Klaruna Disclose · CRA disclosure

Vulnerability disclosure for the Cyber Resilience Act

A public channel for security researchers to report what they find, and a register for everything your own team finds itself — triaged, deduplicated, and kept as evidence in one place.

What the Cyber Resilience Act requires

The Cyber Resilience Act requires manufacturers of products with digital elements to run a coordinated vulnerability disclosure policy and a contact point, so a security researcher who finds a flaw has somewhere credible to send it. Reporting duties for actively exploited vulnerabilities phase in from 11 September 2026 and apply across the EU, whatever the manufacturer's size.

Once an organisation becomes aware that a vulnerability in its product is being actively exploited, Article 14 sets out a sequence of notifications to ENISA and the relevant national CSIRT: an early warning, a fuller notification shortly after, and a final report once the picture is complete. Each stage asks for more than the last — the early warning is deliberately minimal, because at that point a manufacturer often knows only that exploitation is happening.

Most vulnerabilities are never reported in from outside. A manufacturer finds the majority itself, through a penetration test, an upstream dependency advisory, or a customer raising something odd — and the reporting duty applies the same way regardless of how the manufacturer found out.

The deadlines

The Cyber Resilience Act sets three deadlines for an actively exploited vulnerability — and not all of them run from the same starting point.

  • 24 hours
    Early warning

    An early warning to ENISA and the relevant national CSIRT, due within 24 hours of becoming aware the vulnerability is being actively exploited.

  • 72 hours
    Notification

    A fuller notification adding your assessment and any mitigations already in place, due within 72 hours of the same moment.

  • 14 days
    Final report

    A final report covering root cause and remediation, due within 14 days after a corrective or mitigating measure is available — a later point than the one the first two deadlines run from.

How it works

  1. Set up your disclosure channel

    Answer a short questionnaire and Klaruna publishes a bilingual CVD policy page and generates your security.txt file. You place the file on your own domain, and a placement check confirms it actually resolves there before your contact point counts as live.

  2. Reports arrive, or you log your own

    A researcher submits anonymously or with attribution and gets a case key to follow up without an account. Vulnerabilities you find yourselves — a penetration test, an upstream advisory, a customer report — go into the same register.

  3. Your team triages

    Promote a report into the register, link a second report of the same bug to one record, or decline one that doesn't hold up. Every decision lands on the vulnerability's own timeline.

  4. Evidence stays intact

    Proof-of-concept code, crash dumps and packet captures are kept byte for byte and encrypted at rest, not re-encoded the way ordinary uploads are processed elsewhere — so the file that demonstrates the bug still demonstrates it.

  5. Keep a record you can show

    Every intake, promotion, link and decline is written to an append-only audit trail, and the register can be exported as CSV whenever you need to show your work.

What's included

Your own disclosure channel

A public CVD policy page and a generated security.txt file, in English, Polish and Romanian, with a placement check that confirms the file is live on your domain before anything shows as compliant.

Anonymous or credited reports

A researcher chooses their own level of attribution and gets a case key to read replies and add detail later, without creating an account.

One register, every source

Reports from the public channel sit beside vulnerabilities your own team found, so there is one record rather than a register and a spreadsheet.

Triage without losing the thread

Promote a report to the register, link duplicates to a single record, or decline one with a recorded reason. A reporter never learns their report was linked to someone else's.

Attachments as the researcher sent them

Proof-of-concept code, crash dumps and packet captures are stored byte for byte and encrypted, not re-encoded, so the evidence a vulnerability needs is never damaged by the processing that keeps ordinary files safe. Attachments are served only through an authorised route, never from a public link.

A register your team can show

Filter the register by status, and export it as CSV whenever you need to show your work.

Data and security

Everything runs in EU data centres: the application, the database, file storage, backups and email delivery.

Report and vulnerability content is encrypted at rest, and every action, from intake through triage, is written to an append-only audit trail.

Attachments are the one place this product deliberately differs from the rest of Klaruna: a proof of concept is evidence, not an ordinary upload, so it is stored exactly as received rather than re-encoded, and served with headers that stop a browser from running it.

Where it applies

Applies across the EU.

Questions

What counts as 'actively exploited'?
The Cyber Resilience Act's reporting duty is triggered once a vulnerability is actually being exploited, not merely a theoretical risk or an unconfirmed report. The 24-hour and 72-hour clocks run from the moment a manufacturer becomes aware of that exploitation, not from when the underlying flaw was first found or reported.
What do the three deadlines count from?
The early warning and the notification both run from when a manufacturer becomes aware a vulnerability is being actively exploited — 24 hours and 72 hours after that moment. The final report runs from a different point: not later than 14 days after a corrective or mitigating measure becomes available.
What happens to attachments like proof-of-concept code?
They are stored exactly as the researcher sent them and encrypted at rest, rather than being re-encoded the way images are processed elsewhere. They are never served from a public link, only through an authorised route with headers that stop a browser from executing them.
Can a researcher report without giving their name?
Yes. Reporting is anonymous by default, with attribution as an opt-in choice. An anonymous researcher gets a case key to read replies and add detail; losing that key means losing access to the thread, which the page warns about before it's shown.
What if we find the vulnerability ourselves rather than through a report?
Log it directly in the register. It carries the same lifecycle as one that arrived through the public channel — the duty doesn't care how you found out.