When do Art. 14 reporting obligations apply to open-source software stewards?

[maertsen]

Article 71 states that the CRA will apply from Dec 11, 2027. It also states that Article 14 will apply earlier, from Sept 11, 2026.

Article 14 specifies reporting obligations for Manufacturers.
Article 24 says Article 14 applies to stewards.

When does Art. 14 enter into effect for stewards?

[rozhukov]

Is it a typo Maarten? Sept 11, 2025 -> Sept 11, 2026?

Article 71 sets the timeline. It states that the regulation generally applies from December 11, 2027 and creates a specific exception for Article 14 (Reporting Obligations), stating it shall apply earlier, from September 11, 2026. Article 24 does not set its own independent timeline for reporting, but instead, it references the obligations in Article 14.

Article 24 explicitly states that "The obligations laid down in Article 14(1) and Article 14(3) shall apply to open-source software stewards..." Because Article 24 creates a dependency on Article 14 and don't distinguish Stewards from Manufactures in any way, I'd say Sep 11, 2026 is the date for both Stewards and Manufacturer. It's how I read it, IMHO.

[maertsen]

Is it a typo Maarten? Sept 11, 2025 -> Sept 11, 2026?

Indeed, I'll update it.

I can follow your explanation, and I would not mind at all if that's the known good answer.

[tobie]

I agree with @rozhukov. Also what would be the rationale to delay reporting obligations of stewards? If there was such a rationale, it would be spelled out in a recital somewhere.

[maertsen]

FWIW:

• I contacted the EC, who confirmed receipt, but I have yet to receive an answer.
• in a public webinar with the Dutch Ministry of Economic Affairs and the Dutch MSA (RDI) just now, September 11 2026 was mentioned as the correct date.

For now, for stewards located in NL, September seems prudent. Worst case, there is some spare time :-)