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Vulnerability reporting obligations: 11 September 2026

Get every WordPress plugin you ship CRA-ready

The EU Cyber Resilience Act takes effect 11 September 2026 and applies to every commercial WordPress product placed on the EU market. WP HealthKit audits every requirement, exports per-plugin Declarations of Conformity, and gives agencies a fleet-wide view of CRA posture across every client site.

Fines of up to €15M or 2.5% of global turnover

The CRA is enforced law — not a guideline. Non-compliant products can be blocked from the EU market.

What the CRA requires from you

The EU Cyber Resilience Act treats commercial software products — including WordPress plugins sold or used commercially — as regulated goods. From 11 September 2026, you must meet four core obligations.

Vulnerability Disclosure Program (VDP)

Required

You must provide a channel — a security.txt file, SECURITY.md, or public bug bounty page — where security researchers can privately report vulnerabilities to you. You must also have a documented process for responding to those reports and issuing fixes.

Software Bill of Materials (SBOM)

Required

You must maintain a machine-readable inventory of every component your plugin ships: Composer packages, npm dependencies, and bundled third-party libraries. This is required so you can immediately identify affected products when a component vulnerability is published.

Security Risk Assessment

Required

You must produce documented evidence that you assessed your plugin for vulnerabilities before release — and that you have a process to reassess when new threats emerge. A WP HealthKit audit report serves as this artifact.

Patch Release Process

Required

Security fixes must be released separately from feature updates and must be clearly tagged in the changelog. Bundling a security fix into a routine feature release without flagging it is non-compliant.

How WP HealthKit maps to each CRA requirement

Every audit runs all four checks automatically. The report you receive is your compliance documentation artifact.

VDP / SECURITY.md check

Scans every plugin for the presence of SECURITY.md, security.txt, and a valid vulnerability contact. Flags missing or malformed files with specific remediation instructions.

CycloneDX SBOM generation

Generates a CycloneDX-format SBOM covering all Composer packages, npm dependencies, and bundled third-party libraries detected in the plugin ZIP. Downloadable from every audit report.

Security risk assessment artifact

The full 49-layer audit — 45 deterministic engines plus 4 AI engines — produces a timestamped, shareable report documenting the security state of your plugin at the point of audit. This is your CRA risk assessment evidence.

Changelog security tagging

Checks readme.txt and changelog files for properly tagged security releases. Flags releases that bundle security fixes into routine updates without a clear security label.

The September 2026 deadline

The CRA entered into force on 10 December 2024. The vulnerability reporting obligations take effect first — on 11 September 2026. The full set of requirements applies from 11 December 2027.

11 September 2026

Vulnerability reporting obligations

  • 24-hour early warning to ENISA for actively exploited vulnerabilities
  • 72-hour detailed notification with full assessment
  • VDP must be in place before this date

Act now — this deadline is less than 5 months away

11 December 2027

Full CRA requirements

  • SBOM must be maintained and available on request
  • Security risk assessment documented and current
  • CE marking requirements for certain product categories

Start building your compliance process now — not in 2027

Don't wait. Plugins with known unfixed vulnerabilities at the September 2026 deadline face immediate enforcement risk. Market surveillance authorities can require withdrawal of non-compliant products from the EU market.

CRA compliance is included in every plan

SBOM generation, VDP checks, and security risk assessment artifacts are bundled into the standard scan — no add-ons required.

Free

£0 forever

Audit a plugin, get every CRA artefact.

  • Unlimited deterministic audits
  • 1 AI-engine audit / month
  • CycloneDX SBOM download
  • VDP / SECURITY.md check
  • Changelog security tag check

Pro

£29 per month

For plugin authors maintaining one product.

  • 30 full audits per month
  • SBOM + Conformity Statement on every audit
  • API access for automation
  • Free re-audits within 14 days
  • Unlimited AI fix prompts

Agency

£149 per month

Fleet-wide CRA posture for client portfolios.

  • Unlimited audits in registered portfolio
  • Per-plugin EU Declaration of Conformity export
  • Fleet dashboard + morning compliance digest
  • CRA / GDPR / WCAG / EAA grid + finding workflow
  • 5 team seats + REST API + webhooks

Unlimited free audits — no credit card required

CRA questions answered

I run a WordPress agency — does the CRA apply to me, or just to the plugin authors?

Both. When you build, customise, install, or operate a WordPress product for a client on the EU market, you sit somewhere on the CRA "manufacturer / importer / distributor" spectrum depending on the engagement. At a minimum you need a per-plugin self-assessment, evidence of secure-by-default config, and a documented vulnerability disclosure route. WP HealthKit's fleet dashboard tracks the verdict per plugin × per client; the per-plugin Declaration of Conformity export is the artifact the regulator will want to see.

What is the Declaration of Conformity and how do I generate one?

Article 28 of the CRA requires manufacturers to issue an EU Declaration of Conformity for each product confirming compliance with Annex I essential cybersecurity requirements. WP HealthKit generates this per plugin: open any audit in the agency fleet view, click "CRA →" on the plugin's compliance row, and the system produces a print-ready document mapping Annex I §1(2) requirements to your audit findings, with the agency branding, signature block, and verification URL included.

Does the CRA apply to free WordPress plugins?

Yes — if the plugin is maintained by a commercial entity, distributed as part of a commercial service, or used in a commercial context, the CRA applies regardless of whether end users pay for the plugin directly. Free plugins distributed by a company that earns revenue from related services are in scope.

What is an SBOM and why does the CRA require one?

An SBOM (Software Bill of Materials) is a structured inventory of every software component your plugin includes — Composer packages, npm dependencies, bundled libraries, and third-party scripts. The CRA requires it so that when a vulnerability is discovered in a component, you can immediately identify which of your products are affected. Without an SBOM, you cannot efficiently comply with the 24-hour early warning obligation.

Does WP HealthKit generate an SBOM I can submit?

Yes. Every WP HealthKit audit generates a CycloneDX-format SBOM covering Composer packages, npm packages, and bundled third-party libraries detected in the plugin ZIP. The SBOM is downloadable from the audit report page and can be submitted to ENISA or provided to customers as part of your compliance documentation.

What is the 24-hour vulnerability reporting obligation?

Under Article 14 of the CRA, manufacturers must notify ENISA within 24 hours of becoming aware of an actively exploited vulnerability in their product. A further detailed notification is due within 72 hours. This is separate from public disclosure — the 24-hour clock is for regulatory reporting.

What counts as a Vulnerability Disclosure Program (VDP)?

At minimum, a published security.txt or SECURITY.md file with a contact method where security researchers can report vulnerabilities to you privately. You must also have a process for responding to those reports and issuing fixes. WP HealthKit checks for the presence and completeness of these files in every audit.

What are the penalties for non-compliance?

Fines of up to 15 million euros or 2.5% of global annual turnover, whichever is higher. Market access can also be restricted — non-compliant products can be prohibited from the EU market entirely.

CRA compliance deadline: 11 September 2026

Get ahead of the deadline

Run a free CRA-ready audit on a plugin you ship, or stand up a fleet dashboard for every client site you operate.

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