Toledo Technologies LLC

Article 14 has been in force since 11 September 2026

Something you ship is being exploited. You have 24 hours.

On 11 September 2026 the EU Cyber Resilience Act's reporting obligations became enforceable. If a vulnerability in a product you've placed on the EU market is being actively exploited, you owe an early warning to your national CSIRT and ENISA within 24 hours of becoming aware.

Most of the CRA doesn't bite until December 2027. This part is live now — and it applies to products you shipped years ago that are still on the market.

24h
Early warning
72h
Notification
14d
Final report

Legal basis: Regulation (EU) 2024/2847, Article 14. Penalties for non-compliance can reach €15 million or 2.5% of worldwide annual turnover. Products already on the market before the deadline are in scope (Article 69(3)).


First: do you even have a problem?

Start with the free part. cra-watch reads your lockfiles, resolves them against OSV.dev, and intersects the result with the CISA Known Exploited Vulnerabilities catalogue — the closest public register of what is genuinely being exploited in the wild.

Not "here are 400 CVEs, good luck." One question: is any of it on the known-exploited list today?

$ cra-watch scan

  Advisories  13 component(s) carry at least one known advisory
  KEV feed    1709 entries, catalogue 2026.09.11

  NO KEV MATCHES.

  Nothing in your dependency graph appears on the CISA Known Exploited
  Vulnerabilities catalogue. On this evidence there is no Article 14
  24-hour reporting trigger from a listed component today.

Or the other answer:

  2 KEV MATCH(ES) - MANUAL DECISION REQUIRED NOW

  CVE-2021-44228  (GHSA-jfh8-c2jp-5v3q)
    component      org.apache.logging.log4j:log4j-core 2.14.1  [Maven]
    known as       Apache Log4j2 Remote Code Execution Vulnerability
    KEV listed     2021-12-10   ransomware use: Known

  If you confirm exploitation in your product, the clock is:

    Early warning     within 24h    2026-09-15 08:40:10 UTC
    Notification      within 72h    2026-09-17 08:40:10 UTC
    Final report      within 14d    2026-09-28 08:40:10 UTC

Free, MIT licensed, standard library only, no account, no telemetry. 12 lockfile formats plus CycloneDX and SPDX SBOMs. Exit codes designed to be a CI gate.

Get cra-watch on GitHub →

Run it on a schedule, not just on push. The KEV catalogue gains entries continuously — a repo that was clean yesterday can be a reporting question today without a line of your code changing.


Then: the part a scanner can't do

The tool narrows a thousand CVEs to a shortlist. It cannot tell you whether to file — because Article 14's actual test is whether the vulnerability is being exploited in your product, and that's a human judgement about reachability, evidence, and timing.

That judgement is where organisations come apart under a 24-hour clock. Who is accountable for pressing send? What does an early warning say when you still know almost nothing? What defends a decision not to report, eight months later, to a market surveillance authority?

The clock starts when you have a reasonable degree of certainty after an initial assessment — not when a rumour arrives, and not when you finish the investigation.

The kit is the process around the decision: written in advance, so the 24 hours are spent deciding rather than inventing a procedure.

CRA 24-Hour Reporting Kit

Six documents. Instant download. Commercial licence.
$149
  • Decision tree — does this trigger an Article 14 report? Actively exploited vs. high CVSS vs. public PoC. Third-party component reachability. What "becoming aware" actually means.
  • The three clocks — 24h / 72h / 14d, with worked UTC arithmetic and the severe-incident variant (final report one month after notification).
  • Three fill-in templates — early warning, 72-hour notification, final report. Every field labelled, with an annotated "what good looks like" example.
  • Evidence log — the artefact that proves when you became aware and why you concluded as you did. This is what defends a decision not to report.
  • Roles for the first 24 hours — accountable reporter, deputy, technical verifier, comms. No committee, no ambiguity at 3am.
  • 30-minute tabletop dry-run — an injected scenario and a facilitator script, so the first time you run the process isn't live.

Secure checkout by PayPal — card or PayPal balance, no account required. Download link appears here immediately after payment and is emailed to you.

Consultancy & Multi-Entity Licence

Same six documents. Licensed for client work.
$490

The single licence above covers one organisation. This one covers you deploying the kit into client engagements — consultancies, fractional CISOs, MSPs, and groups running several legal entities.

  • Everything in the $149 kit, identical files
  • Use it with an unlimited number of client organisations or entities you control
  • Rebrand and adapt the templates inside client deliverables
  • Same 12-month revision access, same instant download

You still may not resell the pack itself as a product or publish it publicly. It's a licence to use it in your work, not to republish it.

Same instant download. Same 14-day refund.

Plainly: this is engineering and process tooling, not legal advice, and Toledo Technologies is not a law firm. It will not make you CRA-compliant by itself and doesn't claim to. It's the prepared process that turns a 24-hour scramble into a procedure you already wrote down. Verify against Regulation (EU) 2024/2847 and your coordinating national CSIRT's guidance before filing.

What's actually in it

FileWhat it does
00-START-HEREThe first hour. A ten-line quick start for someone who just got the call.
01-DECISION-TREEReport / don't report, as an ASCII tree and a numbered checklist.
02-TIMELINE-AND-CLOCKSThe cascade, worked in UTC, including what to file when you still know nothing.
03-REPORT-TEMPLATESEarly warning, 72-hour, final. Fill in the blanks.
04-EVIDENCE-LOGContemporaneous record template, with a filled example.
05-ROLES-AND-DRY-RUNWho does what, plus a 30-minute tabletop you can run this week.

Delivered as Markdown (editable, diffable, drop it in your repo next to your incident runbooks) plus a single combined PDF for people who want to print it and put it on a wall.


Who this is for

You manufacture a product with digital elements — software, hardware, a connected device, a component sold separately — and it's available on the EU market. Directly, or through an importer, distributor, or authorised representative. Being based outside the EU doesn't remove the obligation.

You're probably a team of 5 to 200 without a dedicated regulatory function, where the person who'd have to file is also the person shipping features. The kit exists so that person has a procedure instead of an afternoon of reading a regulation.

Who this isn't for

If you have in-house regulatory counsel who've already drafted your Article 14 procedure, you don't need this. If you're looking for a compliance certificate, nothing here is one, and anyone selling you one is selling you something that doesn't exist.

Payment received. Here's your kit.

Download the kit (.zip) Combined PDF

A copy of these links has been emailed to you. Bookmark this page — the links stay live. Questions: dev@toledotechnologies.com


Questions

Is the free tool actually free?

Yes. MIT licensed, on GitHub, no account, no telemetry, no upsell inside the tool. It's genuinely useful on its own and I'd rather it were widely used than gated.

Does a KEV match mean I have to report?

No, and the tool says so explicitly. KEV evidences exploitation somewhere in the world. Article 14 asks about exploitation in your product. If the vulnerable code path is unreachable in your build, the answer may be no. The kit's decision tree walks that distinction, and the evidence log is how you record the reasoning.

Is KEV the legal definition of "actively exploited"?

No. It's a US government catalogue — it lags, and it isn't exhaustive. Your own telemetry or a customer's incident report can start the clock before CISA lists anything. KEV is a strong, free, public signal. It isn't the boundary of the obligation.

Refunds?

It's a digital download, so it's yours the moment you buy it. If it's not what you expected, email within 14 days and you get your money back, no argument. Refunds go back through PayPal to the original payment method.

Will this be updated?

The purchase is the current version, and you get any revision published in the 12 months after you buy at no extra cost — emailed to the address you paid from. To be straight with you: that's a document-revision commitment, not a support contract or a subscription. There's nothing to cancel.

Who's behind it?

Toledo Technologies LLC, a US software company. The tool and the kit were built because the deadline is real and the gap between "here are your CVEs" and "file or don't file, in 24 hours" is where teams actually get stuck.