Why the Cyber Resilience Act Should Focus Minds on Continuous Controls Monitoring

Regulators are often criticized for being a step behind technological change. But the EU’s new Cyber Resilience Act (CRA) could not have come into force at a more critical time. Its vulnerability and incident reporting obligations coincide with a period of tremendous technological change, where AI is asking searching new questions of network defenders. The CRA is matched by even more prescriptive new rules for US government agencies and suppliers. 

The message for GRC teams should be clear. You can’t afford to move at the speed that legacy approaches do. Periodic vulnerability scans and control reviews are out. Continuous controls monitoring (CCM), automated evidence collection, and risk-based vulnerability prioritization are in. 

What’s in the CRA?  

Effective September 11, 2026, the CRA applies to in-scope manufacturers of hardware and software (i.e., anything with a “digital element”). Among other things, it demands that they: 

• Identify and document vulnerabilities in their products and any relevant backend/cloud services 
• Notify government authorities, customers, and suppliers/partners of any active exploited vulnerabilities or “severe incidents”: initially within 24 hours, then following up after 72 hours, and producing a final report 14 days after the patch/security incident 

By next year, organizations will also be expected to remediate any vulnerabilities (taking into account the risks they pose) “without delay.” 

The Bigger Picture    

The EU is not the only region concerned about the direction in which the vulnerability and threat landscape is heading. Vendors are finding an order of magnitude more vulnerabilities in their products these days. Exploitation windows are collapsing as threat actors weaponize bugs in record time. And AI is helping them to find novel bugs in greater numbers.  

That’s driving change in US regulation. In June, CISA issued Binding Operational Directive 26-04: Prioritizing Security Updates Based on Risk. It requires agencies to better prioritize vulnerabilities by risk and accelerate patching timelines for high-risk ones.  

These same pressures have also informed new Vulnerability Detection and Response (VDR) and Vulnerability Evaluation and Reporting (VER) requirements for FedRAMP-certified cloud providers. Effective December 7, 2026, they move in-scope organizations from a 30-day timeline for patching to one where the highest risk flaws must be fixed within half a day. This depends on their technical impact, whether they’re internet-reachable, if they’re a Known Exploited Vulnerability (KEV), and if the exploit is automatable. 

The Case for CCM   

This is where CCM changes the model. It turns compliance from a periodic exercise into a continuous view of control health, ownerThese new rules point to that rare thing on both sides of the Atlantic: regulation that meets the moment. In this case, this moment is dominated by AI-powered vulnerability research. It’s driving an explosion in new CVEs for security teams to handle, while simultaneously reducing the time they get to do so before an attacker strikes. 

In this context, traditional GRC is doomed to fail. Vulnerability management must be a continuous process that runs throughout a product’s lifecycle, rather than a “one-and-done” effort at the start. Evidence and controls must be monitored in an ongoing manner, to catch and correct drift as soon as possible. Otherwise, by the time that maximum severity flaw is discovered at the next audit, it might be too late. 

This is the value of CCM. It supports the kind of continuous approach to vulnerability management that organizations need to meet the requirements of the CRA, BOD 26-04 and FedRAMP’s incoming VDR/VER rules. That means automatically collecting evidence, continuously assessing control status, identifying gaps, and triggering remediation. It also maintains an audit trail of evidence that ensures organizations are always regulator ready, however immediate the reporting deadlines. It makes the traditional post-incident scramble for information a thing of the past. 

RegScale Can Help   

When it comes to vulnerability and incident management, regulatory expectations have changed, as they had to. And advances in AI are largely responsible. For businesses selling into the EU, penalties for non-compliance could reach a maximum of €15m ($17m) or 2.5% of global annual turnover, whichever is higher.  

Yet it’s not just in the EU, and not just vulnerability management, where regulators are demanding a fresh approach to GRC. They know that compliance teams are drowning in manual work. And that cyber threats don’t wait for quarterly audits. They’re increasingly receptive to compliance-as-code approaches, where machine-readable, self-validating controls support continuous monitoring and assurance. 

This is the future that RegScale is built for. One where compliance is not the end goal in itself, but the byproduct of continuously monitored and high-performing operational security.  

To find out more about how RegScale can transform your GRC strategy, get in touch today.