Draft the Article 14 report from evidence already assembled — the exploitation proof, the models still in the field, the date a fix became available — and leave the trigger to a named person.
A report of exploitation arrives, and the clock runs from awareness, not from the day the ticket was triaged.
02
A finding meets Art. 3(42) only on reliable evidence of exploitation, never on a severity score.
Reason
03
A legacy model stays in scope — Art. 69(3) reaches products placed on the market before 11 Dec 2027.
04
An incident is read against the Art. 14(5) limbs, the capable-of limb included, by a named person.
05
A fix becomes available, and that date, not the drafting date, starts the 14-day clock.
Decide
06
A severe incident closes one month after the notification, so the two final clocks never run together.
07
A channel is checked before it is needed — ENISA had published no platform URL and no API on 23 August 2026.
Out
08
A record is kept whole — the evidence, the estate it reached, the drafts and the person who submitted.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent drafts and keeps the record; a named person decides the trigger is met, signs the report and submits it, and the manufacturer answers for it.
Example workflow
One finding, evidence to submission
AgentHuman
1Exploitation evidence receivedVulnerability tracker, researcher report, telemetry or a CSIRT contact
2Affected estate assembledSKUs, firmware ranges, legacy models still in the field and the component mapping behind each
3Report draftedEarly warning, notification and final report against the fields ENISA publishes
4Controls appliedClock checks, evidence-sufficiency checks, estate-coverage checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is reported at any of them — the agent is drafting, and the product security lane opens at the completeness gate.
5DecisionBranches at the completeness gate
Evidence sufficient
Goes to the product security lead to submit.
Anything thin
Adds a regulatory counsel read first.
Product security review
The draft is held with its clocks, its evidence and its gaps.
Submit the report · Append evidence · Send to counsel
Submitted — by a named person▼
6Tracker and case records updatedOnly where write access and disclosure policy allow it
7Outcome evaluatedClock margin, evidence completeness, counsel corrections and what a later review found
Corrections
Each counsel correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Deciding a vulnerability is actively exploited.
Submitting to a CSIRT, to ENISA or to any authority.
Signing or sending an early warning.
Deciding an incident is severe under Art. 14(5).
Automation boundaryAgent acts unaided
✓Assemble the exploitation evidence and name the source it came from.
✓Run each reporting clock from the moment of awareness.
✓Map a component finding to the SKUs your SBOM depth reaches.
✓Draft the report against the fields ENISA publishes.
Nothing reaches an authority except by a named person, inside the agreed boundaries.
Judging that a legacy model has left scope.
Telling a user their product is unaffected.
Setting a support period, or reading one into a DoC.
Changes to trigger rules, clocks or report templates.
Example output
One finding, annotated
No platform URL and no API were published on 23 August 2026, and the record is what a person submits from.
Report draft · single findingIllustrative example
Finding
Drafted as
Clock
Evidence of record
Confidence
Held for
Gateway firmware, legacy range
Early warning, actively exploited, evidence attached
Hour 9 from awareness
Researcher packet, 21 August 2026
Held unsubmitted
The product security lead, in person
As receivedTaken from the researcher packet and the build inventory — the mapping reaches as far as the SBOM does.
What the record holdsThe exploitation proofAffected-range mappingFix-availability date
Why no trigger call hereReliable evidence is the Art. 3(42) test, and the July 2026 guidance is non-binding.
ActionSubmit the reportAppend evidenceSend to counsel
What the score decidesBelow the configured threshold the draft picks up a counsel read before.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every findingFrom the vulnerability tracker
03Evidence
One product, one regulation
R155 type approval belongs to our automotive agent and plant OT to our manufacturing one; this is a product in the field.
01Approved path
What the evidence showed
Art. 69(3) applies Article 14 to every in-scope product placed before 11 December 2027 — the date Art. 64 penalties start.
02Human review
Where the support period lives
In the notice our firmware agent echoes, not in the EU declaration of conformity — and Art. 13(8) sets a floor that expected use time can lower.
04Build an evidence trail
The evidence, the product range it reached and the person who reported stay on the record.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Reporting channelsENISA Single Reporting Platform Coordinating CSIRT contacts
A portfolio-level trigger-evidence figure can read clean while one product family absorbs most of the corrections. Nestack reports the counsel-correction rate by product family, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Legacy models still in the field
10.4%
3.6×
Review
Products on third-party stacks
7.9%
2.8×
Review
Connected consumer devices
4.8%
1.7×
Watch
Current-generation industrial units
1.9%
0.7×
Normal
Bar: counsel-correction-rate lift vs. current-generation industrial baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an unreconstructable record costs
A cycle closes when the missed legacy model is a regression case. That suite is what the next report drafted is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Counsel-correction rate rises in one product family.
02Diagnose
The exploit report that named a model line nobody still shipped is read back until one cause remains.
03Improve
The change ships numbered, and the findings that forced it ride with it.
04Verify
Nothing releases while one touched product case is still red.
05Learn
It is kept permanently, and the trigger rules are amended in the very same commit.
Learn → DetectThe return edge. The next report is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, report assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Reporting-workflow discovery and boundary definition.
02Tracker, PLM and telemetry sources.
03Trigger-rule, clock and affected-estate mapping.
04Evidence ingestion and normalisation.
05Estate, component and SBOM-depth binding.
06Completeness scoring and counsel routing.
07Reporter submission workflow.
08Tracker and case-system integration.
09Trigger and evidence cases.
10Guardrails and reporting controls.
11Finding-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne product family, one channelProductionProduction reporting workflowAdvancedMultiple families / regions
Introduced at Pilot
Report drafting to your rules✓✓✓
Named-reporter submission✓✓✓
Product-estate baseline✓✓✓
Introduced at Production
Reporting by product family—✓✓
Submission workflow in your systems—✓✓
Approved write-back—✓✓
Vulnerability-tracker integration—✓✓
Introduced at Advanced
Multi-authority reporting duties——✓
Cross-family evidence packs——✓
High finding volume——✓
Multi-authority notification controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your product estate and build records→Estate ingestion and component mappingWeek 1
02Representative findings and advisories→Draft baseline, clock binding and evidence captureWeek 2
03Your trigger rules and reporting channels→Trigger-rule, clock and channel mapping and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Tracker, PLM and telemetry assessment, then integration setupWeek 2
05Findings you would not want reconstructed→Trigger cases and failure-mode testingWeek 4
06What no draft report may assert→Completeness scoring, counsel routing, guardrails and submission controlsWeek 3
07A named product security lead to submit→Reporter submission workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
These bands are the weeks each phase honestly costs, and that is why the fifth of them carries two.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Reporting workflow discovery, trigger mapping and the automation boundaryW2Source integration and the estate baselineW3Draft assembly, clock logic and submission controlsW4Evaluation suite, trigger cases and failure-mode testingW5Tracker integration, pilot findings and targeted correctionsW6One reporting quarter run under the product security lead, then Agent Care handover
Reading the bandA bar covers only the weeks its own work is named in. The doubled fifth week is real work, not padding.
At the end of W6Validation closes on live findings, and Agent Care picks up the watch.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Electronics AI agent
Build a CRA reporting agent around a clock that starts without warning.
Show us how a finding reaches you today and who submits on 11 September. If anything you placed on the market before December 2027 is still in the field, then Art. 69(3) already puts it inside Article 14, and the record is read back long after.
