Friday, October 23, 2026

SMS OTP Ban: Who Has Made It Law

Here is the rule that should be compulsory: no bank may let a texted code be the only second check on a login or payment. That is an SMS OTP ban, and four markets already enforce one. Britain and the US only advise it. The objection, that a ban shuts out people without smartphones, is answered in the US government's own identity rulebook.

Bank code diverted to a swapped SIM: the case for an sms otp ban

Picture what it prevents. A fraudster talks a mobile shop into moving your number to a new SIM, your phone loses signal, and your bank's next code lands in their hand.

TL;DR: Four markets force banks off text codes; UK and US customers must make the switch themselves.

  • The UAE set 31 March 2026 for banks to drop SMS and email codes.
  • NIST says texted codes are not phishing-resistant but keeps alternatives open to everyone.
  • A synced passkey on your current phone meets NIST's middle bar at no extra cost.
  • Count logins that accept a text code alone: one SIM swap opens all of them.

Why is SMS OTP not secure enough for bank logins?

A texted code proves only that someone controls your phone number, and both the number and the code can be taken from you without touching your handset, through a SIM swap or a fake login page.

NIST SP 800-63B-4, the US federal identity guideline dated August 2025, says out-of-band authentication "is not phishing-resistant": type a texted code into a fake bank page and the attacker relays it, however fast you act. Telling people to be careful with codes is outdated advice.

It also classes SMS codes as "restricted" and tells services to check for SIM changes first. Cifas's Fraudscape 2025 report, published 7 May 2025, found unauthorised UK SIM swaps rose 1,055% in 2024; each swap hands the victim's bank codes to someone else.

Four numbers decide whether a ban is practical. Two come from that Cifas release; two are our arithmetic from the UAE and NIST documents.

UK SIM Swaps in 2024

Nearly 3,000

Each one hijacks your bank texts

Takeovers Hitting Phone Accounts

48%

Your number is the target

UAE Cut-Over Window

8 months

Derived: a whole market switched

Extra Kit for a Passkey

£0

Derived: your phone already qualifies

The cost card kills the banks' usual excuse. NIST permits exportable keys at AAL2, its middle assurance level, and bars syncable authenticators only at AAL3, so on our reading a synced passkey on your phone clears the bar.

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When nearly half of account takeovers involve a mobile phone account, a code sent to that phone is not a second factor. It is the same weak point, asked twice.

Britain already legislates security floors when advice fails, as its ban on default passwords in connected devices shows, and NIST is extending identity rules to AI agents that log in on your behalf. Bank logins remain the gap.

Which countries have made an SMS OTP ban law?

Four markets in our compilation compel banks to move customers off texted codes, namely the UAE, Singapore, Malaysia and the Philippines, while the UK and the US still treat the switch as advice rather than law.

Singapore's date is from the Monetary Authority of Singapore's 9 July 2024 release; the others are as reported by Newsonair, Bernama and the Daily Tribune. Britain's NCSC said on 23 April 2026 that passkeys "should now be consumers' first choice of login", but set banks no date.

Market Rule and date What it means for you
⏱ UAE SMS and email codes gone by 31 Mar 2026 App or face check approves payments
🔒 Singapore Login codes phased out from July 2024 Activated token logs you in instead
⚖️ Malaysia Banks ordered off SMS codes, Sept 2022 Major banks reported done by July 2023
⚖️ Philippines Risky transfers off SMS from 25 June 2026 Texts still allowed for balance checks
⚖️ UK and US Advice only, no removal date Text code stays until you change it

The UAE finished inside one UK financial year; the Philippines, whose circular dates to May 2025, gave banks about 13 months. Our call: a UK regulator could set a 12-to-18-month deadline, asking nothing the Gulf and Southeast Asia have not already done.

Six markets in this article 4 of 6 compel the switch 2 of 6 advise only Compel: UAE, Singapore, Malaysia, Philippines Advice only: UK, US

If you bank in the UK or US, you are in the third of these markets where no rule removes the text code. Our count from the sources above; compelling means a published rule with a date.

Worked example: assume six logins: current account, savings, credit card, PayPal, pension and email. Four (current account, credit card, PayPal, email) accept a texted code alone. One SIM swap reaches 4 of 6, two thirds. Move email and current account to passkeys: 4 minus 2 leaves 2 of 6, one third, halving your exposure.

Now do your own one-swap count: list your money and email logins and count those that accept a text code alone. That number, found in under a minute, is your exposure today.

Would banning text codes lock out people without smartphones?

No, a ban written NIST's way removes the texted code as a sole factor while requiring services to keep other authenticator types open to every customer, so nobody depends on a smartphone.

NIST requires that "alternative authenticator types are available to all subscribers" and that verifiers "SHALL offer at least one phishing-resistant authentication option at AAL2". Texts survive as one route, never the only one. But SP 800-63 binds US federal agencies, not private banks.

Hardware is the fairer objection: passkeys need a phone that still gets updates, which is why we argued devices should print their end-of-support date at the point of sale. Recovery is the real grey area. If a lost phone means the bank lets you back in by text, the weakness returns by the side door. Our view, only an opinion: the fallback should be slower, not weaker (a branch visit, say, or frankly anything a phone shop cannot redirect).

Watch for these:

  • Silent fallbacks: some passkey apps still accept a text via "try another way".
  • Email resets: email recovered by text undoes your passkeys.
  • Lockout: with no second device or backup codes, removing texts can lock you out.
  • Number ports: ask your network what it checks before moving your number.

Key Takeaways to act on: check your own setup

  • Your bank app offers passkeys, yet still lets you pick a text.
  • Your email recovery number is the one your bank texts.
  • You do not know what your network checks before issuing a SIM.
  • You have no second device or backup codes for your bank.

SMS codes should be banned as the sole second factor for UK bank logins, with a deadline: the markets that did it finished in about a year, and alternatives, not texts, protect people without smartphones. Until then, set the rule yourself this week: turn on a passkey or in-app approval in your bank's app, switch off the text-only route, then do the same for your email. No second device or backup codes? Keep the text option until you have one. The NCSC's passkeys guide (undated, retrieved 23 October 2026) shows how.

How we checked this

We read NIST SP 800-63B-4 (page dated 26 August 2025) and its Authenticator Assurance Levels section, plus the Cifas Fraudscape 2025 release of 7 May 2025 and the regulator releases and reports cited above. The worked example assumes six logins, four protected by a texted code alone. No product was tested hands-on for this article. Last verified: 23 October 2026.

Edited by Sheftali, reviewed after publication. Spotted something out of date? Tell us and we will correct it.

Tuesday, October 20, 2026

End of Support Dates Are Hidden

UK law already requires every connectable device to publish its end of support date. The objection is that a web page is enough for anyone who cares. It is not, because the buyer decides at the till, and that date sits where the buyer is least likely to look. Every connected device should print it at the point of sale.

Blank shelf tag beside a phone, with an end of support date hidden online

Key Takeaways

UK law requires makers to publish a minimum security update period and an end date, but it does not require either to be shown at the point of sale.

  • The rule has applied to connectable products sold in the UK since 29 April 2024.
  • The date must be published clearly, free, in English, and without a request from the buyer.
  • None of the five conditions names the box or the shelf, so you find the date only by searching.

Why the end of support date stays hidden

The end of support date stays hidden because the UK rule asks makers to publish it on a web page, not to show it in the shop, so a buyer at the shelf sees nothing the rule requires.

The UK product security regime came into force on 29 April 2024. Schedule 1, paragraph 3 says a maker must state the minimum security update period along with an end date, published clearly, without a request, free, and in English. Read that closely and the box is absent. So is the shelf. The buyer gets the date only from a page they must first think to open.

Ask who carries the cost of this gap. The maker has had two and a half years to comply, yet the shopper pays for the uncertainty at the till. A date that arrives after the purchase is a date the buyer cannot use to choose.

Four figures frame the gap, and each one answers a question a buyer has at the shelf.

Makers' time to comply

2.5 years

Since the UK rule took effect

Conditions on the notice

5 conditions

Each one must be met

Conditions naming the box

0 of 5

Shoppers see nothing in store

End dates per product

1 end date

Required, but not at the shelf

Read the cards together. The compliance window is long and the conditions are many, yet the place a shopper stands appears in none of them. The 2.5 years is our own arithmetic from the April 2024 start date to October 2026, not a figure any regulator published. The end date is required, and still not required where it would change a purchase.

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Makers must meet five conditions for the end-date notice. None of them puts the date in front of a shopper.

Does a device maker have to tell me when support ends?

Yes, if the product is a connectable device sold in the UK, the maker must state the minimum security update period together with an end date, but the law does not say where you will see it. That answer is the whole legal question in one line.

Schedule 1 paragraph 3 pairs the period with the date, which is the number a shopper needs. It does not fix the place, so the maker chooses it. For the same design in another rule, our piece on how the default password ban treats labels shows a floor set by law with the packaging left to the seller.

What is the minimum security update period under UK law?

Under the UK regime, the minimum security update period is the shortest support commitment the maker states for a connectable product, and it must come with an end date. The law makes the maker state it, not promise any particular length.

The figure belongs to the maker, not the regulator. Two phones sold side by side can carry very different commitments, and both can be lawful. That is the reason to compare the stated period rather than assume a standard. If you buy from the EU, the clock runs faster, as our note on the Cyber Resilience Act reporting deadline explains.

How long will my phone get security updates?

It depends on the period the maker has stated, which the law requires them to publish alongside an end date, and that figure can differ from one model to the next in the same brand range. Check the product page for that date before you buy, because the box will not tell you.

Two rules of thumb follow. Read the end date rather than the marketing, and when the page gives no date, treat the product as one with no promised support.

Which situation are you in?

The right step depends on whether you are buying a phone, a connected car part or something sold with no UK page at all, and the table sets out what to do in each case.

Scenarios matter because the rule treats a phone on a UK shelf differently from a car head unit, and the buyer needs to know which one is in front of them.

If youDo thisBecause
🛒 UK phone shopFind the end date on the product pageRequired since 29 April 2024
📋 No date foundSearch the maker's website for the date5 conditions, all must be met
🚗 Connected car partAsk the dealer for the update periodAutomotive carve-out is expected
🏁 No date anywhereTreat the device as unsupportedNo stated commitment to rely on

The default row matters most. A product with no date gives you no promise to rely on, and that is worth a question to the seller before you pay.

5 conditions End date stated Published clearly Not on request Free of charge In English

Does UK law require the end date at the point of sale? No: none of the five conditions names the box or the shelf. Each slice is one condition in Schedule 1 paragraph 3 of the UK product security rules, so the chart counts conditions rather than showing a share.

Where the rule runs out

The end-date rule has gaps, because some products sit on an exception list, a car carve-out is still being drafted, and a seller with no UK page leaves the buyer with nothing to check.

Schedule 3 lists excepted products, and automotive is expected to be carved out by a statutory instrument that is not yet in force. A connected car head unit can therefore fall outside the rule, and the buyer cannot tell which list applies from the showroom floor. Disclosure is thin elsewhere too, as our note on how few top domains publish a security.txt file shows.

  • Check whether the product sits on the Schedule 3 exception list before relying on a date.
  • Ask for the security update period in writing if the product page shows none.

Check these before you buy

  • The product page names a minimum security update period and an end date for this exact model.
  • The date is visible without asking a shop assistant for it.

Make the date a condition of the sale. If the product page shows no end date by the time you reach the till, ask the seller for it in writing, and walk away if they cannot give one this week.

Wednesday, October 14, 2026

security.txt: 1.25% Have One

Every company that sells software or a connected device should be legally required to publish where a stranger can report a security bug, and to promise someone will read it. The cheapest form is a plain text file called security.txt, and only 1.25% of the top million domains have one, per a URIports scan on 24 January 2025. On roughly 98 of every 100 big sites, a researcher who spots a hole has nowhere to send it.

Poster on security.txt showing a laptop with cracked padlock beside an empty letterbox

TL;DR: a published, monitored channel for security reports should be compulsory, and the rule must demand a reply, not just a file.

  • The UK has required device makers to publish a reporting contact and reply timings since 29 April 2024.
  • The EU requires a published disclosure policy from 11 December 2027; the US binds only its own agencies.
  • A listed address that bounces helps nobody, so test your own channel.
  • Write the rule around an answer, not around a file.

Why should security.txt be compulsory?

A security bug report is only useful if the right person receives it, so a public, monitored contact turns a stranger's warning into a fix, while a voluntary one leaves most sites silent.

The format is simple. RFC 9116, the 2022 internet standard for the file, asks for a contact, an expiry date and an optional policy link. The CRA's 24-hour reporting duty assumes a vendor hears about the bug first: before a vendor can tell regulators within a day, someone has to be able to tell the vendor.

Neef, Schlunke (TU Berlin) and Hennig (KIT), in a paper posted to arXiv in June 2026, tracked the 40 largest German listed firms from 2023 to January 2025: adoption of the file or a formal disclosure programme went from half the group to nearly all of it. One country, 40 firms and no proof of cause, but firms plainly move when a deadline is visible.

Voluntary effort is not nothing. By my arithmetic from URIports' two scans, domains with the file rose from 6,816 in April 2024 to 12,510 in January 2025, roughly 84% in nine months. I still disagree that good practice will spread alone: most sites stay silent and attackers do not wait. The UK wrote the duty into law with its default-password ban for connected devices instead of hoping.

Four figures test whether a bare file does the job: the European Commission's CRA page sets the dates, the TU Berlin and KIT paper sampled security mailboxes, and URIports checked the files themselves.

Months between two EU duties

15 months

Vendors report out before listening

Big German firms with a channel

37 of 40

Large firms moved; small unknown

Listed security inboxes that bounced

46%

A listed address may be dead

Files that follow the standard

44%

Most files fail the standard

The bounce figure is the one I would show a regulator. The sample was small, 26 generic security addresses, so it is a warning light rather than a rate. Still, a finder whose email errors out has done everything asked; the failure sits with the company, and only a duty to acknowledge, as UK law now sets, closes it.

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An address that bounces is a promise nobody keeps. The law should demand an answer, not just an address.

Is a vulnerability disclosure policy required by law?

It depends on where you sell: UK law already requires consumer-device makers to publish a reporting contact, EU law will require a coordinated disclosure policy from December 2027, and US federal law requires it only of agencies.

Schedule 1, paragraph 2 of SI 2023/1007 makes the UK maker of a relevant connectable product publish a contact plus timings for acknowledgement and status updates, free and in English (as of 2024). The EU's Cyber Resilience Act, Regulation 2024/2847, requires in Annex I, Part II, point 5 a policy on coordinated vulnerability disclosure; the European Commission's CRA page gives the dates (checked 14 October 2026). CISA's Binding Operational Directive 20-01 applies the idea to US federal agencies only (as of 2020).

Category Detail What it means
⚖️ UK rule Live since 29 Apr 2024: contact plus reply timings ✅ Buyers can demand a reply
⚖️ EU rule Reporting out from 11 Sep 2026, policy from 11 Dec 2027 ⚠️ The listening duty comes last
⚖️ US rule Federal agencies only, since 2 Sep 2020 ❌ Their suppliers are not bound
⏱ Reply clock CISA suggests: acknowledge in 3 business days, assess in 7, resolve in 90 ⚠️ A benchmark, not a legal limit
🔒 Safe harbour Agencies must not pursue good-faith finders ✅ Finders can speak without fear
🛠 Quick test Email your own security address ✅ One email proves it works

The UK and EU put the duty on the people who profit from the product; the US puts it on its own civil servants and leaves the vendors it buys from to volunteer. My view: that is backwards, because unanswered reports pile up in the market, not in one agency's inbox.

2 Sep 2020. US agencies. 29 Apr 2024. UK devices. 11 Sep 2026. EU reporting. 11 Dec 2027. EU full duty.

Where you sell decides whether a public reporting channel is already your legal duty. Source: CISA BOD 20-01, SI 2023/1007 and the European Commission's CRA page.

What goes wrong when a file is all you ask for?

A file proves only that someone typed a few lines once: a published, unmaintained one can point to nobody, which is why the rule must demand a working, answered channel rather than a text file.

RFC 9116 makes the expiry date a required field, yet URIports found 45% of files carry no Expires line and another 13% had already expired. Fewer than half follow the standard, so by my arithmetic roughly one top-million domain in 180 publishes a file that does; that is derived from two published rates, not a URIports figure. The objection that a file is cheap theatre is half right. Call it a file, then correct that: the file was never the point, the reply is.

The other objection is that a mandate would bury small firms. The UK text is gentler than critics assume: it asks when a reporter can expect an acknowledgement and updates, not a deadline for the fix. Whether a one-person shop should carry the same duty as a listed company is the real grey area; in my opinion, yes to acknowledging, no to fixing on a clock. Voluntary targets end badly: the CISA and FBI memory-safety roadmap set a 1 January 2026 date that binds nobody. Watch for these in your own setup:

  • An empty Expires field or a lapsed date.
  • A security address routed into a general support queue.
  • No named owner, so the reply is nobody's job.
  • A policy that threatens finders into silence.

Check which of these is true for you

  • You sell a connected device to UK shoppers and your site never says how to report a flaw.
  • Mail to your security address lands in a shared queue someone else triages.
  • Your file's expiry date has passed, or nobody owns the renewal.
  • A researcher writing to you has no written promise you will not sue.

The decision is whether to wait for the law or run a monitored channel now, and the answer is now. This week, email your own security address from a personal account and time the reply: a bounce or silence tells you what to fix first.

Wednesday, October 7, 2026

Default Password Ban: Why Labels Fail

Every router, camera and smart plug sold in the United States should be legally required to carry a password unique to that unit, or make you set your own, before it touches your Wi-Fi. Britain has enforced exactly that default password ban since 29 April 2024. America chose a sticker. The standard objection says a voluntary label lets shoppers reward careful makers without Washington writing firmware rules. It sounds reasonable, until you see what the sticker has done since.

Infographic arguing for a default password ban, with a router and an open padlock

Key Takeaways: a ban works because it covers every box on the shelf; a voluntary label covers only the makers who choose to apply.

  • British buyers get unique or user-set passwords on smart devices by law, no label needed.
  • The US label is optional, so a maker that skips it loses nothing but a sticker.
  • California and Oregon prove makers can comply, so a federal rule mostly extends firmware they already ship.
  • Until Washington acts, check for a unique or set-your-own password before you buy.

Why a default password ban beats a label

A ban beats a label because it protects the buyer who never reads packaging, never registers the device and never changes a setting, while a label protects only the shopper who already knows to look for it.

The British version, set out on GOV.UK's product security regime page, is blunt: passwords must be unique per product or set by the user. Makers must also publish a route for reporting security bugs and say how long they will ship security updates. A British buyer gets that protection without knowing the law exists, which is the whole point of a rule.

America took the other road. The FCC approved the US Cyber Trust Mark on 14 March 2024 as a voluntary label, CyberScoop reported, so a US shopper gets password protection only when a maker opts in. Its lead administrator, UL Solutions, then withdrew on 19 December 2025 amid an FCC probe into its China ties, says Cybersecurity Dive. The FCC named the ioXt Alliance in its place on 13 April 2026, Broadband Breakfast reported, and won't pay for the job. By my count, the label shoppers were told to trust sat with nobody in charge for nearly four months.

Washington has been here before: its memory safety roadmap deadline for critical-infrastructure software carried no penalty and passed quietly. Europe binds vendors instead, as the Cyber Resilience Act's 24-hour vulnerability warning shows. Four figures from GOV.UK, the PSTI Act 2022 and Broadband Breakfast show the gap.

UK Rule in Force So Far

29 months

Every UK sale since April 2024

FCC Money for the US Label's Administrator

$0

Runs on industry goodwill

Legal Duties on Each UK Device

3

Covered without reading anything

Top UK Fine as Share of Revenue

4%

Scales up for global brands

A fine pegged to worldwide turnover is too big for a global router brand to treat as a cost of selling in Britain, so the cheap answer is one firmware build for every market. You just can't tell from a US box which makers did it.

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Britain needed no sticker to make every router safer. Washington's sticker can't even pay the people meant to run it.

Does the UK ban default passwords on smart devices?

Yes, the UK has banned universal default passwords on consumer connected devices since 29 April 2024, requiring each product to ship with a unique password or make the buyer set one, under the Product Security and Telecommunications Infrastructure regime.

The table sets that law against the US label, read as a buyer standing in a store.

Dimension UK law vs US label What it means for you
💰 Cost of skipping UK Fines up to £10 million
US No penalty at all
❌ US makers risk nothing by opting out
⚖️ Who must comply UK Every maker selling there
US Only makers that apply
⚠️ In a US store, you vet each box
🔒 Password rule UK Unique or user-set, all models
US Same idea, labelled models
✅ Labelled gear meets the British bar
🛠 Who runs it UK A standing regulator, OPSS
US No lead for 115 days
❌ Oversight can lapse with no warning
🌍 Coverage UK The whole country
US State law in 2 of 50
⚠️ Your ZIP code sets your protection
🏁 Best suited for UK Any buyer, no homework
US Buyers who read every box
🏁 Law wins whenever a shopper is rushed

Read down the right-hand column: the label helps only buyers who already do the work. The first-row fine comes from the PSTI Act 2022; the 115-day gap is my arithmetic from the reported dates above.

California. and Oregon. 2020 State law, in force. United Kingdom. 2024 National law, in force. European Union. Dec 2027 Law, applies soon. US federal level. None Voluntary label only.

Outside California and Oregon, no US law guarantees that the next router you buy ships with a unique password. Dates come from each jurisdiction's own text: California SB-327, the UK PSTI regime and EU Regulation 2024/2847.

Do routers have to come with unique passwords?

Only in some places: in Britain since April 2024, in California and Oregon since 2020, and across the EU from December 2027, while a router sold in the other 48 US states can still legally share one factory password.

California's SB-327, operative since 1 January 2020 (as of 2020), demands a password "unique to each device manufactured" or one the user creates. Oregon passed a near-copy. The EU's Cyber Resilience Act, on EUR-Lex, requires a secure by default configuration once its main obligations apply on 11 December 2027. So the "too costly" objection collapses: the engineering exists, and the biggest US state has demanded it for years.

The second objection calls default passwords a niche consumer worry. CISA disagrees. In December 2023 (as of 2023) its Secure by Design alert urged makers to drop default passwords after attackers reached Unitronics controllers at US water facilities; CyberScoop reported their factory password was 1111, so one shared login opened every identical unit. The federal security agency called it a manufacturer failure in writing, then only asked nicely. As with post-quantum migration deadlines, guidance without teeth moves at the pace of the slowest vendor.

One grey area remains, and this is opinion: should a federal rule reach devices already in homes? I'd cover new sales only, because retroactive rules invite lawsuits that stall everything. Watch-outs meanwhile:

  • A Cyber Trust Mark helps, but its absence proves nothing.
  • An app-based setup can leave the local web login on its factory value.
  • Marketplace imports may follow no national rule.

Check these before the device goes on your network

  • Setup forces you to create your own admin password, or the label shows one unique to that unit.
  • The maker's site names a security-update end date for your model.
  • The maker publishes a way to report security bugs.
  • The login printed in the manual stops working after setup.

So here's the decision. If you're in the US, treat the label as a bonus and the password check above as the real test, and this week log in to your own router and replace any password printed in its manual. Then tell your representative that Britain already proved the rule costs makers almost nothing.

Related: the UK product security law behind default-password bans

Related: why an SMS OTP ban should be compulsory for bank logins

Thursday, October 1, 2026

Memory Safety Roadmap: The 1,000x Case

Here is the rule. Under the Product Security Bad Practices guidance from CISA and the FBI, a maker of software used in critical infrastructure that had no published memory safety roadmap by January 1, 2026 is, in the agencies' own word, "dangerous". The date came and went. Your firewall vendor, your hospital's imaging supplier, the firm behind your water utility's control panels: none of them owed you a thing when it passed.

Circuit board with a padlock on its memory chips, illustrating a memory safety roadmap

The flaw is in the rule. The same document says it "is non-binding" and "imposes no requirement", so the risk of a missing plan sits with you, the customer. It should be compulsory. And the standard objection, that leaving C and C++ is too slow and too costly, no longer survives the data.

Key Takeaways

Yes, a published plan to retire memory bugs should be compulsory, and buyers can enforce one through contracts today.

  • The federal date passed with no penalty, so the risk sits with the customer.
  • Memory-safe code cut Google's largest bug class without slowing releases.
  • Products near end of life are exempt, so ask for support end dates first.
  • Write a dated plan covering network-facing code into your next renewal.

Is CISA's memory safety guidance mandatory?

No, CISA's memory safety guidance is voluntary: the agencies call a missing roadmap dangerous for critical-infrastructure software, but attach no fine and no procurement ban, so a vendor that ignored the January 2026 date faces nothing.

Washington has stayed in that register. A June 2025 NSA and CISA information sheet on memory safe languages (Rust, Go and others that stop code touching memory it does not own) says the agencies "urge organizations to consider whether adopting MSLs is practical for their circumstances." That hands every vendor two exits, "consider" and "practical". A buyer waiting for a federal push is waiting for something the government has said, in writing, it will not do.

Other regulators have been less shy. Europe wrote vulnerability handling into law, down to the 24-hour exploited-vulnerability warning the Cyber Resilience Act demands. Even NIST put calendar years on its post-quantum migration deadlines. Memory safety, the older and better-understood problem, got an adjective.

Is Rust really safer than C++?

Yes, by a margin that ends the argument. A November 2025 Google report, Rust in Android, found its roughly 5 million lines of Rust running at about 0.2 memory-safety vulnerabilities per million lines, against roughly 1,000 in its C and C++, a reduction Google puts at more than 1,000x. That kills the excuse that safer languages just move bugs elsewhere.

But the objection was always about cost: rewriting slows teams, and ship dates pay salaries. Four numbers test that. Google's Android data supplies two, measured on changes of comparable size. MITRE's CWE Top 25, released in December 2025, supplies a count of memory errors among the most dangerous weaknesses. The calendar supplies the last.

Days Past the Federal Date

273 days

Every one at your risk

Code Review Time Saved

25% less

Reviewer hours handed back

Memory Flaws in CWE Top 25

6 of 25

Worst weaknesses a plan retires

Rollback Rate, Rust vs C++

4x lower

Fewer broken releases to undo

Show the rollback figure to a sceptical finance director. A rollback is a release pulled after shipping, usually an outage and a lost weekend. Fewer of those means the cost objection runs backwards.

"

The safer code also broke four times less often. Speed was the excuse, and Google's own releases retired it.

With no regulator compelling a plan, your contract is the only lever left.

What a required memory safety roadmap changes for buyers

Requiring the plan turns a vendor's vague intention into a dated, auditable commitment that covers its riskiest code first, which gives a buyer something to enforce at renewal instead of a hope.

Dimension Optional vs Required What it means for you
💰 Cost of skipping Optional nothing under federal rules
Required a breach you can enforce
❌ The vendor's risk lands on you
⏱ Deadline Optional 1 Jan 2026, already missed
Required a date you set and enforce
⚠️ Only your contract makes it bite
📊 Flaws per 100k Optional about 100 in C or C++
Required about 0.02 in new Rust
✅ New code stops adding the top bug class
🔒 Fix order Optional whatever the vendor picks
Required network, crypto code first
✅ Your exposed surface is fixed soonest
⚖️ Legacy escape Optional every product, forever
Required support ends before 2030
⚠️ Ask each vendor for its end date
🛠 Proof on file Optional a promise on a sales call
Required public, like F5's Feb 2026
✅ You can audit it against releases
🏁 Best suited for Optional tools you retire this decade
Required anything facing the internet
🏁 Default to required for edge vendors

The flaw-rate row is my arithmetic, not Google's: Android's measured densities scaled to a 100,000-line component. At those rates a new C++ service carries latent memory flaws in triple figures, and the Rust version most likely none.

Industry norm Google plots · about 70%. Memory bugs. Android in 2025, after Rust · under 20%. Memory bugs.

This settles whether a plan is worth demanding: following one moved memory bugs from most of the problem to under a fifth of it. Source: Google's Rust in Android report, whose chart marks the upper bar as the industry norm.

Where a compulsory roadmap gets hard

A compulsory plan gets hard in two places: products close to retirement, which the guidance already exempts, and vendors who publish a roadmap with no dates in it, which satisfies the letter while changing nothing.

Do software makers have to stop using C and C++ by 2026?

No. The CISA and FBI guidance asks existing products for a plan, not a rewrite, and only calls new critical-infrastructure product lines in C or C++ dangerous where a memory-safe alternative exists. I'd go further than CISA, or at least put it more bluntly: a roadmap without a year beside each component is a brochure.

The unresolved question, in my opinion, is embedded firmware. A substation controller will not be rewritten, and a plan for it may mean little beyond the next model. Newer guidance shares the gap, such as the NSA's May 2026 advisory on MCP security for AI agents: sound advice, no teeth. Watch for:

  • Goals with no year per component.
  • Memory-safe claims covering only new features.
  • An end-of-support date just inside the exemption.
  • Sandboxing sold as a substitute, not a stopgap.

Check this against each vendor before your next renewal

  • It faces the internet or handles your keys.
  • Its support is not scheduled to end this decade.
  • Its newest features are still written in C or C++.
  • It cannot send a plan with a year per component.

If two of those are true, stop waiting for Washington. This week, email the vendor asking for its published plan and support end date, and tell procurement that renewal now depends on a dated commitment, cryptographic code first. Require it yourself, because nobody else will.

Sunday, September 27, 2026

CRA Reporting Gives Vendors 24 Hours

Here is the rule. Since 11 September 2026, any company selling software or connected hardware in the European Union that learns one of its products is being actively exploited has 24 hours to send an early warning to the authorities, and 72 hours to follow it with a full notification. That is CRA reporting, set out in the European Commission's guidance on the Cyber Resilience Act, and it is already live. A vendor in Austin that sells the same router in Berlin and Boston now owes Berlin a warning. Boston gets nothing.

Laptop security alert beside a 24-hour stopwatch, illustrating CRA reporting deadlines for vendors

That gap should close by law, and the usual objection is mostly answered by how the rule is written.

Key Takeaways

A 24-hour exploited-flaw warning should be a legal duty for every software vendor, not a perk reserved for EU buyers.

  • The EU gives vendors 24 hours to warn and 72 to notify once they know of an exploit.
  • Warnings go to a national CSIRT through ENISA's platform, not to the public.
  • US law puts reporting on the breached operator, not the vendor whose product failed.
  • Outside the EU, write a 24-hour exploited-flaw notice into every contract you renew.

Why CRA reporting should be the global floor

A vendor knows first when its product is being exploited, so the duty to warn belongs with the vendor, and a rule that protects only EU customers leaves every other buyer of the same product exposed.

The manufacturer sees the crash reports, the researcher emails and the telemetry spike days before customers notice anything. The Act makes that knowledge travel: manufacturers must also inform impacted users, according to Hogan Lovells' 11 September 2026 briefing. An EU hospital running a VPN appliance gets told. A clinic in Ohio running the identical box does not.

The American answer is thinner. CIRCIA puts the reporting duty on critical-infrastructure operators, the victims, not on the vendor whose code let the attacker in. CISA's Secure by Design pledge is voluntary, so a US buyer holds no enforceable promise unless it sits in the contract. Treating a pledge as a rule is outdated advice.

Anyone who tracked the DPDP consent manager deadline in India or post-quantum migration deadlines under NIST IR 8547 knows the pattern: a regulator sets a clock, and vendors discover how little of their process was built for one.

Run the clock on a real calendar. Confirm exploitation at 5pm on a Friday and the early warning is due by 5pm Saturday, the full notification by 5pm Monday. That is our own arithmetic, and it means someone with authority to file must be reachable all weekend. The four numbers below, from the Commission and Article 64 of the Act, decide whether vendors take that seriously.

Early Warning Window

24 hours

One unstaffed weekend breaches it

Flat Fine Ceiling

EUR 15 million

Enough to sink a small vendor

Filings Per Exploited Flaw

3

A paper trail buyers can cite

Turnover-Based Fine

2.5%

Whichever is higher applies

The revenue-linked ceiling is what changes behaviour at large vendors. A flat cap is a budget line; a share of global revenue grows with the company, so the suppliers in the most networks carry the steepest exposure.

"

In Europe, sitting on an exploited flaw over one weekend risks a fine priced against a vendor's entire global turnover. In America, the same silence costs nothing.

Does the Cyber Resilience Act apply to US companies?

Yes, the Cyber Resilience Act applies to any manufacturer placing products on the EU market, wherever it is based, so a US vendor selling into Europe already owes EU buyers warnings its home customers never receive.

US figures below come from Ballard Spahr's Byte Back analysis of CIRCIA (February 2026) and CISA's pledge page.

Dimension EU vs US What it means for you
💰 Who reports EU The product vendor
US The breached operator
⚠️ A supplier's flaw becomes your filing
⚖️ Legal force EU Binding since Sept 2026
US Pledge, signed by choice
❌ Only your contract makes it enforceable
⏱ First alert EU 24 hours, to a CSIRT
US 72 hours, operators only
✅ EU buyers hear two days sooner
⏱ Final report EU 14 days after a fix
US No vendor duty
✅ A patch date you can hold them to
🌍 Users told EU Impacted users, by law
US No such right
⚠️ Same product, warned only in Europe
🔒 Who sees it EU A CSIRT, not the public
US Nobody, by rule
✅ The warning gives attackers nothing
🛠 Old products EU Past end of support
US No duty at all
❌ Legacy kit goes quiet outside the EU
🏁 Best suited for EU Any buyer inside the EU
US Buyers who contract for 24h
🏁 Elsewhere, the clause is your only clock

The vendor builds the triage desk for Europe anyway, so American customers pay for output they never see. Vendors treating 2027 as the start date have the calendar wrong.

Oct 2025. May 2026. 11 Sep 2026. 11 Dec 2027. US rule first due. US rule new target. EU vendor clock live. Open source joins. 15 months.

If you sell to EU customers, your reporting clock is already running, while the US incident rule has already missed its first deadline. Dates from the European Commission and Ballard Spahr's Byte Back; the final gap is our own count.

Won't a 24-hour rule crush small vendors?

No, because the 24-hour step is an early warning to a national security team, not a public disclosure or a finished report, and the fuller detail follows on a structured, longer schedule.

At its strongest, the objection says a ten-person firm has no security team and a panicked filing could leak. Filings go through ENISA's Single Reporting Platform to the CSIRT of the manufacturer's main establishment, so the warning never touches the open internet. Attackers learn nothing from a message they cannot read.

The burden is real but scoped: a written threshold for "actively exploited" and a named Sunday filer. Plus a rehearsal. Two, honestly, because the first always finds the gap nobody wrote down. AI tooling vendors have more ground to cover, with flaws surfacing in MCP servers flagged in the NSA's advisory and in AI agent credentials nobody has inventoried.

The genuine grey area is the word "aware". In our view the clock should start at credible evidence of exploitation, not legal sign-off, but enforcement will settle it. Watch for these:

  • Community-maintained components sit outside the clock until open-source stewards join.
  • Severe incidents run a different final-report schedule, so check which your contract names.
  • US buyers hold no right to the EU notice, even for identical firmware.

Check these before your next renewal

Your contract sets an exploited-flaw notice of one day or less.

Your vendor names who files on a Sunday.

The product is also sold in Europe, so the warning exists.

Unsupported products still carry a written warning promise.

Do not wait for Washington. This week, pull your three largest software contracts and add one clause: the vendor notifies you within 24 hours of confirming active exploitation, on the same terms it already owes EU regulators. A vendor that refuses a promise it already keeps in Europe has told you what you need to know.

Related: why a memory safety roadmap should be compulsory for software vendors

Related: why a compulsory default password ban beats a voluntary label

Related: why every vendor should publish a working security.txt reporting channel