LESSON 15

Reporting exploited vulnerabilities and severe incidents

The 24 / 72 hour / 14 day clocks, who you notify, and how to be ready before the clock starts.

10 min read video walkthrough

Two reportable events

Actively exploited vulnerability. A vulnerability in your product for which there is reliable evidence that a malicious actor has exploited it in a system without permission. Note: exploitation anywhere, not necessarily against your customer.

Severe incident having an impact on the security of the product. An incident that negatively affects, or is capable of negatively affecting, the ability of the product to protect availability, authenticity, integrity or confidentiality — including where malicious code execution is achieved, or where a compromise of your development or production environment could affect products.

The clocks

Both use the same three-stage cadence, submitted through the single reporting platform to the CSIRT designated as coordinator and to ENISA:

StageDeadlineContent
Early warning24 hours from becoming awareThat the event happened; whether exploitation is suspected to be malicious; Member States likely affected
Vulnerability / incident notification72 hours from becoming awareGeneral information available: severity, impact, corrective or mitigating measures taken or advised, indicators of compromise where applicable
Final report14 days after a corrective measure is available (vulnerabilities) or one month after the notification (incidents)Description of the vulnerability including severity and impact, information on the malicious actor if available, details of the security update or corrective measures

You must also inform affected users of the incident or vulnerability without undue delay, and where necessary tell them the risk-mitigation and corrective actions they can take.

Why 24 hours is an organisational problem

Twenty-four hours from awareness means the clock can start on a Friday evening at a support inbox. To make it survivable:

  • Define "awareness" internally and train first-line support and the security@ triage rota to recognise the trigger.
  • Pre-register on the reporting platform and pre-fill your organisation and product data. Discovering your credentials do not work at hour 20 is a self-inflicted wound.
  • Keep a decision tree on one page: is it our product? is there evidence of exploitation in the wild? then file the early warning — an early warning is not an admission and can be withdrawn or refined at 72 hours.
  • Nominate a named reporter and a deputy, with out-of-hours contact details, and rehearse the process at least annually.

Interaction with disclosure

Reporting and public disclosure are different duties on different clocks. Report to ENISA/CSIRT at 24/72 hours regardless of fix status; disclose publicly once the security update is available. Do not delay the regulatory report to keep an embargo, and do not publish exploit-enabling detail in the early warning.

Coordination with other regimes

A severe incident can trigger CRA reporting, NIS2 obligations if you are an essential or important entity, and GDPR breach notification if personal data is involved. The deadlines and recipients differ. Build one incident playbook that fans out to all applicable regimes from a single internal trigger, rather than three processes that each discover the incident separately.

Key takeaways

  • Report actively exploited vulnerabilities and severe incidents to ENISA and the coordinating CSIRT via the single reporting platform.
  • Early warning at 24 hours, notification at 72 hours, final report at 14 days (vulnerabilities) or one month (incidents).
  • Affected users must also be informed without undue delay.
  • Pre-register, keep a one-page decision tree, and rehearse — the 24-hour clock starts at awareness, not at convenience.

References

  • Article 14 (reporting obligations)
  • Article 16 (voluntary reporting)
  • NIS2 Directive (EU) 2022/2555
  • GDPR Article 33

Check your understanding

  1. Q1What is the deadline for the early warning?

  2. Q2Who receives CRA vulnerability and incident reports?

  3. Q3A vulnerability is reportable when:

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