The Software Bill of Materials (SBOM) is quickly changing from a best practice to a requirement in software supply chains worldwide. As software grows more complex, with layers of open-source libraries and third-party components, organizations and governments realize that understanding software composition is vital for security, compliance, and resilience.

Today, companies need to know not just what software they use but also how it is built, which components are involved, and what risks those components may pose. This need is real, as governments around the world are mandating SBOMs in many situations, especially for software procurement, critical infrastructure, and regulated industries. This blog looks at why SBOM is becoming a requirement in software supply chains globally, the regulatory reasons behind this shift, and what it means for organizations in India and elsewhere.

Understanding SBOM: A Foundation of Software Transparency

A Software Bill of Materials (SBOM) is a detailed list of all components open source, proprietary, and third-party that make up a software product. It works like an ingredient list on packaged foods, showing each component’s name, version, supplier, and its relation to other parts of the software. SBOM aims to provide clear visibility into software supply chains, helping with risk, vulnerability, and compliance management throughout the software lifecycle.

While SBOM was once mainly a tool for risk management or cybersecurity, its role is growing due to new legal and regulatory needs worldwide.

Historical Context: From Best Practice to Required Compliance

The push for mandatory SBOM adoption started with major software supply chain attacks, like the SolarWinds breach, which revealed fundamental weaknesses in how organizations and software vendors handle dependencies and third-party code.

In response, governments began formalizing software transparency and supply chain risk management requirements. An important early step was the U.S. Executive Order 14028 on Improving the Nation’s Cybersecurity, issued in 2021. This order required the use of SBOMs for federal software procurement and suppliers. The U.S. government mandated that software producers give SBOMs to federal agencies as part of cybersecurity and procurement processes.

This executive order changed regulatory expectations: SBOMs became a requirement for compliance in federal contracts, not just optional guidance. Many other regulations and policies are now following this lead.

Global Regulatory Drivers Making SBOM Mandatory

1. U.S. Federal Procurement Requirements

In the U.S., software vendors selling to federal agencies must supply SBOMs that meet specific standards and formats like SPDX or CycloneDX. This requirement is actively enforced through procurement policy.

Further, guidance from the Cybersecurity and Infrastructure Security Agency (CISA) and other regulatory bodies signals broader expectations for SBOMs to be part of secure software development and procurement.

2. European Union Cyber Resilience Act (CRA)

In the EU, the Cyber Resilience Act (CRA) is set to make SBOMs mandatory for software products with digital elements sold within the EU. Manufacturers, importers, and distributors will need to provide SBOMs as part of the technical documents required for CE certification and market access. Non-compliance could lead to restrictions or bans on selling software products in the EU.

This requirement positions SBOM as necessary for legal market participation, not just a security option.

3. Indian Regulatory Expectations

India has also recognized SBOM as a crucial part of cybersecurity and operational resilience. Organizations like SEBI (Securities and Exchange Board of India) require critical entities, especially in financial services, to maintain SBOMs as part of the Cybersecurity and Cyber Resilience Framework (CSCRF). These SBOMs must be regularly updated to reflect software component changes, following global standards.

Additionally, CERT-In (Indian Computer Emergency Response Team) requires SBOM scanning and reporting for both domestic and imported technologies to identify vulnerabilities and unauthorized code before deployment.

4. Sectoral and Industry Standards Alignment

Beyond government requirements, industry standards bodies and frameworks like NIST SSDF (Secure Software Development Framework) and ISO specifications have made SBOM central to secure software development practices, making SBOM compliance essential for adhering to modern software security principles.

Why Regulatory Mandates Are Accelerating SBOM Adoption

Addressing Software Supply Chain Risk

Modern software often includes code from various sources, such as third-party libraries and open-source components, which are maintained by different external parties. While these components speed up development, they also create security and compliance issues. When a vulnerability like Log4j or other significant CVEs affects the supply chain, organizations without SBOM visibility find it hard to assess impacts and respond quickly.

SBOM provides structured transparency that helps identify, assess, and fix vulnerabilities quickly especially when combined with vulnerability databases and automated tools.

Enabling Faster Incident Response

With SBOMs, software teams and security professionals can pinpoint exactly which deployed systems contain vulnerable components and prioritize mitigation actions. SBOMs provide the inventory needed to speed up vulnerability scanning and patch planning. This visibility is crucial for modern DevSecOps and supply chain security strategies.

Supporting Compliance Beyond Borders

Regulations like the EU CRA and Indian SEBI mandates apply not only to local vendors but also to international suppliers and software used in regulated sectors. Therefore, software vendors with global customers must be ready to provide SBOMs for compliance, no matter where they operate.

For companies, failing to meet SBOM requirements can lead to loss of market access, exclusion from public sector contracts, and possible legal and operational penalties.

SBOM in Procurement and Vendor Risk Management

Contractual Requirements and Due Diligence

Regulated companies increasingly include SBOM requirements in vendor contracts and procurement agreements. This change shows that visibility into third-party software reduces risk and increases accountability.

Procurement teams now routinely check SBOM compliance alongside security questionnaires and service level agreements. This trend is reshaping how vendors operate, with SBOM becoming a basic requirement for enterprise software contracts.

Licensing and Intellectual Property Management

SBOMs also help with compliance to open-source licensing rules. By providing detailed information about component versions and licenses used, SBOMs assist organizations in avoiding unintentional breaches of open-source terms, ensuring legal compliance across different jurisdictions.

Implementation Challenges and Best Practices

Despite its growing importance, adopting SBOMs comes with challenges, including:

• Choosing compatible SBOM formats like SPDX or CycloneDX

• Generating SBOMs consistently across build and CI/CD processes

• Integrating SBOM data into security workflows and asset inventories

• Keeping SBOMs accurate and updated as software changes

Regulatory guidance from organizations like NTIA and CISA clarifies expectations by defining minimum SBOM elements and recommended practices for structured production and distribution.

To move beyond mere compliance, companies should adopt automation, governance workflows, and tools that integrate SBOM generation and validation into their software lifecycle.

Conclusion

Software supply chain security has evolved from a technical issue to a regulatory priority. Mandates like the U.S. Executive Order 14028, the EU Cyber Resilience Act, and India’s SEBI CSCRF are pushing a global push toward mandatory SBOM adoption as a fundamental part of secure, transparent software supply chains.

For companies in regulated markets or global sectors, SBOM compliance is essential not optional for market access, risk management, and secure software delivery.

A strong governance framework that ensures SBOM visibility is crucial for modern enterprises. CastlerCode helps organizations create structured approaches to software supply chain transparency and resilience, improving their ability to meet changing regulatory needs and manage software risk proactively.

To improve your software supply chain with transparency and readiness for compliance, consider CastlerCode solutions.