Understanding Software Bill of Materials (SBOM): Enhancing Transparency and Security in Software Supply Chains

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What is SBOM? What does it have to do with the Executive Order on Improving the Nation’s cybersecurity? Is my software supply chain compliant? How do I make sure my organization remains compliant in the future?

This article answers all those questions and more. We will explore the background of SBOM and SLSA compliance by reviewing the executive order. Then, we will explain what an SBOM is, what must go into it, and how it benefits your app security. Finally, we’ll discuss ways to implement SBOMs into your pipeline and gain SLSA compliance—all without your developers needing to leave their development environment.

Key highlights:

  • A Software Bill of Materials (SBOM) is a detailed inventory of all software components, libraries, and dependencies within an application.
  • SBOMs are critical for managing vulnerabilities, ensuring license compliance, and maintaining visibility across the software supply chain.
  • Growing regulatory mandates and industry standards are making SBOM adoption an essential requirement for enterprises worldwide.
  • Cycode provides an end-to-end solution for generating, managing, and integrating SBOMs into DevSecOps pipelines to strengthen compliance and security.

Executive Order on Improving the Nation’s Cybersecurity

In May 2021, the White House released Executive Order 14028, Executive Order on Improving the Nation’s Cybersecurity. This partially came as a response to significant security breaches of organizations like SolarWinds and CodeCov, and partially as a response to the growing number of malicious cyber actors (MCAs) targeting developers.

The order tasked several groups to begin developing a new set of software security standards, tools, and best practices. It included a yet-to-be-defined category known as “critical software”. It also got rid of some barriers between government agencies to share cybersecurity threat information. Beyond improving the cybersecurity of the federal government’s systems, it also tasked private businesses and academia to begin enhancing software supply chain security to follow best practices as set out by NIST, the National Institute of Standards and Technology. 

Additionally, a review board was set up to review and assess cybersecurity incidents, and a playbook was created to dictate the federal government’s response to incidents.

Most significant for the field of software development may be a requirement for federal agencies to implement “zero trust” architectures, accelerating migrations to secure cloud and adopting other data protection capabilities—plus related endpoint detection, response, and logging—to mitigate continuing supply chain risk.

Most important to businesses were the promise of new best practices and standards for software supply chains. At the time of the order, it became clear that new compliance standards were coming, though it was not yet clear which shape they would end up taking.

 

What ended up occurring was the maturation of a relatively new concept known as the Software Bill of Materials (SBOM), a requirement to participate in vulnerability disclosure programs, and a requirement to demonstrate conformance with the best security practices.

What is an SBOM?

While the idea of a Bill of Materials (BOM) that conveys the components and their provenance within a product is by no means novel, what was new was the idea of developing a standard to apply to software and software supply chains throughout the nation.

Many manufacturing companies are already required to provide a BOM that details every part of a product, along with its original manufacturer if it came from a third party. A common instance where SBOMs help consumers is in the case of a vehicle recall. If a car is shipped with a faulty part, the makers can quickly know which part it is, where it came from, and how to fix or replace it. The same concept applies to SBOMs.

As the National Telecommunications and Information Administration (NTIA) states, “an SBOM is a formal record containing the details and supply chain relationships of various components used in building software.” It provides a detailed inventory of all the parts contained within the software, including open-source libraries, third-party components, and proprietary code. This transparency helps organizations manage their supply chain, identify vulnerabilities in a preventative manner, and respond to security incidents faster.

The promise of SBOMs is that an up-to-date and comprehensive Bill of Materials ensures high-quality code, compliance with regulations, and security from attack.

SCA vs SBOM: Main Differences

Software Composition Analysis (SCA) is often confused with the Software Bill of Materials (SBOM) because they both focus on the components within your application, particularly open-source libraries and dependencies. The key difference is their primary function: SCA is a dynamic process or a security tool, and the SBOM is a static data artifact. An SCA tool can generate the data needed for an SBOM, but the SBOM itself is the final, standardized inventory document. Understanding this distinction is crucial for selecting the right tools and establishing effective security workflows.

Aspect SBOM (Software Bill of Materials) SCA (Software Composition Analysis)
Purpose To provide a standardized, complete inventory of all software components (open-source, commercial, and proprietary) and their supply chain relationships. It’s a compliance and transparency artifact. To automatically scan code and binaries to identify open-source components, map them to known vulnerabilities (CVEs), and check for license compliance. It’s a security analysis tool.
Scope A comprehensive list of components (ingredients) required to build the software, regardless of security status. A dynamic analysis focused on the security and license risk of identified open-source components.
Format/Output A structured data file (e.g., SPDX, CycloneDX) that is machine-readable and shareable with consumers and partners. A risk report or security alert within a dashboard that flags vulnerabilities, policy violations, and license conflicts.
Timing Generated at specific points in the SDLC, typically before a build or release, and shared with the consumer. Continuously executed throughout the DevSecOps pipeline (check-in, build, testing) to provide real-time risk feedback.
Use Case Regulatory compliance, contractual obligation, post-incident forensic analysis (e.g., Log4Shell), and third-party risk assessment. Finding and fixing vulnerabilities in open-source dependencies, managing license risk, and enforcing security policies during development.

Minimum Components of an SBOM

Because of the fast-moving and evolving nature of both the situation and the technology, the minimum requirements of an SBOM were originally kept simple and flexible by the NTIA.

  • Data Fields: SBOMs must include the baseline information about each component. This includes a data field for each component, including supplier name, component name, version, dependencies, author of the SBOM data itself, and timestamp. This information sets components apart from one another and makes them easier to track.
  • Automation Support: Due to the nature of CI/CD pipelines, SBOMs should support automation. Thus, SBOMs can be read and generated by machines and scale across one’s ecosystem. This led to a standardization of their formats as well, with the three acceptable formats being Software Package Data eXchange (SPDX), ClycloneDX, and Software Identification (SWID) Tags.
  • Practices and Processes: Lastly, the NTIA has a list of practices and processes for organizations to follow. They include a standard that a new SBOM must be created whenever a software component is updated in a new build or release, that they should be distributed and delivered in a timely fashion, and that they must be access-controlled.

Main Benefits of SBOMs

Adopting a comprehensive Software Bill of Materials (SBOM) is no longer optional; it’s a foundational element of modern supply chain security and compliance. For enterprise organizations facing stringent regulatory demands and constant zero-day threats, the SBOM provides essential transparency that translates directly into business value. The goal of the SBOM is to transform reactive security into proactive risk management. By providing an accurate, machine-readable “ingredient list,” an SBOM empowers various teams, from developers to legal to the C-suite, to maintain security, ensure legal adherence, and build trust with customers.

Here are the primary ways that SBOMs help an enterprise-level organization:

  1. Enhanced Software Security: Since SBOMs provide a comprehensive inventory of all software components used in an application, organizations can quickly identify and address security vulnerabilities. By tracking known vulnerabilities and applying patches, organizations can improve the overall security posture of their software.
  2. Risk Mitigation in the Supply Chain: With SBOMs, organizations gain visibility into their software components. This assists in assessing risks in the supply chain and making informed decisions about hardening and patching. Essentially, having an SBOM streamlines the process of identifying which components need security patches and updates.
  3. Regulatory Compliance: SBOMs help organizations be compliant with current and future guidelines when it comes to cybersecurity.
  4. Improved License Management: SBOMs help organizations understand the licensing requirements associated with each component. This aids in ensuring compliance with open-source licenses and other licensing obligations, thus preventing legal issues related to software licensing.
  5. Transparency and Trust: SBOMs allow for transparency in software development practices, fostering trust among customers, partners, and stakeholders. Demonstrating a commitment to security and accountability can be a competitive advantage for enterprise-level organizations, especially when cybersecurity incidents are common.

Incident Response: If a security incident or breach does occur, having an SBOM allows organizations to quickly assess the potential impact and take appropriate remediation measures.

SBOMs and Regulatory Compliance

Compliance has rapidly evolved from a desirable attribute to a non-negotiable requirement for modern software producers. Driven by high-profile supply chain attacks and national security concerns, governments and industry bodies worldwide are now mandating software transparency. As a result, meeting these compliance frameworks is no longer a secondary benefit of SBOMs—it is a major organizational driver for their adoption. The Software Bill of Materials serves as the foundational, auditable artifact necessary to prove due diligence and adherence to a growing list of global standards and regulations.

Government Mandates

The most significant recent driver for SBOMs is governmental action aimed at securing national cyber infrastructure. The U.S. Executive Order 14028 on Improving the Nation’s Cybersecurity explicitly mandates the use of SBOMs for software sold to federal agencies, setting a clear precedent for the broader market. This focus highlights the shift toward holding software producers accountable for the security of their supply chains.

The Order, alongside guidance from agencies like the National Institute of Standards and Technology (NIST) and the Cybersecurity and Infrastructure Security Agency (CISA), creates a common framework for security best practices. Enterprises must not only generate SBOMs but also prove they have processes in place to continuously monitor and act on the information they contain.

  • Key Tasks:
    • Demonstrate conformance with NIST Secure Software Development Framework (SSDF) practices.
    • Provide machine-readable SBOMs (SPDX, CycloneDX) for federal contracts.
    • Align SBOM generation and management processes with CISA’s maturity model.

Industry-Specific Regulations

Beyond governmental mandates, several highly regulated industries are tightening their own requirements, making SBOMs essential for market access. Sectors like financial services, healthcare, and critical infrastructure rely heavily on open-source software but face unique risks and scrutiny regarding patient or customer data. Therefore, the ability to rapidly assess and patch vulnerabilities is paramount.

For organizations operating in Europe, the emerging EU Cyber Resilience Act (CRA) is set to establish harmonized cybersecurity rules for digital products, likely requiring formal vulnerability documentation that an SBOM supports. In the medical device space, the FDA now requires manufacturers to provide a list of software components, effectively a medical device SBOM (mBOM), to manage patient safety risks.

  • Key Tasks:
    • Maintain compliance with sector-specific standards (e.g., PCI DSS, HIPAA, ISO 27001).
    • Generate and share SBOMs to satisfy vendor due diligence requests from customers in regulated fields.
    • Utilize SBOMs to rapidly demonstrate non-impact in the event of a breach affecting the industry.

Open-Source Licensing Compliance

The use of open-source software (OSS) comes with various legal obligations dictated by different licenses (e.g., GPL, MIT, Apache). Failing to adhere to these terms can result in significant legal challenges, including lawsuits, forced source code disclosure, or injunctions against product distribution. An accurate and up-to-date SBOM is the definitive tool for tracking these obligations.

The SBOM provides a clear record of the license associated with every component, making it possible for legal and compliance teams to audit and enforce internal policies automatically. This prevents the accidental inclusion of libraries with restrictive licenses into proprietary codebases, saving considerable legal cleanup work and allowing for early intervention.

  • Key Tasks:
    • Identify and flag components using copyleft licenses (e.g., GPL, LGPL) that may restrict commercial use.
    • Ensure all necessary license and copyright notices are collected for distribution.
    • Automate license compliance checks against a pre-approved policy list based on SBOM data.

Audit Readiness

For large enterprises, the cycle of internal and external security audits is continuous. Preparing for these audits traditionally involves extensive manual effort to gather component lists and proof of vulnerability management, often delaying releases and draining security resources. The SBOM fundamentally changes this dynamic by acting as the single source of truth for software composition.

Having a machine-readable, standardized SBOM artifact that is generated at the time of the build proves the state of the software at a fixed point in time. This greatly simplifies the auditor’s task and allows the enterprise to respond to inquiries about vulnerability status or patching timelines instantly, making the audit process significantly more efficient and less intrusive.

  • Key Tasks:
    • Provide auditors with a standardized SBOM (SPDX/CycloneDX) that links directly to vulnerability and license data.
    • Quickly prove the successful remediation of flagged vulnerabilities in previous audit cycles.
    • Use the SBOM history to demonstrate continuous compliance improvement over time.

Global Standards Alignment

While specific laws vary, the core objective of improving software integrity is a global phenomenon. International organizations like the OpenSSF (Open Source Security Foundation) are driving global alignment through frameworks like SLSA (Supply-chain Levels for Software Artifacts), which is increasingly being adopted worldwide. SLSA’s highest levels explicitly require the generation and attestation of comprehensive SBOMs.

Adopting global standards like SLSA and leveraging accepted SBOM formats (SPDX and CycloneDX) ensures that an enterprise’s compliance efforts are future-proof and interoperable. This allows organizations to sell and share software across borders and diverse ecosystems without needing to re-engineer their compliance documentation for every market.

  • Key Tasks:
    • Integrate SBOM generation with SLSA-required provenance and tamper-evidence attestations.
    • Standardize on global formats (SPDX, CycloneDX) for maximum interoperability with customers and partners.
    • Use SBOM data to demonstrate alignment with global best practices for securing the entire software supply chain.

SLSA and SBOMs: Frameworks for Supply Chain Security

Related to the federal government’s executive order on cybersecurity, other organizations have been hard at work determining best practices for software supply chain security. One prominent development has been SLSA 1.0, which stands for Supply-chain Levels for Software Artifacts, originally created by Google’s security team and developed by OpenSSF. SLSA works with the security efforts being made throughout the industry to secure the software supply chain using SBOMs.

Think of it this way: SBOM and SLSA are two complementary tools that can be used to improve the security of software supply chains. They should be used together to provide a comprehensive view of the security of a software supply chain. SBOM can be used to identify potential vulnerabilities, and SLSA can be used to ensure that those vulnerabilities are mitigated.

At the highest SLSA level, organizations are required to provide an SBOM that includes information about all the dependencies of their software artifacts. This information can be used to track the provenance of software components and to identify potential security vulnerabilities.This framework aims to not only help organizations achieve and maintain compliance with security regulations, but also standardize and improve security above and beyond the minimum requirements. Many large-scale organizations are beginning to adopt SLSA 1.0 so they can rest assured in the security of their software supply chain.

How to Implement SBOMs in DevSecOps Pipelines

Implementing a robust SBOM strategy requires integrating component analysis directly into your existing DevSecOps pipeline. This transition must be automated and seamless to maintain developer velocity and achieve continuous compliance. A successful implementation strategy treats the SBOM not as a compliance checklist, but as a dynamic data artifact that enhances your overall pipeline security. By integrating specialized tools that can automatically scan, generate, and manage SBOMs at every critical stage, enterprises can ensure they have an accurate, up-to-date inventory that reflects the exact state of their deployed software.

Integrate SBOM Generation Into CI/CD Builds

The most critical step is embedding SBOM generation directly into the Continuous Integration/Continuous Delivery (CI/CD) process. Relying on manual or pre-build scans introduces a risk of outdated or incomplete data. Instead, the SBOM should be created as a mandatory output artifact of the actual build process itself, ensuring it accurately reflects the components used to create the final binary or container image.

This tight integration ensures that every release candidate is paired with its corresponding, tamper-proof inventory. Developers should be prevented from moving forward with a build if the SBOM generation fails or if it flags components that violate defined security or license policies. This practice shifts security left, enabling immediate feedback on dependencies at the point of introduction.

  • Key Subtasks:
    • Configure your build servers (e.g., Jenkins, GitHub Actions, GitLab CI) to run an SBOM generation tool as a build step.
    • Treat the SBOM output file as a required, versioned artifact alongside the application binary.
    • Set build policies to fail the pipeline if a component without clear provenance or license information is detected.

Adopt Standardized Formats

The utility of an SBOM is directly related to its machine-readability and interoperability. Enterprises must standardize on accepted, globally recognized formats that can be easily consumed by different security, compliance, and consumer tools. The two industry-leading formats, SPDX (Software Package Data Exchange) and CycloneDX, are highly recommended due to their rich metadata capabilities and broad tool support.

Standardization ensures that the SBOM can be efficiently shared with customers, regulators, and third-party risk management systems without requiring custom parsing or translation. Using a standardized format also allows the SBOM to include crucial metadata, such as the supplier, component version, and even hashes to ensure the artifact’s integrity.

  • Key Subtasks:
    • Mandate the use of either SPDX or CycloneDX (or both) across all software teams.
    • Ensure the generating tool includes required metadata fields, such as package name, version, and unique identifiers (e.g., purl).
    • Verify that the SBOM format supports integrity checks, such as cryptographic hashes of the components listed.

Validate Completeness and Accuracy

Generating an SBOM is only the first step; validating its integrity is essential for trust and compliance. A complete SBOM must accurately capture not just direct dependencies listed in manifest files (like package.json or pom.xml), but also transitive dependencies (dependencies of dependencies) and components introduced via other means, like vendor libraries or operating system packages.

Modern SBOM solutions must use advanced analysis techniques, such as binary scanning and deep dependency resolution, to ensure no component is missed. This validation process should be automated and its results permanently attached to the artifact, proving that the SBOM is a truthful representation of the software’s composition.

  • Key Subtasks:
    • Implement binary analysis to identify components that are often missed by source-only scans.
    • Cross-reference the generated SBOM against dependency lock files to check for discrepancies.
    • Attach a provenance attestation (often using SLSA standards) to prove how and when the SBOM was generated.

Continuously Update SBOMs

Software composition is not static. New vulnerabilities are discovered daily (zero-days), dependencies are patched, and components are updated. Therefore, an SBOM must be treated as a living document. The pipeline must be configured to trigger a new SBOM generation or update whenever code changes, a dependency version is bumped, or a security patch is applied to the environment.

Beyond the build pipeline, the utility of the SBOM continues into the runtime environment. Organizations must use their stored SBOMs to continuously monitor for newly disclosed vulnerabilities (CVEs) that affect their deployed components, enabling rapid, targeted incident response.

  • Key Subtasks:
    • Establish a mechanism to regenerate the SBOM upon any merge to the main branch or a new release tag.
    • Use the SBOM data as the input for continuous monitoring tools that query vulnerability databases.
    • Ensure older, archived versions of the SBOM are retained for long-term auditability.

Link SBOMs With Vulnerability Management Tools

The true value of an SBOM is unlocked when it is linked directly to your organization’s broader vulnerability and risk management framework. An SBOM simply lists the ingredients; it is the Vulnerability Exploitability eXchange (VEX) data that determines which of those ingredients are currently a security risk.

By connecting the SBOM component list to a VEX feed, security teams can instantly answer the question, “Are we affected by this new CVE?” Furthermore, the SBOM data can be ingested by your ticketing systems (e.g., Jira) to automatically create remediation tasks assigned to the correct development teams, streamlining the entire fix-and-patch process.

  • Key Subtasks:
    • Integrate the SBOM repository with your existing vulnerability scanning tools (e.g., SCA, SAST).
    • Automate the creation of VEX data to provide context on whether a vulnerability is actually exploitable in the application.
    • Use the SBOM to prioritize remediation efforts based on the severity and exploitability of vulnerabilities in critical components.

Distribute and Govern Access

The final step in implementation is establishing clear policies for distributing and governing access to the SBOM data. As a critical security and compliance artifact, the SBOM must be securely stored and only shared with authorized parties, such as customers requiring due diligence, internal security teams, or external auditors.

A central SBOM repository or management solution is crucial for ensuring integrity, version control, and access control. This system should be able to instantly query and deliver a specific SBOM version upon request, formalizing the transparency commitment to the supply chain.

  • Key Subtasks:
    • Establish a secure, central repository for storing all generated and signed SBOMs.
    • Define strict access control policies for internal teams (developers vs. security vs. legal).
    • Determine the formal process and format for sharing SBOMs with downstream customers or partners.

SBOM Best Practices for Enterprises

Generating a basic Software Bill of Materials meets the minimum compliance bar, but true software supply chain resilience requires a mature, strategic approach. For large organizations managing numerous applications and complex DevSecOps environments, a set of best practices is essential to ensure the SBOM is reliable, actionable, and truly beneficial for long-term security. These practices transform the SBOM from a static document into a dynamic asset that drives security decisions across the entire organization.

Automate SBOM Generation Across the SDLC

Manual or semi-manual processes for creating SBOMs are prone to human error, lead to outdated data, and are simply not scalable across enterprise portfolios. The gold standard is to fully automate SBOM generation from the moment code is written to its final deployment. Automation ensures the SBOM is consistent, complete, and generated at the exact moment of the build, creating a verifiable snapshot of the software’s state.

This best practice extends beyond the CI/CD pipeline. Automation should also handle the continuous monitoring of the SBOMs in production, automatically linking newly discovered vulnerabilities (CVEs) to the affected components and immediately triggering alerts or remediation tickets. Automated workflows are the only way to manage the volume and velocity of changes in a modern codebase.

  • Key Subtasks:
    • Implement CI/CD integration to generate a new, signed SBOM with every committed change or official build.
    • Automate dependency resolution, including transitive dependencies, to ensure 100% component coverage.
    • Use automation to continuously monitor all deployed SBOMs against live vulnerability feeds.

Standardize on Accepted Formats (SPDX, CycloneDX, SWID)

An SBOM’s effectiveness relies on its ability to be easily consumed and shared by machines and systems across the software ecosystem. Enterprises must enforce the use of standardized, machine-readable formats. SPDX and CycloneDX are the two industry-accepted formats, each offering rich metadata fields that go beyond simple component lists to include license, hash, and provenance information.

Standardization removes friction when sharing SBOMs with customers for due diligence or when ingesting them into internal security tools. By generating SBOMs in these formats, the data becomes instantly interoperable, supporting rapid security tool integration and accelerating response times during incidents like a zero-day vulnerability disclosure.

  • Key Subtasks:
    • Mandate the use of CycloneDX (often preferred for security use cases) and/or SPDX (preferred by certain compliance bodies).
    • Ensure the tool can generate the required minimum fields (supplier, component name, version, hash, dependencies).
    • Integrate the format into the distribution process, ensuring external parties can easily consume the data.

Establish Clear Governance and Access Policies

An SBOM contains highly sensitive information about an organization’s software makeup, making its governance as important as its generation. Enterprises must establish clear policies defining who can generate, modify, access, and share the SBOM, ensuring the document’s integrity and preventing unauthorized disclosure of proprietary details.

A centralized SBOM management platform is necessary to maintain version control and strictly enforce these access policies. Governance also dictates the organizational workflow—who is responsible for actioning vulnerability data derived from the SBOM, how is the remediation status tracked, and how long are historical SBOMs retained for audit purposes.

  • Key Subtasks:
    • Define a central team (e.g., AppSec or DevSecOps) responsible for SBOM policy and enforcement.
    • Implement role-based access control (RBAC) to limit external sharing and internal editing privileges.
    • Document the retention schedule for all historical SBOMs to satisfy long-term compliance requirements.

Maintain Continuous Updates and Version Control

Given the speed of development and the constant discovery of new vulnerabilities, an SBOM must be treated with the same rigor as source code. A best practice is to version-control every SBOM artifact, ensuring that a traceable, immutable record exists for every single build or release. This capability is vital for providing forensic evidence during a security audit.

Furthermore, the SBOM should be continuously updated post-release. When a critical zero-day is announced (like Log4Shell), security teams should be able to instantly query the latest production SBOMs to identify affected software and components, drastically reducing the time required for vulnerability assessment and patching.

  • Key Subtasks:
    • Store all SBOM artifacts in a tamper-resistant repository, linked to the corresponding source code commit or build ID.
    • Establish processes to update the SBOM metadata when a vulnerability is patched in the production environment.
    • Define policies for how often SBOMs must be re-generated for long-running or legacy applications.

Document Unknown or Redacted Components Transparently

In a complex enterprise environment, not every component will have perfect provenance. There may be binary-only third-party modules or proprietary components whose details are purposefully obfuscated. A mature SBOM program does not simply omit these components; it documents their existence and addresses the risk transparently.

The best practice is to use defined fields within the standard SBOM formats to flag these “known unknowns” or redacted proprietary components. This maintains the document’s integrity while signaling to consumers that a potential area of risk exists, allowing for a responsible, policy-driven conversation about acceptable risk tolerance.

  • Key Subtasks:
    • Use specific fields (e.g., “redacted” or “unknown”) in the SBOM format to mark components without complete metadata.
    • Define clear internal policies for the acceptance or rejection of software containing unknown components.
    • Provide supplementary documentation (like Vulnerability Exploitability eXchange (VEX) data) for any proprietary components.

Integrate SBOM Data With Security and Compliance Tools

The SBOM is an input, not an end goal. The most impactful best practice is to ensure the SBOM data is seamlessly ingested by all relevant downstream systems. This includes vulnerability management platforms, Governance, Risk, and Compliance (GRC) tools, and even legal review systems.

Integrating the SBOM data transforms these tools from relying on generic scans to leveraging a verified, component-level inventory. For instance, a GRC tool can automatically check a component’s license against a corporate policy list, and the vulnerability scanner can focus only on components listed in the SBOM, improving accuracy and reducing false positives.

  • Key Subtasks:
    • Connect the SBOM repository to the Vulnerability Management System for rapid incident response.
    • Feed SBOM license data directly into legal review or GRC platforms for automated compliance checks.
    • Use Cycode’s centralized Code-to-Cloud platform to orchestrate SBOM data flow across SAST, SCA, and CI/CD tools.

Align With CISA’s SBOM Maturity Model for Long-Term Growth

To ensure the SBOM program evolves with industry standards, enterprises should align their strategy with established frameworks like the one provided by CISA. This maturity model offers a phased approach—from basic generation to full consumption and sharing—that allows organizations to systematically strengthen their capabilities over time.

Adopting this model provides a clear roadmap for investment and improvement, ensuring the SBOM initiative remains strategic rather than becoming a stagnant compliance checkbox. This future-focused alignment is key to staying ahead of evolving regulatory demands and supply chain attack techniques.

  • Key Subtasks:
    • Benchmark current SBOM capabilities against CISA’s three-stage model (Generation, Consumption, Sharing).
    • Define quarterly goals for advancing maturity in specific areas, such as adding VEX support.
    • Use maturity milestones to communicate progress and success to executive stakeholders and security leadership.

Selecting the Right SBOM Solution

Because of the minimum requirements for SBOMs, solutions must support automation, include certain data fields, and follow a set of best practices. For enterprises, selecting the right solution is about more than just generating a list—it’s about choosing a platform that can manage, update, and integrate that list across your entire security and compliance ecosystem.

Consider tools that offer the following features:

Consider tools that offer the following features:

 

Key SBOM Solution Features Why the SBOM Features Matter
Automated SBOM Generation Ensures accuracy and scalability by removing human error and manual effort. The SBOM is always generated at the time of the build, creating a verifiable, trusted artifact that reflects the final product state.
CI/CD Integration Enables ‘Shift-Left’ security and compliance by making SBOM creation a mandatory part of the development workflow. This prevents non-compliant code from being released and maintains developer velocity.
Continuous Updates Provides crucial incident response capability. The solution must continuously check the components listed in the deployed SBOM against real-time vulnerability feeds (like new CVEs) to provide instant alerts and minimize exposure time to zero-days..
Regulatory Alignment Guarantees compliance with key mandates (e.g., U.S. Executive Order 14028, EU Cyber Resilience Act). The solution should support the attachment of VEX data and attestations to meet auditable standards.
Standard Format Support Guarantees interoperability and shareability. SBOMs must be generated in industry-standard, machine-readable formats (SPDX and CycloneDX) so they can be easily consumed by customers, regulators, and other security tools.
Code-to-Cloud Coverage Provides end-to-end context and protection. An ideal solution, like Cycode, uses the SBOM data to inform security posture not just in the pipeline, but also in the cloud environment, linking code issues to runtime risk.

 

Ideally, implementing SBOMs would look like finding an organization that could:

  1. Scan your software composition to determine data and dependencies.
  2. Automatically generate SBOMs that adhere to all current requirements in addition to current best practices for software supply chain security.
  3. Continuously monitor your CI/CD pipeline for vulnerabilities and unauthorized access.
  4. Offer end-to-end application security, including hardcoded secrets detection, source code protection, data orchestration, and code-to-cloud coverage, so that, in addition to meeting compliance standards, your application is fully protected.

At Cycode, we have such a solution. Find out more here.

Streamline Your Compliance with Cycode’s SBOM Solution 

Due to the rapidly evolving technology and regulation landscape, businesses can best respond to the executive order by learning everything they can about SBOM, staying up-to-date on NTIA and NIST guidelines, and embracing the latest cybersecurity solutions.

With Cycode, enterprises can generate SBOMs automatically and gain access to a wealth of other protective features. We’re the application security platform that puts security-first while remaining developer-friendly, a commitment we demonstrate with our runtime solutions. 

Ready to get started? Book a demo today.

Frequently Asked Questions

What Trends Are Impacting the Future of SBOMs?

The future of the Software Bill of Materials is being shaped by three critical, interconnected trends that push them beyond simple inventory lists and into dynamic security tools:

  1. Mandatory Regulatory Compliance: The most immediate trend is the expansion of government mandates (like the U.S. Executive Order and the EU Cyber Resilience Act). This is driving enterprise adoption from being "nice-to-have" to "must-have," making SBOMs a prerequisite for market access in many sectors.
  2. Vulnerability Exploitability eXchange (VEX): The security community realized that an inventory list alone creates "alert fatigue." VEX is a supplementary artifact that clarifies whether a vulnerability listed in an SBOM is actually exploitable in the context of the running application. The future is not just an SBOM, but an SBOM paired with VEX data.
  3. Code-to-Cloud Integration: SBOMs are becoming key data artifacts in comprehensive security platforms. Solutions like Cycode are using SBOM data generated in the pipeline to inform security decisions in the cloud and runtime environment, linking development risk directly to operational risk. This integration makes the SBOM a central part of a holistic security strategy.

How Often Should an SBOM Be Updated?

The best practice for enterprise organizations is to treat the SBOM as a living, dynamic document, not a static file.

  • During Development: An SBOM should be automatically re-generated whenever a new dependency is added, a version is updated, or a new release candidate is created. For continuous integration (CI) environments, this means an SBOM is generated with every successful build.
  • In Production: SBOMs must be continuously monitored against real-time, external vulnerability databases. If a new, critical zero-day (CVE) is disclosed, the management system must query the deployed SBOM instantly to determine the scope of impact, making the SBOM data effectively "updated" for risk analysis.
In essence, an SBOM must be updated any time the software's components or the risk profile of those components changes.

What Tools Can Generate SBOMs?

SBOMs are primarily generated by tools that specialize in analyzing the composition of software. The three main categories are:

  1. Software Composition Analysis (SCA) Tools: These are the most common generators. SCA tools scan source code, package managers, and build manifests to identify open-source components and their transitive dependencies, automatically compiling this data into a standardized format (SPDX or CycloneDX).
  2. Build System Plugins: Some modern build systems (like Maven, Gradle, or package managers like npm) offer native plugins that can generate simple SBOMs directly during the build process.
  3. Specialized SBOM Platforms: Tools like Cycode's platform offer end-to-end solutions that not only generate high-fidelity, comprehensive SBOMs (including binary analysis for full coverage) but also manage them centrally, monitor them continuously, and integrate the data across the entire DevSecOps pipeline for actionability.

Are SBOMs Required by Law?

Yes, in certain contexts, SBOMs are now legally required, and this trend is expanding globally.
The primary mandate currently is in the United States, where the Executive Order on Improving the Nation’s Cybersecurity (EO 14028) requires any software vendor selling to the federal government to provide an SBOM.
This regulatory trend is quickly expanding:

  • Sector-Specific: The FDA has begun requiring medical device manufacturers to submit component information (effectively an SBOM) for patient safety.
  • International: The European Union's proposed Cyber Resilience Act (CRA) includes provisions that will mandate software producers to provide documentation and transparency, which will heavily rely on SBOMs for compliance across the EU market.

While not all commercial software immediately requires an SBOM by law, the market pressure and contractual requirements from customers seeking supply chain assurance mean they are quickly becoming a de facto requirement for any enterprise.