December 11 2027: full application
From December 11 2027, every product with digital elements placed on the EU market must comply with the CRA in full. Without compliance, there is no CE marking, and without CE marking, there is no EU market access.
What becomes mandatory
- The 21 essential requirements in Annex I: 13 product security requirements in Part I and 8 vulnerability handling requirements in Part II
- Conformity assessment through the procedure that matches your product's classification
- Technical documentation under Annex VII, covering design, risk assessment, and vulnerability handling
- The EU declaration of conformity, in which you take responsibility for compliance
- CE marking on the product, showing it meets the CRA
How much lead time this really needs
Work backwards from December 2027, and the window is shorter than it looks. Your conformity assessment has to finish before that date, and it needs complete evidence to assess. That evidence comes from security work built into your development process, not added at the end.
If your product needs a notified body, add the time it takes to secure a slot, complete the assessment, and fix any findings. For many teams, that means the work needs to be underway now.
What the timeline means for products already on the market
The Article 69 cut-off
Under Article 69(2), products placed on the market before December 11 2027 fall under the CRA only if they are substantially modified from that date. A product you placed on the market in 2026 and leave unchanged doesn't need CE marking under the CRA.
What counts as a substantial modification
Article 3(30) defines a substantial modification as a change that affects compliance with the essential requirements in Annex I Part I, or transforms the product's intended purpose. For example:
- Counts as a substantial modification: You add remote cloud access to an industrial controller that previously worked only on a closed local network. The attack surface changes, so the original security assessment no longer holds.
- Doesn't count as a substantial modification: You ship a security update that fixes a vulnerability without changing the product's functions or intended purpose. Patching keeps the product secure; it doesn't make it a new product.
The exception: reporting applies to all legacy products
Article 69(3) makes an exception. By derogation from Article 69(2), the Article 14 reporting obligations apply to all in-scope products placed on the market before December 11 2027.
What this means in practice: if a product you sold in 2022 has an actively exploited vulnerability today, you must send an early warning within 24 hours of becoming aware. No modification, CE marking, or new sale is needed to trigger that duty.
The Cyber Resilience Act timeline after 2027
Full application is not the end of the timeline. Three later dates matter for certification, reporting, and the future shape of the Regulation.
June 11 2028: legacy certificates expire
Under Article 69(1), EU-type examination certificates and approval decisions on cybersecurity requirements issued under other Union harmonization legislation stay valid until June 11 2028. That holds unless they expire earlier or the other legislation says otherwise.
This matters if you are already certified under the Radio Equipment Directive's cybersecurity requirements or under machinery law. Your existing certificate buys you six months beyond full application. Plan your CRA assessment so it is complete before that certificate lapses.
September 11 2028: Commission report on the reporting platform
By September 11 2028, the Commission needs to report to the European Parliament and the Council on how well the Article 16 single reporting platform works.
December 11 2030: first evaluation of the Regulation
By December 11 2030, the Commission needs to submit its first evaluation and review report under Article 70(1). Further reports would follow every four years, with each one made public. This is where the annexes, product categories, or deadlines could be changed.
What the CRA timeline means for UK manufacturers
If you sell products with digital elements into the EU, every date still applies to you.
Why these dates apply to you regardless of Brexit
The CRA binds anyone who places products with digital elements on the EU market, not only manufacturers established in the EU. A UK manufacturer selling a connected device in Germany has the same essential requirements, reporting duties, and the December 2027 deadline as a German one.
Under Article 18, you can appoint an EU authorized representative by written mandate to carry out specific tasks on your behalf. If you don't, your EU importers must verify your compliance before they place your products on the market. Either way, finding the right partner and agreeing on who does what takes months. Treat it as a lead-time item of its own.
How the CRA sits alongside UK cyber legislation
Status as of October 9 2026. The UK's Cyber Security and Resilience (Network and Information Systems) Bill updates the NIS Regulations 2018. It was introduced in the House of Commons on November 12 2025 and completed its Commons stages on June 16 2026. Lords committee stage began on September 1 2026, and Lords report stage is scheduled for October 26 2026. It is not yet law.
The two are separate regimes with separate scopes. The UK bill regulates organizations that run essential and digital services, such as energy, healthcare, data centers, and managed service providers. The CRA regulates products.
A UK company can fall under both: once as a service operator in the UK, and once as a manufacturer selling into the EU. On the product side, the UK's own rules sit in the Product Security and Telecommunications Infrastructure (PSTI) regime for consumer connectable products, which has applied since April 29 2024.
What a UK manufacturer should do first
- Map your EU sales. List every product with digital elements you place on the EU market, and confirm which are in scope
- Set up CRA reporting now. It has applied since September 11 2026, including for products you already sell. Align it with your UK incident processes so one event doesn't need two separate reactions
- Decide on your EU representation. Appoint an authorized representative or agree on responsibilities with your importers
- Build one evidence base for both regimes. Reuse risk assessments, security testing, and vulnerability handling records across the CRA, PSTI, and UK NIS work where the requirements overlap
What missing a CRA deadline costs
Missing a CRA deadline can cost you a fine of up to EUR 15 million. For most manufacturers, losing access to the EU market costs more.
Fines
Under Article 64(2), breaches of the essential requirements in Annex I and of the manufacturer obligations in Articles 13 and 14 carry fines of up to EUR 15 million or 2.5% of total worldwide annual turnover for the preceding financial year, whichever is higher. Article 14 is the reporting obligation, so this ceiling already applies today.
The micro and small enterprise exception
Article 64(10) protects the smallest manufacturers on one point. Microenterprises and small enterprises face no administrative fine for missing the 24-hour early warning deadline specifically. The 72-hour notification and the final report are not covered by this exception.
Company size also counts beyond that. Under Article 64(5), authorities must take the size and market share of the operator into account when setting any fine, with particular regard to microenterprises and SMEs.
The bigger risk: market withdrawal
Market surveillance authorities can require you to bring a non-compliant product into compliance, withdraw it from the market, or recall it. For most manufacturers, a product pulled from the EU market costs more than the maximum fine. Lost revenue, recall logistics, and damaged customer trust add up fast, and they keep adding up until the product is compliant again.