Positioning note · August 2026
Article 14 starts a clock. Evidence has to keep up.
The EU Cyber Resilience Act's Article 14 reporting obligations begin to apply on September 11, 2026. The deadline is concrete. So is the question behind it: what changed, what authority moved, and what can the producer prove?
Positioning, not launch. Garnet is a research-grade v0.x project. It is not a CRA compliance product, legal advice, a conformity assessment, or a promise tied to September 11. No delivery date is implied here.
What Article 14 puts on the clock
Article 14 covers actively exploited vulnerabilities and severe security incidents for products in scope. Its early-warning deadline is no later than 24 hours after awareness; the next notification is due no later than 72 hours after awareness. The final-report timetable differs between vulnerabilities and incidents. Full application of the Regulation follows on December 11, 2027.
That is a reporting duty, not a language feature. It does sharpen a question software teams already face: when code changes faster than a person can reread it, what can the organization prove about the authority that changed?
Garnet's position
Garnet treats authority as reviewable program data. garnet check verifies declared capability budgets across the registered surface. garnet diff-caps reduces a large source change to its declared-capability delta. Neither command makes a product compliant; they make the acceptance record smaller and harder for the author to fake.
The proposed garnet build --evidence path is under construction. No such build flag exists in the shipping CLI. Today's runnable pieces are garnet caps, garnet diff-caps, and garnet seal; the seal records the declared surface, but it does not rerun the checker.
Verified today / Still open
Verified today
@caps and @max_depth have deterministic traps on the interpreter and VM, with cross-OS trap parity recorded.
- The
garnet CLI runtime-gates the bounded host-authority set named in the capability scope table.
- Linux seccomp application is proven through the external reference tests.
Still open
garnet build --evidence remains under construction under W-SHIP.
- The named checker-only, declared-only, unbridged, and caps-invisible fences are not runtime enforcement.
- macOS and Windows OS-sandbox application, regulatory validation, and production readiness remain unproven.
Why the review ceremony matters
Evidence only matters if its author cannot grade it into acceptance. Garnet's repository keeps implementation, independent review, the structured record, carrier approval, re-evaluation, and merge as separate acts. A content change voids the earlier verdict; sanctioned record-only succession does not extend what was reviewed; a missing record stays red. Those separations matter more than the format of an evidence bundle. A generated PDF does not prove acceptance. A useful chain ties each claim to a trap and each acceptance to its decision-maker.
- Declare. Name the authority the program is meant to hold.
- Trap. Test the bounded enforcement surface and preserve the red cases.
- Review. Bind independent judgment to exact bytes, head, and tree.
- Accept. Let the accountable carrier decide; do not let the producer self-promote.
That position follows the existing register and ceremony rail ([U-32](https://github.com/Island-Dev-Crew/garnet/blob/main/ops/lane1/review/04-request.md), [U-33](https://github.com/Island-Dev-Crew/garnet/blob/main/ops/lane1/review/04-request-addendum-u33.md)). It does not upgrade either finding or claim that the open work has shipped.
Primary sources and scope