Four dates
| Date | What applies | Provision |
|---|---|---|
| 10 December 2024 | Entry into force. No obligations yet, but the transition clocks start. | Article 71(1) |
| 11 June 2026 | Conformity assessment bodies may be notified. If your product needs a notified body, this is when you can start booking one — and capacity is finite. | Article 71(3) |
| 11 September 2026 | Article 14 reporting obligations apply, including to products already on the market. | Article 71(2) |
| 11 December 2027 | Full application. Essential requirements, CE marking, technical documentation and the declaration of conformity. | Article 71(2) |
Does shipping before December 2027 help?
Article 69(2)
Less than people hope. Products placed on the market before full application are only caught if they are substantially modified after that date — but two things bite regardless.
- The Article 14 reporting obligations apply from September 2026 to products already on the market.
- A substantial modification makes the product a new product, requiring full conformity assessment. For actively developed software, that is a question of when rather than whether.
What to do with the time
The work divides into things you can only do once (the risk assessment, the architecture description, the support period reasoning) and things that must be continuous (the SBOM, the vulnerability position, the disclosure process).
The continuous things are the ones to automate first, because they are the ones that go stale between now and the deadline — and the ones an authority can check most easily.