
CRA and open source: who takes responsibility for the product?
Contributor, steward and manufacturer are not synonyms. A scoping record helps avoid asking a community to carry the supplier’s responsibilities.
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Analysis on AI, cybersecurity, regulation, governance and digital systems. With sources, practical consequences and one clear next action.
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Current knowledge, organised by topic, date and practical consequence.

Contributor, steward and manufacturer are not synonyms. A scoping record helps avoid asking a community to carry the supplier’s responsibilities.
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The European decision strengthens obligations for designated services. It does not automatically turn every business customer into a very large platform.
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Before 11 September, separate three dates: market placement, vulnerability identification and awareness of active exploitation.
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The Commission's published enforcement framework explains that the AI Office may issue simple requests for information or requests by formal decision. An incorrect or misleading reply may be sanctioned; for a request by decision, failure to reply or an incomplete reply may also lead to a fine.
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Decree-Law 125/2025 brought Portugal's new Cybersecurity Legal Regime into force on 3 April 2026. For a potentially covered entity, the immediate risk is not only interpreting its sector: it is being able to prove classification, registration data, the responsible person, and a permanently available contact.
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DORA requires covered financial entities to maintain and update a register of all contractual arrangements for ICT services at the applicable levels. September is a useful gate to reconcile the standardised model with summer changes in contracts, services, entities, and subcontracting chains.
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August 2026 marked a new phase of AI Act application and enforcement, reflected by the Commission and official timeline, with Digital Omnibus changes in the consolidated text. Organisations should not continue operating from calendars created before those changes.
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Regulation (EU) 2023/1543 on European Production and Preservation Orders has applied since 18 August 2026. In-scope service providers need to receive, authenticate, preserve, and respond through a workflow that respects timing and data protection.
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The Data Act has generally applied since September 2025 and contains rules on switching between data-processing services. As acquisitions and commercial changes affect technology providers, customers should be able to locate contractual duties and convert them into a technical exit path.
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Cyber Resilience Act Article 14 reporting duties apply from 11 September 2026. An early warning may be due within 24 hours and the main notification within 72 hours after a manufacturer becomes aware of a covered actively exploited vulnerability or severe incident.
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The double-blind evaluation pilot announced by DeepMind offers a promising way to protect prompts and weights, but the AI Act allocates duties by role and use case. An organisation deploying a system still needs inventory, classification, instructions, oversight, logs, and controls in its own context.
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Regulation (EU) 2026/1744, in force since 27 July, changed the AI Act timetable. Sections 1 to 3 of Chapter III now apply on 2 December 2027 to high-risk systems under Article 6(2) and Annex III, and on 2 August 2028 to systems under Article 6(1) and Annex I. The general application date of 2 August 2026, however, did not disappear.
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