ce-marking.md): Choose the right CRA conformity route, prepare the declaration of conformity, structure the technical file.
- [CRA Blue Guide Concepts FAQ | Placing on the Market, Making Available, Distance Sales](/artifacts/eu/cyber-resilience-act/faq/blue-guide-concepts.md): CRA FAQ on Blue Guide concepts used in Cyber Resilience Act interpretation: placing on the market, making available, putting into service, online sales.
- [CRA CE Marking FAQ | Meaning, Placement Rules, Software Labeling, Notified Bodies](/artifacts/eu/cyber-resilience-act/faq/ce-marking.md): CRA CE marking FAQ covering what the mark means, when it is mandatory, software and website placement rules, packaging fallback, notified body numbers.
- [CRA Component Due Diligence FAQ | Third-Party Components, FOSS, SBOM, Vulnerabilities](/artifacts/eu/cyber-resilience-act/faq/component-due-diligence.md): CRA component due diligence FAQ covering third-party components, FOSS, CE-marked components, SBOM review, risk-based checks, upstream vulnerability reporting.
- [CRA Conformity Assessment Routes FAQ | Module A, Module B+C, Module H, Critical and Important Products](/artifacts/eu/cyber-resilience-act/faq/conformity-assessment-routes.md): CRA FAQ on conformity assessment routes covering module A, module B+C, module H, important and critical products, harmonised standards, certification schemes.
- [CRA Core Functionality FAQ | Important Products, Critical Products, Classification](/artifacts/eu/cyber-resilience-act/faq/core-functionality.md): CRA FAQ on core functionality covering classification of important and critical products, ancillary functions, integrated components.
- [CRA Cybersecurity Risk Assessment FAQ | Article 13, Threat Modelling, Variants, Constraints](/artifacts/eu/cyber-resilience-act/faq/cybersecurity-risk-assessment.md): CRA FAQ on cybersecurity risk assessment covering Article 13, threat modelling, intended purpose, foreseeable misuse, external dependencies, documentation.
- [CRA Declaration of Conformity FAQ | Full vs Simplified, Languages, Updates, Duties](/artifacts/eu/cyber-resilience-act/faq/declaration-of-conformity.md): CRA FAQ on the EU declaration of conformity covering full and simplified formats, required contents, languages, updates, single declarations across EU laws.
- [CRA Economic Operators FAQ | Manufacturers, Importers, Distributors, Authorised Representatives](/artifacts/eu/cyber-resilience-act/faq/economic-operators.md): CRA FAQ on economic operators covering manufacturer, authorised representative, importer, distributor, responsible operator rules, checks, traceability.
- [CRA Essential Cybersecurity Requirements FAQ | Annex I Part I and Part II](/artifacts/eu/cyber-resilience-act/faq/essential-cybersecurity-requirements.md): CRA FAQ on the essential cybersecurity requirements covering Annex I Part I and Part II, applicability, evidence, interoperability constraints.
- [CRA FAQ Hub | Blue Guide Concepts, CE Marking, Component Due Diligence](/artifacts/eu/cyber-resilience-act/faq.md): Browse the CRA FAQ hub for Blue Guide market-access concepts, CE marking, and component due diligence.
- [CRA Hardware and Software Boundaries FAQ | Product Scope, Combined Products, Source Code](/artifacts/eu/cyber-resilience-act/faq/hardware-software-boundaries.md): CRA FAQ on hardware and software boundaries covering combined products, standalone software, source code, companion apps, remote data processing.
- [CRA Harmonised Standards and Common Specifications FAQ | Presumption of Conformity, OJ Publication](/artifacts/eu/cyber-resilience-act/faq/harmonised-standards-and-common-specifications.md): CRA FAQ on harmonised standards, common specifications, and certification schemes covering presumption of conformity, Official Journal publication.
- [CRA Important and Critical Products FAQ | Annex III, Annex IV, Core Functionality](/artifacts/eu/cyber-resilience-act/faq/important-and-critical-products.md): CRA FAQ on important and critical products covering Annex III and Annex IV classification, core functionality, conformity routes, FOSS rule limits.
- [CRA Integrated Components and Dependencies FAQ | Due Diligence, RDPS, Third-Party Components](/artifacts/eu/cyber-resilience-act/faq/integrated-components-and-dependencies.md): CRA FAQ on integrated components and dependencies covering due diligence, third-party components, RDPS, cloud dependencies, upstream fixes, FOSS dependencies.
- [CRA Interplay With Other EU Laws FAQ | RED, AI Act, GDPR, Data Act, EHDS, Machinery](/artifacts/eu/cyber-resilience-act/faq/interplay-with-other-eu-laws.md): CRA FAQ on interplay with other EU laws covering exclusions, overlap with RED, AI Act, GDPR, Data Act, EHDS, Machinery, GPSR, NIS2, aviation, marine.
- [CRA Known Exploitable Vulnerabilities at Launch FAQ | Placement on the Market, CVEs, Late Discoveries](/artifacts/eu/cyber-resilience-act/faq/known-exploitable-vulnerabilities-at-launch.md): CRA FAQ on known exploitable vulnerabilities at launch covering the launch-time rule, exploitability, known vulnerabilities, CVEs, compensating controls.
- [CRA Legacy Products FAQ | Pre-2027 Products, Reporting, Grandfathering, Substantial Modification](/artifacts/eu/cyber-resilience-act/faq/legacy-products.md): CRA FAQ on legacy products covering pre-11 December 2027 products, Article 14 reporting, continued sale, substantial modification, spare parts, old designs.
- [CRA Manufacturer Obligations FAQ | Article 13 Duties, Support Period, Reporting, Documentation](/artifacts/eu/cyber-resilience-act/faq/manufacturer-obligations.md): CRA FAQ on manufacturer obligations covering Article 13 duties, risk assessment, support periods, vulnerability handling, reporting, documentation.
- [CRA Market Surveillance and Enforcement FAQ | Authorities, Safeguards, Sweeps, Formal Non-Compliance](/artifacts/eu/cyber-resilience-act/faq/market-surveillance-and-enforcement.md): CRA FAQ on market surveillance and enforcement covering authorities, investigations, safeguard procedures, formal non-compliance, sweeps, joint activities.
- [CRA Module A FAQ | Internal Control, Self-Assessment, Eligibility, Documentation](/artifacts/eu/cyber-resilience-act/faq/module-a.md): CRA FAQ on module A covering internal control, eligible products, class I limits, FOSS exception, technical documentation, testing, CE marking.
- [CRA Module B+C FAQ | EU-Type Examination, Conformity to Type, Notified Bodies](/artifacts/eu/cyber-resilience-act/faq/module-b-c.md): CRA FAQ on module B+C covering EU-type examination, conformity to type, notified-body role, certificate changes, production control, CE marking.
- [CRA Module H FAQ | Full Quality Assurance, Notified Body Surveillance, CE Marking](/artifacts/eu/cyber-resilience-act/faq/module-h.md): CRA FAQ on module H covering full quality assurance, quality-system approval, notified-body surveillance, scope changes, CE marking, language rules, records.
- [CRA Notified Bodies FAQ | Notification, Scope, NANDO, Independence, Competence](/artifacts/eu/cyber-resilience-act/faq/notified-bodies.md): CRA FAQ on notified bodies covering notification, competence, independence, NANDO scope, accreditation, cross-border choice, subcontracting.
- [CRA Open-Source Software FAQ | FOSS, Commercial Activity, Stewards, Donations, Paid Editions](/artifacts/eu/cyber-resilience-act/faq/open-source-software.md): CRA FAQ on open-source software covering FOSS qualification, commercial activity, donations, paid support, stewards, contributors, repositories.
- [CRA Over-the-Air Updates FAQ | OTA, Automatic Updates, Secure Distribution, Offline Paths](/artifacts/eu/cyber-resilience-act/faq/over-the-air-updates.md): CRA FAQ on over-the-air updates covering OTA versus automatic updates, secure distribution, screenless products, gateways, offline update paths.
- [CRA Penalties and Fines FAQ | Fine Tiers, Turnover Caps, SME Carve-Outs, Stewards](/artifacts/eu/cyber-resilience-act/faq/penalties-and-fines.md): CRA FAQ on penalties and fines covering Article 64 fine tiers, turnover caps, SME carve-outs, steward exemptions, cumulative fines, criminal sanctions.
- [CRA Product Families FAQ | Variants, Shared Assessments, Family Reuse, Conformity Scope](/artifacts/eu/cyber-resilience-act/faq/product-families.md): CRA FAQ on product families covering shared risk assessments, family-wide documentation reuse, cybersecurity-relevant variant differences.
- [CRA Remote Data Processing Solutions FAQ | RDPS Scope, Cloud Services, SaaS Boundaries, Documentation](/artifacts/eu/cyber-resilience-act/faq/remote-data-processing-solutions.md): CRA FAQ on remote data processing solutions covering Article 3(2) RDPS tests, cloud-service boundaries, websites and portals, third-party SaaS, backend scope.
- [CRA Repairs and Spare Parts FAQ | Repairs, Refurbishment, Spare-Part Exemption, Compatibility](/artifacts/eu/cyber-resilience-act/faq/repairs-and-spare-parts.md): CRA FAQ on repairs and spare parts covering substantial modification, Article 2(6) identical spare parts, non-identical replacements.
- [CRA Reporting Obligations FAQ | Article 14 Deadlines, CSIRT Filing, User Notices, Legacy Products](/artifacts/eu/cyber-resilience-act/faq/reporting-obligations.md): CRA FAQ on reporting obligations covering Article 14 deadlines, actively exploited vulnerabilities, severe incidents, CSIRT routing, user notifications.
- [CRA Scope FAQ | Products with Digital Elements, Connections, Software, Exclusions](/artifacts/eu/cyber-resilience-act/faq/scope-and-products-with-digital-elements.md): CRA FAQ on scope and products with digital elements covering software, firmware, components, direct and indirect connections, offline products, exclusions.
- [CRA Secure-by-Default FAQ | Default Configuration, Auto Updates, Tailor-Made Limits](/artifacts/eu/cyber-resilience-act/faq/secure-by-default.md): CRA FAQ on secure by default covering Annex I default configuration, automatic security updates, opt-outs, components, inapplicability.
- [CRA Security Updates vs Functionality Updates FAQ | Separation, Free Updates, Article 13(10)](/artifacts/eu/cyber-resilience-act/faq/security-updates-vs-functionality-updates.md): CRA FAQ on security updates versus functionality updates covering separation where technically feasible, free security updates, automatic updates.
- [CRA Substantial Modification FAQ | Post-Market Changes, New Manufacturer, Legacy Products](/artifacts/eu/cyber-resilience-act/faq/substantial-modification.md): CRA FAQ on substantial modification covering Article 3(30), software updates, repairs, new manufacturer status, conformity reassessment.
- [CRA Support Period FAQ | Placement on the Market, Unit-Level Timing, Update Availability](/artifacts/eu/cyber-resilience-act/faq/support-period.md): CRA FAQ on support periods covering Article 13(8), placement on the market timing, unit-level support periods, standalone software, update availability.
- [CRA Tailor-Made Products FAQ | Business-User Exception, Paid Updates, Evidence](/artifacts/eu/cyber-resilience-act/faq/tailor-made-products.md): CRA FAQ on tailor-made products covering the narrow business-user carve-out, secure-by-default and paid-update deviations, required evidence.
- [CRA Technical Documentation FAQ | Annex VII, Languages, Authority Access, Updates](/artifacts/eu/cyber-resilience-act/faq/technical-documentation.md): CRA FAQ on technical documentation covering Annex VII content, timing, languages, versioning, authority access, reused documentation, simplified formats.
- [CRA Transition Period FAQ | Key Dates, Legacy Products, Pre-CRA Stock, RED Interplay](/artifacts/eu/cyber-resilience-act/faq/transition-period.md): CRA FAQ on the transition period covering entry into force, phased application dates, legacy products, stock and customs timing, standalone software.
- [CRA Update Availability and Archives FAQ | Article 13(9), Archives, Historical Versions](/artifacts/eu/cyber-resilience-act/faq/update-availability-and-archives.md): CRA FAQ on update availability and software archives covering Article 13(9), Article 13(10), Article 13(11), retention of issued security updates.
- [CRA User Information and Transparency FAQ | Annex II, Support Disclosure, User Notices](/artifacts/eu/cyber-resilience-act/faq/user-information-and-transparency.md): CRA FAQ on user information and transparency covering Annex II instructions, support-period disclosure, end-of-support notices, vulnerability notices.
- [CRA vs RED Cybersecurity Delegated Act | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/cra-vs-red-cybersecurity-delegated-act.md): Compare the Cyber Resilience Act with the RED cybersecurity delegated act so you can decide which products fall under which rule, what dates apply.
- [CRA vs UK PSTI Act | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/cra-vs-uk-psti-act.md): Compare the EU Cyber Resilience Act with the UK PSTI product security regime so your team can plan dual market compliance without mixing two different rule.
- [CRA Vulnerability Handling FAQ | Lifecycle Duties, Components, Disclosure, Fix Sharing](/artifacts/eu/cyber-resilience-act/faq/vulnerability-handling.md): CRA FAQ on vulnerability handling covering Annex I Part II duties, component vulnerabilities, upstream reporting and fix sharing.
- [Deadlines and Compliance Calendar | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/deadlines-and-compliance-calendar.md): Track the CRA entry into force date, the notified body date, the reporting start date, and the main application date.
- [Essential Cybersecurity Requirements | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/essential-cybersecurity-requirements.md): Understand the CRA essential cybersecurity requirements in Annex I.
- [Penalties and Fines | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/penalties-and-fines.md): Understand the CRA administrative fine tiers in Article 64, the conduct that attracts the highest penalties, and the evidence that reduces enforcement exposure.
- [Products with Digital Elements Scope | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/products-with-digital-elements-scope.md): Understand what counts as a product with digital elements under the CRA, how remote data processing fits, and where the scope boundary usually causes mistakes.
- [Reporting Obligations | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/reporting-obligations.md): Prepare for CRA Article 14 reporting, including the twenty four hour early warning, the seventy two hour notification, final reports, CSIRT routing.
- [Requirements | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/requirements.md): Review the full CRA requirement set, including manufacturer duties, operator duties, support period rules, user information, corrective action, reporting.
- [SBOM and Vulnerability Management Template | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/sbom-and-vulnerability-management-template.md): Use this CRA SBOM and vulnerability management template to structure dependency records, triage, remediation, advisory publication, and support period evidence.
- [Technical Documentation and Audit File | EU Cyber Resilience Act, CRA Product Security and CE Marking](/artifacts/eu/cyber-resilience-act/technical-documentation-and-audit-file.md): Build a CRA technical documentation file that covers product definition, risk assessment, support period, Annex I mapping, standards use, test evidence.


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