CRA reporting obligations start September 11, 2026. From that day, if you learn a vulnerability in your product is being actively exploited, ENISA and your national CSIRT get an early warning within 24 hours. Fuller notification at 72 hours. Final report inside 14 days.

Medical devices under MDR and IVDR are excluded from CRA scope. A lot of regulatory teams stopped reading there. Too comfortable. Companion apps, cloud services, accessories, general purpose software: if it sits outside MDR classification, it can be in scope. Ship a phone app with your device and part of your stack may owe Brussels a report.

And the exemption has a shelf life. The Commission’s MDR revision proposal imports the same reporting requirements into device regulation itself, through Eudamed. Brussels is not exempting the idea. Just delaying it.

Treat September 11 as a dress rehearsal. If your PSIRT can’t produce a 24 hour early warning today, that’s the gap. Not the paperwork.