Pharus
Sign in

Do small companies get fined for missing the CRA’s 24-hour deadline?

Not for missing the 24-hour early warning, if you’re a micro or small enterprise. The early warning is still required, and the exemption doesn’t cover the 72-hour notification, the final report or medium-sized companies.

By Hallvard Munkås Andersen, founder of Pharus · Published

What the exemption says

Breaking Article 14 can mean administrative fines of up to EUR 15 million or 2.5% of worldwide annual turnover, whichever is higher (Article 64(2)). Article 64(10) makes one exception: manufacturers that are micro or small enterprises aren’t fined for missing the 24-hour deadline for the early warning, whether for an actively exploited vulnerability or a severe incident.

Recital 120 says so plainly, and adds that member states shouldn’t impose other kinds of financial penalty for it either.

What it doesn’t cover

  • The early warning itself. The duty to send it stands. The exemption is about the fine for being late, not a licence to skip it.
  • The 72-hour notification and the final report. Missing those can be fined as usual.
  • Medium-sized and larger companies. Only micro and small enterprises are covered.
  • The rest of the CRA. From 11 December 2027, gaps in the security requirements and vulnerability handling can be fined too, whatever your size. Size then counts when the fine is set (Article 64(5)).

A detail in the wording

Article 64(10) is worded as an exception to paragraphs 3 to 9, while the fines for breaking Article 14 are set in paragraph 2. Read literally, the cross-reference misses the paragraph that matters. Recital 120 states the intent without that ambiguity. If it ever matters in a real case, it’s a point for a lawyer.

Are you a small enterprise?

The CRA uses the EU definition (Recommendation 2003/361/EC):

Staff (annual work units)Annual turnover or balance sheet total
MicroenterpriseFewer than 10At most EUR 2 million
Small enterpriseFewer than 50At most EUR 10 million
Medium-sized enterpriseFewer than 250Turnover at most EUR 50 million, or balance sheet total at most EUR 43 million

If your company is part of a group, the group’s figures count. A subsidiary of a large group isn’t a small enterprise, however small it is on its own. And your category only changes once you’ve been over or under a ceiling for two accounting years in a row.

Norwegian manufacturers

Fines are set by each member state’s rules and imposed by its market surveillance authority (Article 64(1)). Until the CRA is part of the EEA Agreement, Norwegian authorities can’t impose penalties under it (does the CRA apply before the EEA?). For the products you sell in the EU, enforcement is a matter for the authorities in the member states concerned.

Why you should still meet the 24 hours

  • The 72-hour notification and the final report have their own deadlines, and those aren’t exempt.
  • The CSIRTs and ENISA need the warning to alert others in time. That’s why the deadline is so short.
  • Customers and partners ask. A missed deadline is hard to explain in a security review, fine or no fine.
  • Help is there: the CSIRTs designated as coordinators must offer helpdesk support on reporting, in particular to micro, small and medium-sized companies (Article 17(6)).

When the deadline starts is in the article on actively exploited vulnerabilities, and what each report must contain is in the CRA playbook.

Know where it goes.

Article 14 has applied since 11 September 2026. The first early warning is due 24 hours after you become aware; settle the route before then.

Book a walkthrough

30 minutes with your own SBOM. We match it live and map your Art. 14(7) route.

We only use your email to arrange the walkthrough. See our privacy notice.

Or set up a workspace yourself
Lista lighthouse at night, seen across the sea from Borhaug: one point of light on the horizon and its streak on the water, stones on the shore in front.
Lista lighthouse from Borhaug at night. Photo: Einar Mostad.