CRA: Vulnerability Management and Vulnerability Disclosure
The Cyber Resilience Act requires a continuous, traceable approach to vulnerability management. GObugfree supports companies with VDP, bug bounty programs, triage, and traceable reporting.
The first mandatory reporting requirement takes effect on September 11, 2026: Manufacturers must report actively exploited vulnerabilities and serious security incidents within 24 hours of becoming aware of them.
Are you affected?
The CRA may be relevant to you if you:
- distribute products with digital elements in the EU
- are part of a supply chain with EU relevance
- develop, integrate or operate software, connected systems or digital components
The CRA Timeline
- CRA takes effect: December 10, 2024
- First reporting requirements take effect: September 11, 2026 (actively exploited vulnerabilities, serious incidents)
- Key requirements become mandatory: December 11, 2027 (secure development, vulnerability management, documentation)
From point-in-time testing to a continuous process
The CRA shifts the focus: security is no longer just a periodic assessment, but an ongoing process across the entire product lifecycle. What matters is that vulnerabilities are identified, assessed, remediated and documented.
| Traditional approach | CRA perspective |
|---|---|
| Periodic testin | Continuous monitoring |
| Audit-driven | Risk- and vulnerability-driven |
| Documentation added afterwards | Evidence as an integral part |
How VDP and Bug Bounty support this
In Recital 76, the regulation explicitly mentions bug bounty programs as a possible component of coordinated vulnerability disclosure processes.
- VDP: A structured channel for incoming vulnerability reports
- Bug Bounty: Continuous external visibility through security researchers
- Triage: Validation, prioritisation and quality assurance of findings
- Reporting: Traceable documentation for internal governance and audits
Implementing vulnerability management in a controlled way
We support vulnerability management and external security testing in the context of the CRA. The focus is on a structured, traceable approach to vulnerabilities, from reporting to validation and prioritisation through to documented remediation.
- Clearly defined scope: Which systems and digital components are tested
- Validated findings: Relevant reports are reviewed, prioritised and presented in a clear, actionable format
- Traceable evidence: Validated findings, prioritisation and recommended measures are documented in a structured way
- Controlled process: VDP, bug bounty or testing are set up to fit your organisation
GObugfree is ISO 27001-certified and operates a Swiss platform for structured vulnerability management.
Your question on CRA and vulnerability management
Would you like to know whether VDP, a bug bounty program, or a structured testing approach is right for your situation? Send us a quick note describing your current situation. We’ll get back to you with an initial assessment.