SBOM adoption has shifted from best practice to regulatory requirement. EO 14028 mandates SBOMs for U.S. federal software, the EU CRA requires component documentation for all products with digital elements, PCI DSS 4.0 demands software inventory for payment systems, and the FDA requires SBOMs for medical devices. The tooling ecosystem — from GitHub's Dependency Graph to open source generators and management platforms like sbomify — is mature enough to make adoption straightforward.
When the concept of Software Bills of Materials first entered mainstream cybersecurity discourse, it was largely aspirational — a good practice that forward-thinking organizations might adopt. That era is over. SBOMs have moved from recommendation to requirement, driven by a convergence of regulatory mandates, industry standards, and a tooling ecosystem that has matured enough to make adoption practical for organizations of any size.
The question is no longer whether to adopt SBOMs, but how quickly you can integrate them into your existing workflows.
The Regulatory Landscape Has Changed
Executive Order 14028: The U.S. Federal Mandate
The U.S. Executive Order 14028 on Improving the Nation’s Cybersecurity marked a turning point for SBOM adoption. It requires software vendors selling to the federal government to provide SBOMs, and directs NIST and CISA to define minimum elements and guidelines for SBOM production and consumption.
The implementing guidance has evolved since 2021. EO 14144 (January 2025) initially strengthened attestation requirements, but EO 14306 (June 2025) rescinded key portions, and OMB Memorandum M-26-05 (January 2026) shifted from a centralized attestation mandate to an agency-led, risk-based approach. The core outcome: EO 14028’s SBOM and supply chain security principles remain in effect, but each agency now tailors its assurance requirements to its specific risk profile. M-26-05 specifically encourages SBOM requirements for cloud service providers.
The impact extends far beyond federal contractors. EO 14028 established the expectation that software transparency is a baseline requirement, not a differentiator. Private-sector procurement teams increasingly include SBOM requirements in their contracts, following the federal government’s lead.
EU Cyber Resilience Act: A Global Standard
The EU Cyber Resilience Act (CRA) (Regulation EU 2024/2847) goes further than any previous regulation. It is binding EU law that requires manufacturers placing products with digital elements on the EU market to identify and document components and dependencies, including by drawing up a software bill of materials. Unlike U.S. guidance documents, the CRA is enforceable legislation — organizations selling software in European markets need SBOM capabilities in place now.
The CRA is significant because of its broad scope: it applies to manufacturers, importers, and distributors of products with digital elements — encompassing commercial software, IoT devices, and embedded systems. The CRA requires SBOMs covering at least top-level dependencies in a commonly used, machine-readable format. It also mandates vulnerability handling processes, meaning SBOMs must be actively monitored, not just generated and filed. Market surveillance authorities can request SBOMs as part of conformity assessment.
PCI DSS 4.0: Payment Industry Requirements
PCI DSS v4.0.1 Requirement 6.3.2 requires maintaining an inventory of bespoke and custom software, including third-party software components incorporated into that software, to facilitate vulnerability and patch management. This requirement became mandatory after March 31, 2025. While PCI DSS doesn’t mandate SBOMs by name, Requirement 6.3.2 is effectively an SBOM requirement for custom software in cardholder data environments.
FDA Medical Device Guidance
The FDA now requires SBOMs as part of pre-market submissions for medical device software. This requirement recognizes that medical devices increasingly depend on open source components, and that patient safety depends on knowing exactly what software is running on those devices.
UK Code of Practice for Software Vendors
The UK’s Software Security Code of Practice adds another jurisdiction to the growing list of governments that expect software transparency. While currently voluntary, it signals the direction of UK regulation and aligns with the broader global trend.
The Tooling Ecosystem Is Ready
Two years ago, generating and managing SBOMs required significant manual effort. Today, the tooling ecosystem is mature, integrated into the platforms developers already use, and largely free.
Native Platform Support
GitHub provides SBOM generation through its Dependency Graph, producing SPDX-format SBOMs directly from repository dependency data. This gives millions of developers a zero-configuration starting point for SBOM generation.
Docker Scout analyzes container images and generates SBOMs, providing vulnerability analysis alongside image builds. For containerized applications, this means SBOM generation is built into the deployment pipeline.
Open Source Generators
The open source ecosystem offers mature SBOM generation tools for every major language and package ecosystem:
- sbomify GitHub Action — Automatically selects the best generator for your stack and enriches the output with metadata from 11 data sources
- Syft — Generates SBOMs from container images, file systems, and archives
- Trivy — Aqua Security’s multi-purpose scanner with SBOM generation
- CycloneDX plugins — Language-specific generators for npm, Maven, pip, Go, and more
Management and Monitoring
Generating an SBOM is only the first step. The real value comes from continuous monitoring — automatically checking your components against vulnerability databases as new CVEs are disclosed. Management platforms like sbomify provide:
- Centralized SBOM storage with SBOM hierarchy for complex products
- Continuous vulnerability monitoring via Google OSV
- License compliance checking
- A Trust Center for sharing SBOMs and compliance documents with customers
- Enrichment from 11 data sources to fill gaps in generated SBOMs
Why the Timing Is Critical
Regulations Are Converging
For the first time, multiple major regulatory frameworks are requiring SBOMs simultaneously. Organizations that sell software across jurisdictions — the U.S., EU, and UK — face overlapping requirements that all point to the same capability: transparent, machine-readable documentation of software components. Building this capability once satisfies multiple requirements.
Cyber Threats Demand Visibility
Supply chain attacks continue to grow in sophistication and frequency. The lesson of Log4Shell — that you need to know what’s in your software before a vulnerability is disclosed — has been reinforced repeatedly. SBOMs provide the visibility needed for rapid vulnerability response, turning days of investigation into seconds of database queries. For more on this topic, see our guide on the role of SBOMs in cybersecurity.
Market Differentiation
Organizations that can provide SBOMs on demand — through a self-service portal like sbomify’s Trust Center — demonstrate a maturity that procurement teams increasingly expect. This is especially true in regulated industries (healthcare, finance, defense) where software transparency is becoming a selection criterion.
The Cost of Waiting
Implementing SBOM processes under regulatory deadline pressure is significantly more expensive and disruptive than doing it proactively. Organizations that adopt SBOMs now can iterate on their processes, train their teams, and resolve integration challenges at their own pace — rather than scrambling to meet a compliance deadline.
Getting Started
The path from zero to continuous SBOM monitoring is shorter than most organizations expect:
Add SBOM generation to CI/CD — The sbomify GitHub Action can be added to an existing workflow in minutes. It automatically detects your technology stack and generates a compliance-ready SBOM.
Ingest into a management platform — Upload generated SBOMs to sbomify for centralized storage, vulnerability monitoring, and compliance tracking.
Enable continuous monitoring — sbomify automatically cross-references your components against vulnerability databases, alerting you to new risks as they’re disclosed.
Share with stakeholders — Use sbomify’s Trust Center to provide customers, auditors, and partners with on-demand access to your SBOMs and compliance documents.
For a complete walkthrough, see the sbomify zero-to-hero guide. For details on how SBOMs support vulnerability detection workflows, see our guide on SBOM scanning for vulnerability detection.
Conclusion
The convergence of regulatory mandates, mature tooling, and escalating supply chain threats has made SBOM adoption an immediate priority — not a future consideration. The infrastructure exists, the standards are defined, and the regulatory clock is ticking. Organizations that act now position themselves for compliance, security, and competitive advantage. Those that wait risk scrambling under deadline pressure.
The time to embrace SBOMs is unequivocally now.
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