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Cyber Resilience Act · Article 14 · Applies 11 September 2026
SBOM, exploitation intelligence, risk exceptions and remediation are one pipeline in Phoenix, not four compliance projects.
ARTICLE 14 · TIME REMAINING
What is CRA?
The Cyber Resilience Act (CRA) is an EU law, not a guideline or a best-practice framework. It applies to anyone who manufactures software or hardware with digital elements sold into the EU, and it requires them to build in security by design and report actively exploited vulnerabilities on a strict clock. It entered into force in December 2024. Its reporting obligations, the part that actually bites, apply from 11 September 2026.
Why Now?
Most manufacturers already generate an SBOM for customers. On 11 September, that's the floor, not the finish line.
Publishing a component list without an exploitability answer means every CVE match turns into a customer support ticket, with your name on the false positives.
Your risk exception register already makes these calls: not reachable, mitigated, accepted, fixed. It just needs a place to be signed and filed.
What Should You Do?
If any of this sounds like you, the clock already applies, and the sooner you know, the more of the 24 hours you actually have.
How can Phoenix help?
Exploitation evidence lands, or a malicious package is confirmed. Campaign and repeat-offender context attaches to the verdict.
OrangeAffected products, versions and owners resolved through the build-file pivot and ownership attribution.
Purple
OrangeReachability and exposure assessed. Exploitability position drafted against the affected component.
OrangeEarly warning filed through the ENISA Single Reporting Platform from the register.
GreenFix bundle or compensating control identified. Corrective and mitigating measures stated.
Green
OrangeCorrective measure shipped, exception records reconciled, final report filed.
Next step
Run the 24-hour tabletop against an event from your own history, using a malicious-package incident rather than a CVE, since that is the trigger most programmes cannot see.
ARTICLE 14 · TIME REMAINING
Regulation vs. time-to-report / time-to-fix
The CRA is one clock among several. Here is how it stacks up against NIS2, DORA, the AI Act, and the equivalent US and UK regimes.
| Regime | Report clock | Fix clock | Effective | Binding on |
|---|---|---|---|---|
| EU CRA (Art. 14) | 24h → 72h → 14d (1 month severe) | risk-based ("without undue delay") | 11 Sep 2026 (rules); 11 Dec 2027 (full/SBOM) | Product manufacturers |
| EU NIS2 (Art. 23) | 24h → 72h → 1 month | none (risk-based, Art. 21) | 17 Oct 2024 (varies by state) | Essential/important entities |
| EU DORA (Art. 19) | 4h from classification (≤24h from awareness) → 72h → 1 month | entity-set deadlines (RTS 2024/1774 Art. 10) | 17 Jan 2025 | Financial entities + critical ICT TPPs |
| EU AI Act (Art. 73) | 15d general / 10d death / 2d critical infra | risk-based | 2 Aug 2026 (high-risk) | High-risk AI providers |
| US CISA BOD 26-04 | n/a (patch directive) | 3d / 14d / 60d / defer | 10 Jun 2026 (full 7 Dec 2026) | FCEB agencies (de facto private) |
| US FedRAMP 20x VDR | n/a | PAIN matrix 2–192d + KEV due dates | mandatory 7 Dec 2026 | Cloud service providers |
| UK FCA SUP 15.3 | "immediately" (qualitative) | none | current | FCA-regulated firms |
| UK FCA PS26/2 | threshold-based, phased | none | 18 Mar 2027 | Almost all FCA/PRA/BoE firms |
| UK CSR Bill | 24h → 72h | TBD | not yet in force | OES/RMSPs/data centres |
Derek Fisher – Head of product security at a global fintech. Speaker, instructor, and author in application security.
Derek is an award winning author of a children’s book series in cybersecurity as well as the author of “The Application Security Handbook.” He is a university instructor at Temple University where he teaches software development security to undergraduate and graduate students. He is a speaker on topics in the cybersecurity space and has led teams, large and small, at organizations in the healthcare and financial industries. He has built and matured information security teams as well as implemented organizational information security strategies to reduce the organizations risk.
Derek got his start in the hardware engineering space where he learned about designing circuits and building assemblies for commercial and military applications. He later pursued a computer science degree in order to advance a career in software development. This is where Derek was introduced to cybersecurity and soon caught the bug. He found a mentor to help him grow in cybersecurity and then pursued a graduate degree in the subject.
Since then Derek has worked in the product security space as an architect and leader. He has led teams to deliver more secure software in organizations from multiple industries. His focus has been to raise the security awareness of the engineering organization while maintaining a practice of secure code development, delivery, and operations.
In his role, Jeevan handles a range of tasks, from architecting security solutions to collaborating with Engineering Leadership to address security vulnerabilities at scale and embed security into the fabric of the organization.
Jeevan Singh is the Director of Security Engineering at Rippling, with a background spanning various Engineering and Security leadership roles over the course of his career. He’s dedicated to the integration of security practices into software development, working to create a security-aware culture within organizations and imparting security best practices to the team.
In his role, Jeevan handles a range of tasks, from architecting security solutions to collaborating with Engineering Leadership to address security vulnerabilities at scale and embed security into the fabric of the organization.
James Berthoty has over ten years of experience across product and security domains. He founded Latio Tech to help companies find the right security tools for their needs without vendor bias.
Chris Romeo is a leading voice and thinker in application security, threat modeling, and security champions and the CEO of Devici and General Partner at Kerr Ventures. Chris hosts the award-winning “Application Security Podcast,” “The Security Table,” and “The Threat Modeling Podcast” and is a highly rated industry speaker and trainer, featured at the RSA Conference, the AppSec Village @ DefCon, OWASP Global AppSec, ISC2 Security Congress, InfoSec World and All Day DevOps. Chris founded Security Journey, a security education company, leading to an exit in 2022. Chris was the Chief Security Advocate at Cisco, spreading security knowledge through education and champion programs. Chris has twenty-six years of security experience, holding positions across the gamut, including application security, security engineering, incident response, and various Executive roles. Chris holds the CISSP and CSSLP certifications.
Jim Manico is the founder of Manicode Security, where he trains software developers on secure coding and security engineering. Jim is also the founder of Brakeman Security, Inc. and an investor/advisor for Signal Sciences. He is the author of Iron-Clad Java: Building Secure Web Applications (McGraw-Hill), a frequent speaker on secure software practices, and a member of the JavaOne Rockstar speaker community. Jim is also a volunteer for and former board member of the OWASP foundation.
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