Re: [open-regulatory-compliance] Update on reporting obligations for ope

[Daniel Thompson-Yvetot <denjell@xxxxxxxxxxxxxx>]

My understanding here: a steward is not obliged to engage in any reporting activities under the CRA until it is fully in application (currently expected in December 2027).

I will point out, that some countries (the nordics) are already looking at expanding the “attention” they are giving to open source via other legislation and potentially via transposition of the PLD (which will enter national jurisprudence starting December 2026).

In these cases (Finland?!) a project may indeed be expected to report outside of the CRA mechanisms.

Finally, a Steward might have good reason to report anyway, so don’t be afraid to notify about a KEV

or share your IoCs at the single reporting platform!!!

Cheers,

Daniel 

https://comply.land

On Sat, 05 Sep 2026 at 11:41, Arnout Engelen via open-regulatory-compliance <open-regulatory-compliance@xxxxxxxxxxx> wrote:

I read that to mean "the circumstances described in Article 24(3)" (and I guess further guidance or precedent that may come in the future).

The text of the CRA is linked at the top of the FAQ, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202402847

Arnout

On Sat, Sep 5, 2026, at 00:19, Scott Lewis via open-regulatory-compliance wrote:

Could you please point to where 'under certain circumstances' is defined/detailed?  And is there any online version of the CRA text?...so that the relevant Articles could be pointed to?

Thx.

On 9/4/2026 1:00 PM, Juan Rico via open-regulatory-compliance wrote:

Dear ORC community, and especially to those planning to act as stewards!

The European Commission has updated the EC CRA FAQ today bringing clarity to a topic that has been largely discussed.

The new FAQ entry published today 5.5 says:

"5.5 Are open-source software stewards subject to reporting obligations under the CRA?
Article 24(3) of the CRA establishes that reporting obligations laid down in Article 14, paragraphs (1), (3) and (8), apply to open-source software stewards under certain

circumstances.

In accordance with Article 71(2) of the CRA, Article 24(3) shall apply from 11 December 2027."

Hope this helps, have a great weekend.

Juan

--

Juan Rico

Senior Manager ORC, Oniro and Cloud Programs | Eclipse Foundation Europe GmbH | X | LinkedIn | YouTube | Instagram | Bluesky | Mastodon

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