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Post Deployment Tasks

The Cyber Reslience Act for Post Deploy CI/CD Steps: Phase 3

Achieving Post Deploy Tasks of the Secure Software Development Framework

The European Union Cyber Resilience Act (CRA) establishes cybersecurity obligations that extend beyond software development and initial release. Manufacturers of covered products with digital elements must maintain processes for identifying, evaluating, and addressing vulnerabilities throughout the applicable product support period. These responsibilities include monitoring software components for newly disclosed vulnerabilities, determining which products are affected, distributing security updates, and coordinating vulnerability disclosures.

During Post Deployment, organizations must be prepared to respond to vulnerabilities discovered after software has been released. A software component that was considered secure during development may become vulnerable when a new Common Vulnerabilities and Exposures (CVE) record is published. Build-time scanning alone cannot identify every future vulnerability.

For DevOps and platform engineering teams, continuous vulnerability management should extend the CI/CD pipeline into operational environments. By correlating software component inventories, SBOMs, product versions, and deployment records with emerging vulnerability intelligence, organizations can identify affected products, prioritize remediation, and maintain evidence demonstrating ongoing security activities.

The following sections map CRA requirements to actionable Post Deployment practices and suggested open-source tooling. The tools are illustrative and are not mandated by the regulation.

1 - Affected-Product Identification - Post Deployment

Affected-Product Identification for Post Deployment Activities.

Affected-Product Identification - Phase 3: Post Deployment

Objective: Identify which released products, software versions, and operational deployments are affected when new vulnerabilities are disclosed.

The CRA requires manufacturers to identify and document vulnerabilities and components contained in their products and to assess vulnerabilities according to the risks they pose. Effective vulnerability handling depends on understanding which products contain affected components and whether those components introduce exploitable security risks.

For DevOps teams, this requires establishing traceability between software components, SBOMs, product versions, release artifacts, and the environments where software is deployed.

An SBOM identifies the components contained in a software product or release, but an SBOM alone does not necessarily identify where affected software is currently running. Correlating component inventories with release and deployment metadata provides additional visibility into the operational impact of newly disclosed vulnerabilities.

This process, commonly referred to as vulnerability impact analysis or blast-radius assessment, helps organizations distinguish vulnerabilities affecting actively deployed products from vulnerabilities associated with obsolete or unused releases.

Where deployment information is available, teams can associate affected products with specific environments, endpoints, applications, and responsible owners. This supports faster investigation, targeted remediation, and improved communication with affected users.

While the CRA does not explicitly mandate endpoint-level deployment mapping, this capability can strengthen vulnerability handling and provide supporting evidence of product-specific risk assessment.

CRA Requirements and Open-Source Tooling

CRA Reference Security Activity CI/CD Implementation Suggested Open-Source Tools
Annex I, Part II(1) Affected-component identification Correlate disclosed vulnerabilities with SBOM components, software versions, and supported products. OWASP Dependency-Track, OSV.dev, Ortelius
Article 13(8), Annex I, Part II(2) Product vulnerability impact assessment Determine which product versions are affected and evaluate the risks associated with identified vulnerabilities. Ortelius, DefectDojo, OWASP Dependency-Track
Annex I, Part II(1)–(2) Release and deployment traceability Associate software components and SBOMs with release artifacts and available deployment records. Ortelius, Argo CD, Flux
Annex I, Part II(2) Vulnerability blast-radius assessment Identify affected product versions and, where supported, deployed applications, environments, and endpoints. Ortelius, OWASP Dependency-Track
Annex I, Part II(2), (4) Remediation ownership and affected-product communication Identify responsible teams and maintain records of affected products for remediation and security advisories. Ortelius, DefectDojo
Annex I, Part II(1)–(2) Vulnerability status and exploitability documentation Document product-specific vulnerability assessments, including whether vulnerabilities are affected, not affected, fixed, or under investigation. OpenVEX, CycloneDX, Ortelius

Expected Compliance Evidence

  • Component-to-product vulnerability mappings.
  • Product and release version inventories.
  • SBOM-to-release associations.
  • Available deployment and endpoint inventory records.
  • Affected-product and vulnerability impact assessments.
  • Product-specific vulnerability status statements.
  • Assigned remediation ownership and tracking records.
  • Documented decisions concerning product exposure and exploitability.

2 - Remediation and Security Update - Post Deployment

Remediation and Security Update for Post Deployment Activities.

Remediation and Security Update - Phase 3: Post Deployment

Objective: Address identified vulnerabilities without delay and securely distribute appropriate security updates to affected products.

The CRA requires manufacturers to address and remediate vulnerabilities in relation to the risks they pose to their products. Remediation may involve updating vulnerable dependencies, modifying application code, applying configuration changes, replacing affected components, or implementing other appropriate mitigation measures.

Where technically feasible, security updates must be provided separately from functionality updates. The CRA also establishes requirements for securely distributing security updates and making them available without delay and, subject to specified exceptions, free of charge.

For DevOps teams, vulnerability remediation should connect Post Deployment monitoring with development and build workflows. When a vulnerability is identified, teams should evaluate available fixes, determine compatibility with affected products, create remediation changes, and validate those changes through automated build and security testing.

Remediation workflows should support dependency upgrades, application changes, regression testing, release approval, and controlled deployment of security updates.

Where applicable, organizations should maintain records demonstrating that fixes were developed, tested, released, and communicated to affected users. Deployment verification provides additional operational assurance that updated software has reached the intended environments.

Automating these workflows can reduce remediation delays while maintaining required security reviews and release authorization controls.

CRA Requirements and Open-Source Tooling

CRA Reference Security Activity CI/CD Implementation Suggested Open-Source Tools
Annex I, Part II(2) Vulnerability remediation Investigate identified vulnerabilities and implement appropriate fixes or mitigating measures without delay, based on product risk. Renovate, DefectDojo, Ortelius
Article 13(6) Third-party vulnerability remediation coordination Coordinate identified component vulnerabilities and applicable fixes with upstream maintainers. GitHub Security Advisories, Renovate
Annex I, Part II(2) Dependency and application updates Update vulnerable dependencies or application code and validate remediation through automated builds and tests. Renovate, Trivy, Grype
Annex I, Part II(2) Separation of security and functionality updates Maintain workflows capable of delivering security fixes independently of unrelated functionality changes where technically feasible. Renovate, Argo CD, Flux
Annex I, Part I(2)(c) Security update capability Support product mechanisms for receiving and applying appropriate security updates. The Update Framework (TUF), Sigstore Cosign
Annex I, Part II(7) Secure update distribution Verify the authenticity and integrity of security updates before delivery or installation. The Update Framework (TUF), Sigstore Cosign, Harbor
Annex I, Part II(8) Timely update availability and user advisories Distribute available security fixes without delay, subject to CRA requirements, and communicate relevant user actions. Argo CD, Flux, GitHub Security Advisories
Article 13(8)–(9) Support-period security maintenance Maintain vulnerability handling capabilities and ensure security updates remain available for the applicable period. Harbor, Ortelius
Annex I, Part II(2)–(3) Remediation validation Reassess vulnerability status after remediation and verify that updated software addresses the identified security issue. Trivy, Grype, OWASP Dependency-Track

Expected Compliance Evidence

  • Vulnerability remediation records and assigned responsibilities.
  • Dependency upgrade and application modification history.
  • Security update build and test results.
  • Documented remediation risk assessments.
  • Security update release and distribution records.
  • Signed update artifacts and integrity verification results.
  • User notification and security advisory records.
  • Product version and deployment verification records.
  • Security update availability and retention records.
  • Documented mitigation decisions for vulnerabilities that cannot be immediately patched.

3 - Continuous Vulernability Management - Post Deployment

Continuous Vulernability Management for Post Deployment Activities.

Continuous Vulernability Management - Phase 3: Post Deployment

Objective: Continuously identify, assess, and track newly discovered vulnerabilities affecting released software throughout the product support period.

The CRA requires manufacturers to maintain effective vulnerability handling processes and address cybersecurity risks associated with their products and integrated components. These responsibilities extend throughout the applicable product support period and include regularly reviewing product security, identifying newly disclosed vulnerabilities, and taking appropriate remediation measures.

For DevOps teams, continuous vulnerability management requires maintaining visibility into software components after release. SBOMs generated during Build and Deploy should be retained and monitored against evolving vulnerability intelligence from sources such as the National Vulnerability Database (NVD), OSV, and other security advisory databases.

When new vulnerabilities are identified, organizations should determine whether affected components are included in supported product versions, evaluate their potential exploitability and impact, and assign remediation activities to responsible teams.

Automated vulnerability correlation, risk-based prioritization, and integration with development issue tracking can help reduce the time between vulnerability disclosure and remediation.

CRA Requirements and Open-Source Tooling

CRA Reference Security Activity CI/CD Implementation Suggested Open-Source Tools
Article 13(8) Ongoing vulnerability management Maintain effective vulnerability handling processes throughout the applicable product support period. OWASP Dependency-Track, Ortelius
Annex I, Part II(1) Continuous component vulnerability identification Monitor SBOM components against newly disclosed vulnerabilities and maintain product component inventories. OWASP Dependency-Track, OSV.dev, Grype
Annex I, Part II(2) Vulnerability risk assessment and prioritization Evaluate newly discovered vulnerabilities for product relevance, exploitability, impact, and required remediation. DefectDojo, Ortelius, OSV-Scanner
Annex I, Part II(3) Continuous security testing Conduct effective and regular security tests and reviews of supported product versions. Trivy, OWASP ZAP, Wazuh
Article 13(5), Annex I, Part II(1)–(2) Third-party component vulnerability monitoring Identify newly disclosed vulnerabilities in integrated open-source and commercial dependencies and assess product impact. OSV-Scanner, OWASP Dependency-Track, OpenSSF Scorecard
Article 13(8), Annex I, Part II(2) Vulnerability lifecycle tracking Track identified vulnerabilities through investigation, remediation, validation, and closure. DefectDojo, Ortelius

Expected Compliance Evidence

  • Maintained product SBOMs and component inventories.
  • Continuous vulnerability monitoring records.
  • Newly identified vulnerability assessment reports.
  • Product-specific vulnerability risk and exploitability determinations.
  • Vulnerability remediation assignments and tracking history.
  • Periodic security test and review results.
  • Evidence of vulnerability handling activities throughout the product support period.

4 - Vulnerability Disclosure and Regulatory Reporting - Post Deployment

Vulnerability Disclosure and Regulatory Reporting for Post Deployment Activities.

Vulnerability Disclosure and Regulatory Reporting - Phase 3: Post Deployment

Objective: Establish processes for coordinated vulnerability disclosure, communicate security information to affected users, and satisfy applicable CRA regulatory reporting obligations.

The CRA requires manufacturers to maintain coordinated vulnerability disclosure processes and provide mechanisms through which security researchers, customers, and other parties can report potential product vulnerabilities.

Manufacturers must also disclose appropriate information about fixed vulnerabilities once a security update becomes available, subject to the regulation’s provisions concerning disclosure timing and security risks. Such information includes affected products, vulnerability impact and severity, and actions users can take to remediate the issue.

In addition, Article 14 establishes mandatory regulatory reporting obligations for qualifying actively exploited vulnerabilities and severe incidents affecting the security of products with digital elements.

These reporting requirements have applied to manufacturers since September 11, 2026. They require early warning notifications within 24 hours of awareness, followed by more detailed notifications within 72 hours. Final reporting deadlines vary depending on whether the report concerns an actively exploited vulnerability or a severe security incident.

For DevOps and security operations teams, disclosure and reporting processes should integrate vulnerability intelligence, incident investigation, affected-product identification, remediation tracking, and communication workflows.

Organizations should establish procedures for determining whether a vulnerability meets the CRA’s regulatory reporting criteria, collecting required information, and submitting notifications through the designated reporting mechanisms.

Not every newly disclosed CVE triggers regulatory reporting. Article 14 applies to the specific categories of reportable vulnerabilities and incidents defined by the regulation.

CRA Requirements and Open-Source Tooling

CRA Reference Security Activity CI/CD Implementation Suggested Open-Source Tools
Annex I, Part II(5) Coordinated vulnerability disclosure Maintain and enforce a documented coordinated vulnerability disclosure policy. GitHub Security Advisories, DefectDojo
Annex I, Part II(6) Vulnerability reporting channels Provide mechanisms and security contacts for reporting vulnerabilities in products and third-party components. GitHub Private Vulnerability Reporting, security.txt
Annex I, Part II(4) Public disclosure of fixed vulnerabilities Publish appropriate information about fixed vulnerabilities, affected products, severity, impacts, and remediation actions, subject to CRA disclosure provisions. GitHub Security Advisories, OSV, CSAF
Article 14(1)–(2) Actively exploited vulnerability reporting Establish procedures for identifying and reporting qualifying actively exploited vulnerabilities. TheHive, DefectDojo, Ortelius
Article 14(3)–(5) Severe security incident reporting Identify, investigate, and escalate qualifying severe incidents affecting product security. Wazuh, Falco, TheHive
Article 14(2), (4) Regulatory notification timelines Establish escalation workflows to meet applicable 24-hour, 72-hour, and final reporting deadlines. TheHive, DefectDojo
Articles 14 and 16 Regulatory notification submission Collect required incident and vulnerability details and submit mandatory notifications through the ENISA CRA Single Reporting Platform. TheHive, DefectDojo
Annex I, Part II(4), (8) User security advisories Communicate affected-product information, available security updates, and recommended remediation actions to users. GitHub Security Advisories, CSAF
Article 13(6) Upstream vulnerability coordination Notify relevant third-party component maintainers of identified vulnerabilities and share applicable fixes as required. GitHub Security Advisories, OSV

CRA Regulatory Reporting Deadlines

The following timelines apply to qualifying actively exploited vulnerabilities and severe security incidents under Article 14.

Reporting Requirement Deadline Required Action
Early warning notification Within 24 hours of awareness Submit an initial notification concerning a qualifying actively exploited vulnerability or severe security incident.
Vulnerability or incident notification Within 72 hours of awareness Submit a more detailed notification with available product, vulnerability or incident, and mitigation information.
Final report — actively exploited vulnerability No later than 14 days after a corrective or mitigating measure becomes available Provide the required final vulnerability information, including severity, impact, and corrective measures.
Final report — severe security incident Within one month after submission of the 72-hour incident notification Provide the required final incident analysis and corrective or mitigating measures.

Mandatory notifications are submitted through the ENISA CRA Single Reporting Platform.

Reporting deadlines are triggered by awareness of qualifying events, rather than the publication of every CVE.

Expected Compliance Evidence

  • Published coordinated vulnerability disclosure policy.
  • Documented vulnerability reporting contacts and channels.
  • Vulnerability reports and investigation records.
  • Published security advisories and disclosure history.
  • Affected-product identification and impact assessments.
  • Reportability assessments for actively exploited vulnerabilities and severe incidents.
  • Regulatory notification timestamps and submission records.
  • Security incident investigation and root-cause analysis records.
  • Remediation decisions and corrective action records.
  • User notification and security update communication records.

Phase 3 Compliance Evidence Summary

Post Deployment activities should establish a continuous and traceable process for identifying vulnerabilities, determining affected products, implementing remediation, and communicating security information throughout the product support period.

Organizations should integrate SBOM monitoring, vulnerability intelligence, release inventories, and available deployment records to maintain visibility into software security after release.

When vulnerabilities are discovered, teams should document their relevance to supported products, assess exploitability and impact, assign remediation responsibilities, and preserve records of corrective actions.

Where practical, correlating vulnerable components with deployed product versions and operational endpoints can improve remediation prioritization and reduce the time required to identify affected environments.

For qualifying actively exploited vulnerabilities and severe security incidents, organizations must also maintain procedures capable of supporting statutory CRA reporting deadlines.

The resulting evidence should demonstrate that vulnerability handling is an ongoing operational process rather than a one-time activity performed during software development or release.

References

Implementation Note: The CRA establishes obligations for covered manufacturers and, where applicable, other economic operators and open-source software stewards. The open-source tools listed are illustrative technica