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CRA Reporting Playbook Template
Cyber Resilience Act, Article 14 Incident Reporting Procedures
Customize for your organization's product portfolio and incident response team
Regulatory reference: Regulation (EU) 2024/2847 (Cyber Resilience Act), Article 14, Obligations of manufacturers in relation to vulnerabilities and incidents.
Organization Information
CRA Compliance Lead (name, title, contact)
Products with Digital Elements (list all EU-market products)
Internal Incident Response Team Lead
24h Initial Notification Procedure
Article 14.1, Report to national CSIRT within 24 hours of becoming aware of an actively exploited vulnerability or incident.
Trigger Criteria
- Actively exploited vulnerability identified in a product with digital elements
- Security incident affecting a product placed on the EU market
- Threat intelligence indicates active exploitation of a vulnerability in your product
- Customer report of a security incident with evidence of active exploitation
24h Notification Workflow
| Step | Owner | Action | Timeline |
| 1 | [SOC / On-call engineer] | Confirm active exploitation, validate against trigger criteria | T+0h to T+2h |
| 2 | [IR Team Lead] | Activate incident response, assign severity and incident commander | T+1h to T+3h |
| 3 | [Compliance Lead] | Draft initial notification using CSIRT template (Annex A) | T+2h to T+8h |
| 4 | [Legal / DPO] | Review notification for accuracy and regulatory completeness | T+8h to T+16h |
| 5 | [Compliance Lead] | Submit to national CSIRT via established channel | T+16h to T+24h |
| 6 | [IR Team Lead] | Internal status broadcast to executive team | T+24h |
24h Notification Content Requirements
- Organization name and contact details
- Product(s) affected (name, version, EU market placement date)
- Nature of the vulnerability or incident
- Known or likely impact on users
- Initial remediation measures taken or planned
- Point of contact for follow-up communication
72h Substantial Incident Report
Article 14.2, Detailed report within 72 hours when incident is assessed as substantial.
Substantial Incident Criteria
- Incident affects or may affect multiple users or operators
- Significant disruption to availability, integrity, or confidentiality
- Cross-border impact (affects users in multiple EU member states)
- Requires coordinated response across organizational boundaries
72h Report Workflow
| Step | Owner | Action | Timeline |
| 1 | [IR Commander] | Severity classification, determine if substantial per criteria above | T+24h to T+30h |
| 2 | [Engineering Lead] | Technical analysis, root cause hypothesis, affected components, blast radius | T+24h to T+48h |
| 3 | [Compliance Lead] | Draft substantial incident report (Annex B) | T+36h to T+60h |
| 4 | [Legal / Executive] | Review and approve report | T+60h to T+66h |
| 5 | [Compliance Lead] | Submit to CSIRT with updated impact assessment | T+66h to T+72h |
72h Report Content Requirements
- Updated status of the vulnerability/incident since 24h notification
- Impact assessment, number of affected users, geographic scope
- Technical root cause analysis (preliminary)
- Remediation status, patches deployed, workarounds in place
- Risk assessment for remaining exposure
- Coordination with other CSIRTs or national authorities (if applicable)
14d Significant Incident Final Report
Article 14.3, Comprehensive report within 14 days for significant incidents. Submitted to CSIRT and ENISA.
Significant Incident Criteria
- Incident has or may have a significant impact on the digital ecosystem
- Large-scale disruption of essential services
- Incident involving critical infrastructure or essential products
- CSIRT or ENISA has classified the incident as significant
14-Day Report Workflow
| Step | Owner | Action | Timeline |
| 1 | [IR Commander] | Confirm significant classification with CSIRT | T+72h to T+96h |
| 2 | [Engineering Team] | Complete root cause analysis, full technical timeline | T+72h to T+7d |
| 3 | [Engineering Lead] | Develop and test permanent remediation | T+3d to T+10d |
| 4 | [Compliance Lead] | Draft significant incident report (Annex C) with ENISA template | T+7d to T+12d |
| 5 | [Legal / Executive] | Final review and executive sign-off | T+12d to T+13d |
| 6 | [Compliance Lead] | Submit to CSIRT and ENISA via established channels | T+13d to T+14d |
| 7 | [IR Commander] | Post-incident review, capture lessons learned | T+14d to T+21d |
14-Day Report Content Requirements
- Complete incident timeline from detection to remediation
- Final root cause analysis with evidence
- Full impact assessment, users, products, geographic scope
- Permanent remediation measures implemented
- Preventive measures to avoid recurrence
- Coordination summary with CSIRTs, ENISA, and other authorities
- Lessons learned and process improvements identified
CSIRT Contact Matrix
Populate with your national CSIRT and relevant EU member state CSIRTs where your products are distributed.
| CSIRT | Country | Contact Email | Reporting Portal | Phone (24/7) |
| [National CSIRT] | [Country] | [email] | [URL] | [phone] |
| [CSIRT 2] | [Country] | [email] | [URL] | [phone] |
| [CSIRT 3] | [Country] | [email] | [URL] | [phone] |
| ENISA | EU | incident@enisa.europa.eu | https://www.enisa.europa.eu | , |
ENISA Submission Checklist
- Organization registered in ENISA incident reporting portal
- CRA Compliance Lead has portal access credentials
- Incident report template pre-configured with organization details
- Notification channels tested (email confirmation received from CSIRT)
- Incident report reviewed by legal counsel before submission
- Copy of all submissions retained in incident register for 5 years
- Follow-up communication timeline documented per CSIRT requirements
Internal Escalation Matrix
| Role | Name | Contact | Escalation Trigger |
| On-call Engineer | [Name] | [Phone / PagerDuty] | All incidents, first responder |
| IR Team Lead | [Name] | [Phone] | Any confirmed active exploitation |
| CRA Compliance Lead | [Name] | [Phone] | 24h notification threshold reached |
| VP Engineering | [Name] | [Phone] | Substantial incident classification |
| General Counsel | [Name] | [Phone] | Significant incident / ENISA submission |
| CEO | [Name] | [Phone] | Cross-border impact / media exposure |
Document Control
| Field | Value |
| Version | 1.0, Template |
| Last Updated | June 2026 |
| Next Review | September 2026 (CRA enforcement date) |
| Classification | Internal, Confidential |
| Owner | [CRA Compliance Lead] |