10 Cybersecurity Challenges Companies Need to Solve as EU Cyber Rules Take Effect

For years, security teams have been told to improve vulnerability management, strengthen incident response, and build security into the software development lifecycle. Beginning September 11, 2026, manufacturers covered by the Cyber Resiliency Act (CRA). A will have reporting obligations for actively exploited vulnerabilities and severe incidents affecting the security of products with digital elements. The CRA's broader requirements will take effect on December 11, 2027, including an early warning that must generally be submitted within 24 hours of becoming aware, followed by a more detailed notification within 72 hours. 

Even companies that don't directly sell into the EU may feel the effects. A North American customer with EU operations may apply CRA-influenced security requirements across its global vendor procurement process rather than maintaining separate standards for each region.

Can your security program meet regulatory expectations?

You need the ability to detect issues. Once detected, security needs to investigate. Teams need to determine which products and customers could be affected, and someone needs to decide whether it meets the reporting threshold. Engineering may need to begin remediation while legal, compliance, and leadership determine what to communicate.

Suddenly, 24 hours doesn't feel very long.

1. Knowing What You're Actually Responsible For

You can't protect what you don't know exists, and you certainly can't investigate it quickly.

Modern software products contain an extensive collection of first-party code, open-source libraries, third-party components, APIs, cloud services, and other dependencies. When a critical vulnerability is disclosed, the security team needs to know if they are affected.

The CRA makes component visibility increasingly important. Its vulnerability-handling requirements cover vulnerabilities affecting products and their components; manufacturers also must identify and document vulnerabilities and components.

This turns software inventories and software bills of materials into incident-response tools. When the next critical dependency vulnerability appears, the important question is:

Could you quickly identify all affected products and versions?

2. Detecting Security Issues Fast Enough

Effective detection requires visibility across an increasingly complicated attack surface: applications, APIs, authentication systems, cloud infrastructure, endpoints, third-party integrations, and more. Organizations can have SIEM platforms, application monitoring, vulnerability scanners, endpoint tooling, cloud security products, and extensive logging, yet still struggle to detect meaningful malicious activity.

The CRA makes this distinction especially important because its reporting obligations aren't triggered by every vulnerability sitting in a scanner backlog. Covered events include vulnerabilities a manufacturer becomes aware have been actively exploited, as well as severe incidents affecting product security.

Security leaders should ask:

How quickly would you know if someone were actively exploiting your product?

3. Understanding What Actually Happened

Imagine an alert indicates suspicious activity against a production application. Within the first few hours, responders may need to determine whether the activity was successful, which vulnerability was involved, what systems or product versions are affected, whether data or functionality was compromised, and whether other customers face the same exposure.

At the same time, the organization may need to determine whether the event meets a regulatory reporting threshold. These decisions often need to be made while the investigation is still developing and critical information remains incomplete. Teams need access to sufficient telemetry, product knowledge, technical expertise, and decision-making processes to move from an alert to a defensible assessment.

The question becomes: Can you move quickly from "something happened" to a defensible understanding of what happened?

4. Investigating Under Tight Reporting Timelines

Those 24- and 72-hour reporting stages mean investigation and reporting may need to happen at the same time. You don’t need to know everything on the first day; the early-warning structure recognizes that investigations develop over time, but teams still need sufficient information to make decisions and communicate effectively. Incomplete logs can make that difficult. So can short retention periods, missing application telemetry, poor asset inventories, or information spread across engineering and infrastructure teams. 

Security leaders therefore need to look beyond whether they have an incident-response plan and consider the evidence available to execute it.

Could you build a meaningful picture of an incident within three days using the evidence you collected today?

5. Turning Security Tools Into Useful Evidence

During an incident, security teams often struggle to connect information across their security tools. One piece of evidence may live in the SIEM. Another is in application logs. Authentication events sit somewhere else. A vulnerability scanner provides a single view of the affected system, while the CI/CD platform tells responders which code was actually deployed.

The individual tools aren't necessarily the problem, but the fragmentation between them is.

The challenge is making the right evidence accessible and usable when responders are working against the clock. If accessing that evidence requires opening tickets with multiple teams, requesting permissions, and manually assembling timelines from different systems, reporting deadlines become much harder to meet. A useful incident-readiness exercise is therefore to ask:

Could your security team investigate a serious incident without having to chase down information across five different teams?

6. Establishing Ownership Before an Incident

Security incidents quickly become organizational events. Security may lead the investigation. Engineering may own remediation. Legal and compliance teams may help determine reporting obligations. Leadership needs to understand business impact. Communications and customer-facing teams may need to tell customers what's happening.

The CRA's reporting timelines make predefined escalation paths particularly valuable. Organizations should know who can classify an event, who decides when regulatory reporting is necessary, who submits required notifications, who approves external communications, and who coordinates remediation. This isn't simply about creating another incident-response document. The people expected to execute it need to understand and rehearse the process.

Consider this scenario:

If a potentially reportable vulnerability appeared at 4 p.m. on a Friday, would everyone know what they're responsible for?

Organizations can make this more concrete with an incident-response SOP and pre-approved communication templates for internal stakeholders and customers. Templates shouldn't replace judgment, but they can remove unnecessary administrative work when every hour matters.

7. Finding Exploitable Vulnerabilities Before Attackers Do

The CRA creates reporting obligations when certain vulnerabilities are actively exploited. A mature security program should seek to identify those weaknesses before attackers do.

Automated security testing is essential at scale, but scanners aren't equally effective at finding every class of vulnerability. Business-logic flaws, complex authorization problems, chained vulnerabilities, and attack paths that depend on application context require human analysis.

This is where application security testing and penetration testing become particularly useful for validating how an attacker could realistically compromise a product.

The CRA's broader requirements reinforce this risk-based approach by requiring manufacturers to conduct cybersecurity risk assessments and address vulnerability handling throughout a product's support period.

Does your testing inform which vulnerabilities attackers could actually exploit?

8. Managing Third-Party and Open-Source Risk

Open-source packages, frameworks, libraries, SDKs, APIs, and commercial components allow teams to ship faster. They also mean vulnerabilities can enter your product through software you don't directly control. When a vulnerability is disclosed in one of those components, teams need to quickly determine their exposure.

Which products use the affected component? 

Which versions? 

Is the vulnerable functionality actually present or reachable? 

Are customers running affected releases? 

Is a patch available?

Third-party risk isn't only a vendor-management problem. For software companies, it is also a product security and incident response problem.

When a critical third-party vulnerability is disclosed, how quickly can you assess exploitability, prioritize affected products, and begin remediation?

9. Maintaining Security After Release

Products evolve. Dependencies change. Researchers discover new vulnerabilities. Attack techniques improve. Code considered secure at release may become vulnerable months or years later.

The CRA formalizes this lifecycle perspective. Manufacturers must determine a support period and effectively handle product vulnerabilities during that period. That requires processes to receive vulnerability reports, assess them, develop fixes, test those fixes, and distribute security updates. Finding exploitable vulnerabilities before release matters, but a penetration test before a major release only provides a snapshot of risk at that time.

Can you reliably find, validate, fix, test, and deploy security updates throughout the product lifecycle?

10. Proving Your Security Program Actually Works

An organization can have an incident-response policy. It can have vulnerability-management procedures. It can own a SIEM, run automated scanners, maintain an SBOM, and have escalation paths documented in a wiki.

None of that proves the process will work when something goes wrong. Tabletop exercises can reveal confusion about roles and reporting decisions. Penetration testing can expose vulnerabilities existing controls have missed. Incident simulations can show whether monitoring produces enough evidence for investigators to understand what happened.

These exercises reveal whether security readiness exists in practice. If it doesn’t, the consequences extend beyond regulatory compliance. CRA enforcement can include significant financial penalties as well as restrictions, withdrawals, or recalls of non-compliant products. A poorly handled security incident can also affect customer confidence, contracts, operations, and reputation.

If an actively exploited vulnerability appeared tomorrow, where would your current process break first?

Compliance Is the Deadline. Security Readiness Is the Goal.

A 24-hour reporting requirement can't be solved with a better reporting policy. By the time someone begins writing the report, the organization's visibility, detection, investigation, decision-making, and response capabilities have already been tested. 

For companies placing covered products on the EU market, these requirements set a clear deadline for having security processes in place. For other North American software companies, the direction of travel is still worth watching. Customers operating globally can bring regulatory expectations into vendor assessments and procurement processes, while expectations for demonstrable software security keep rising.

Security leaders shouldn't wait for an incident or a compliance deadline to discover whether their processes work.

Test the applications. Test the incident-response process. Test the escalation paths. Find the gaps while there's still time to fix them.

Because when a real incident occurs, the question won't be whether your security program looked good on paper. It will be whether it worked.