Preparing Internal Detection, Escalation, and Decision-Making Processes

Article 14 is often discussed as a regulatory question, but operationally it is an internal-process question. The official platform and structured forms are straightforward once understood. The difficult part is everything between the first faint signal that a product is under attack and the moment a named person decides to file an early warning.

Detection has to draw on every channel that could carry an exploitation signal: the coordinated disclosure inbox, customer and support reports, internal telemetry, threat intelligence, and contact from authorities. These channels work only when they funnel into a single triage process that someone owns, with prompt acknowledgement and a short triage service level.

Escalation must run under the worst conditions, out of hours and with ambiguous signals, which means a single known route, always-on coverage, a low threshold to escalate on suspicion, and a documented runbook. The most underprepared element is decision authority. Filing a 24-hour early warning should not wait for executive or legal sign-off. Naming a role with standing authority to declare a reportable event and file the preliminary early warning is the highest-leverage preparation a manufacturer can make.

This is the fifth article in our six-part CRA reporting series.