BSI TR-03183-2: SBOM Requirements (v2.1.0)

Guide to the German Federal Office for Information Security (BSI) Technical Guideline TR-03183-2 v2.1.0, which defines SBOM format and content requirements aligned with the EU Cyber Resilience Act.

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Who it affects: Manufacturers placing products with digital elements on the EU market who need a concrete technical baseline for SBOM format and content. BSI TR-03183-2 is widely treated as the de facto reference for satisfying the EU Cyber Resilience Act’s SBOM expectations, especially for German federal procurement.

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Overview

The BSI Technical Guideline TR-03183-2 (“Cyber Resilience Requirements - Part 2: SBOM”), published by Germany’s Federal Office for Information Security (BSI), specifies the format and content of Software Bills of Materials. Where the EU Cyber Resilience Act tells manufacturers that an SBOM is required, BSI TR-03183-2 spells out what that SBOM must look like in practice.

The current version is v2.1.0 (2025-08-20). It is binding for German federal procurement and is increasingly referenced by EU-market vendors as a concrete baseline that aligns with CRA expectations.

Format requirements (§4)

RequirementDetail
EncodingJSON or XML
FormatCycloneDX v1.6 or later, OR SPDX v3.0.1 or later

SBOM-level required fields (§5.2.1)

FieldDescription
Creator of SBOMEmail address or URL identifying the SBOM author
TimestampDate and time the SBOM was compiled

Component-level required fields (§5.2.2)

FieldDescription
Component creatorEmail address or URL
Component nameName of the component
Component versionVersion string, or RFC 3339 file modification date if no version exists
FilenameActual filename of the component (not a path)
DependenciesDependency relationships, with a completeness indicator
Distribution licencesSPDX identifiers or expressions
HashSHA-512 of the deployable component
Executable propertyWhether the component is executable
Archive propertyWhether the component is an archive
Structured propertyWhether the component is structured or unstructured

Conditional fields - required if present (§5.2.3, §5.2.4)

  • SBOM-URI - canonical URI of the SBOM document
  • Source code URI - location of the component’s source code
  • URI of deployable form - location of the deployable artifact
  • Other unique identifiers - CPE, purl, etc.
  • Original licences - upstream licence declarations

Critical requirements

  • No vulnerability data in the SBOM (§3.1) - vulnerability information must be exchanged out-of-band (e.g. via VEX/VDR), not embedded in the SBOM itself.
  • SPDX licence identifiers (§6.1) - all licence values must use SPDX identifiers or expressions; free-form licence strings are not compliant.

Score uploaded SBOMs against the BSI checklist

sbomify ships a BSI TR-03183-2 v2.1.0 plugin that grades each uploaded SBOM against the format, SBOM-level, and component-level requirements above and surfaces the result on the SBOM detail page. Enable it from the Plugins page in your workspace sidebar:

Additional resources


Disclaimer: This page represents our interpretation of the referenced framework. While we strive for accuracy, we may have made errors or omissions. This content is provided for informational purposes only and does not constitute legal advice. For compliance decisions, consult the official source documents and seek qualified legal counsel.

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