CRA reporting: spreadsheet vs tool vs consultant
You can track Cyber Resilience Act reporting in a spreadsheet, with a dedicated tool such as CRA Reporting Kit, or by hiring a consultant or law firm. Each is the right choice for some companies. This page compares them honestly.
What you are trying to do
Whatever you choose, the job is the same. Since 11 September 2026, when you become aware of an actively exploited vulnerability or a severe incident in your product, you send an early warning within 24 hours, a notification within 72 hours and a final report later, through the single reporting platform [1][2]. You also inform users. The method you pick has to work on a Saturday night.
The comparison
| Spreadsheet | CRA Reporting Kit | Consultant or law firm | |
|---|---|---|---|
| Cost | Free if you already have the software | $199 one-time | Varies widely; usually priced per hour or as a retainer |
| Setup time | Hours to build formulas and templates yourself | Minutes: open the file | Days to weeks to agree scope and contract |
| Deadline tracking | Only as good as your formulas | Built in, with due-soon and overdue warnings | Handled by the adviser if they are on call |
| Report drafts | You write them | Drafts for each report and a user notice | Written or reviewed by the adviser |
| Data privacy | Depends where the file lives; cloud sheets are shared by link | Stays in your browser, no upload | Shared with a third party under their confidentiality terms |
| Legal judgement | None | None, not legal advice | Yes, this is what you pay for |
| Weekend cover | Your own staff | Your own staff | Only if the contract includes it |
Spreadsheet
Good for: companies with one product, a technical founder who likes building their own tools, and very low expected volume.
Risks: date formulas break when someone edits a cell, time zones get mixed up, and there is no warning when a deadline approaches unless you build one. The two final report deadlines also run from different moments: 14 days after a fix is available for a vulnerability, one month after the notification for an incident [2]. That is easy to get wrong in a quick sheet. If the sheet sits in a shared cloud folder, details of an unpatched exploited flaw may be visible to more people than you intend.
A dedicated tool
Good for: small and medium manufacturers who will do the reporting themselves and want the deadlines, drafts and record in one place without building it.
Limits: CRA Reporting Kit does not submit reports, does not decide whether something counts as actively exploited, and does not give legal advice. It keeps time and prepares text. You still need people who can act within 24 hours.
Consultant or law firm
Good for: this is the better choice when the stakes or the uncertainty are high. Choose an adviser when:
- You are unsure whether you are a manufacturer, importer or distributor for a product.
- An incident may also trigger other duties, such as personal data breach rules or sector rules, and the reports need to line up.
- The incident could lead to liability claims, press attention or contact with regulators beyond the report itself.
- You have many products and Member States and need a full process designed and audited.
Limits: cost, and availability. Check that the contract covers response within hours, including weekends, because the early warning does not wait for office hours [2].
Combining them
These are not exclusive. A common setup is to run reporting in-house with a tool or sheet, and keep an adviser for the hard calls. Many security consultants also use a tool to track client cases.
How to decide
- If you have legal uncertainty about your role or a high-impact incident, talk to an adviser.
- If you will do the reporting yourselves and want it ready today, use a tool.
- If you have one product and time to build and test your own sheet, a spreadsheet can work.
More detail: the first 24 hours, the reporting obligations and the vulnerability handling checklist.
Related guides
- CRA 24-hour reporting: actively exploited vulnerabilities
- Cyber Resilience Act reporting obligations since September 2026
- CRA vulnerability handling and SBOM checklist
Sources
- Regulation (EU) 2024/2847 (Cyber Resilience Act), Official Journal, EUR-Lex: Articles 3, 14, 64, 69, 71 and Annex I
- Cyber Resilience Act text, Article 14 (reproduction of the official text)
- Crowell and Moring, It's live: CRA reporting is mandatory as of 11 September 2026
This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.