In August, the US Cybersecurity and Infrastructure Security Agency (CISA) published a draft for public comment on updated guidance building on NTIA's 2021 The Minimum Elements for a Software Bill of Materials. In the four years since its original publication, the SBOM landscape has changed dramatically. What began as a recommended best practice is now a foundational component of global cybersecurity policy. Legislative frameworks like OMB M-22-18, Executive Order 14028, and the National Cyber Strategy underscore the critical role SBOMs play in procurement security, compliance, and operational resilience.
As the nation's leading cybersecurity authority, CISA issued this draft update expressly to reflect the evolving needs and capabilities around SBOMs. The new guidance introduces additional elements and provides a roadmap for Federal organizations to strengthen both the quality and security of their software supply chains. At Sonatype, we've been championing the effective use of SBOMs as part of a secure supply chain and recognize that it's no longer a box to check. Agencies and organizations increasingly recognize their strategic value, with recent legislation amplifying the urgency for comprehensive adoption.
Done right, they accelerate the Authority to Operate (ATO) process and align with the broader push for secure digital transformation. In a show of joint international support, CISA and NSA recently published A Shared Vision of Software Bill of Materials (SBOM) for Cybersecurity that advocates for SBOM adoption and presents additional guidance endorsed by 19 international cybersecurity organizations.
In this blog, we'll show how organizations can move beyond viewing SBOM management as a compliance formality and instead use it as a driver for proactive, risk-based software assurance.
The Shifting SBOM Landscape and What's Changed Since 2021
CISA's 2025 draft guidance introduces some key additions, including Component Hash, License Information, Tool Name, and Generation Context. All of these elements are meant to equip agencies with verifiable, actionable insights about their software. This moves SBOMs out of the realm of a simple checklist of included components.
Along with this evolution, SBOM tooling continues to mature. Automation is now essential, because manual processes just can't keep up with the incredible pace of today's development cycles or the scale of modern environments. Automation keeps SBOMs current and also helps build security and compliance directly into CI/CD pipelines.
Federal agencies are also unlocking new use cases for SBOMs. Integration with Vulnerability Exploitability Exchange (VEX) enables rapid vulnerability correlation and prioritization, empowering teams to respond faster and reduce risk. As agencies adopt more SaaS and AI-driven solutions, SBOMs grant visibility into third-party software dependencies that once appeared opaque. Ultimately, today's SBOMs provide meaningful, real-time insights and bridge the gap between compliance and proactive risk management. Agencies are expected to deliver SBOMs that inform action, not just fulfill requirements.
The Business Case for Strategic SBOM Management
Treating SBOMs as a strategic asset rather than a compliance checkbox delivers significant business value. From procurement to productivity, a mature SBOM program provides the intelligence needed to operate securely and efficiently in a complex software landscape.
Secure Procurement and Streamline Compliance
As federal mandates evolve, contracts will increasingly require SBOMs that meet CISA standards. Proactively managing high-quality SBOMs ensures you can meet procurement obligations without delay. Furthermore, this practice is central to aligning with NIST's Secure Software Development Framework (SSDF), a key requirement for software suppliers to Federal agencies. A robust SBOM program provides the evidence needed to demonstrate secure development practices, streamlining compliance and building trust with government partners. This directly accelerates the ATO process.
Elevate Risk Management and Incident Response
Based on Sonatype's own research, we know software supply chain attacks increased more than 700% between 2019 and 2022, with the average data breach costing $4.35 million. This focus by bad actors on the supply chain and the potential for widespread damage makes it clear why SBOMs are becoming so valuable. They provide clarity, offering detailed insight into component licenses, provenance, and hashes to reduce blind spots. This visibility is especially critical during a crisis. The Log4j vulnerability demonstrated how organizations with mature SBOM programs could identify their exposure in hours, not weeks. Those without proper tooling and visibility found themselves still exposed months later. A comprehensive SBOM, paired with a VEX document, accelerates incident response by pinpointing exactly where you are vulnerable, enabling faster remediation and proactive vendor risk management.
Effective SBOM management also directly correlates to developer productivity. Automated tooling provides immediate visibility into component quality and security, so developers can select better, safer components from the start. By catching issues early, you reduce the rework and technical debt that slows teams down. This enables faster, more secure development cycles, freeing developers to focus on innovation instead of remediation.
Making SBOMs Actionable
An actionable SBOM is a source of continuous intelligence that strengthens your entire software supply chain. Agencies need to think in terms of automation at scale. This means implementing systems that automatically ingest, enrich, and correlate SBOM data as it arrives. An effective program doesn't just collect SBOMs, it uses them to fuel a continuous cycle of analysis and risk management without manual intervention.
Fuel Your C-SCRM Program
Think of an SBOM not as the end goal, but as essential fuel for your Cyber Supply Chain Risk Management (C-SCRM) program. A mature C-SCRM toolkit automatically ingests SBOMs from vendors and internal development teams. It then analyzes them for known vulnerabilities and license risks, updating the software's risk profile in real-time. This transforms compliance from a static check into a living, breathing part of your security posture.
Garbage In, Garbage Out: Data Quality Matters
The effectiveness of this entire process depends on the quality of the SBOM data. A poor-quality SBOM — one that is incomplete, inaccurate, or out-of-date — can be worse than having no SBOM at all, creating a false sense of security. True software transparency requires data that is accurate, provides sufficient depth, and is continuously updated to reflect the current state of the software.
Connect SBOMs to Vulnerability Management
To make SBOMs truly actionable, they must be integrated with vulnerability advisories and management tools. Pairing an SBOM with formats like the VEX and the Common Security Advisory Framework (CSAF) helps resolve the "known unknowns" with speed and precision. This combination allows security teams to quickly determine if a vulnerability in a component is actually exploitable in their environment, allowing them to prioritize what really matters.
This approach is a core component of a modern, secure software supply chain, where SBOMs are one piece of the puzzle. The goal should be to achieve full life cycle intelligence, from initial open source governance to runtime security.
What Now? Practical Next Steps for Federal Agencies
Building greater trust through transparency is essential for resilience across the federal software supply chain, and the 2025 Minimum Elements from CISA are a critical step forward.
To align with this new standard, agencies should begin requiring SBOMs that meet these updated elements in all new software acquisitions. It is also the right time to audit your current tooling. Can it generate, consume, and correlate SBOMs in standard formats like SPDX and CycloneDX?
Plan for automation by integrating API-based delivery into your DevSecOps pipelines, and prepare for emerging guidance on SaaS and AI. Partnering with a vendor who can help operationalize SBOM data is key to transforming this information into actionable intelligence for vulnerability management and sustained compliance.
To see how agencies are using SBOM management solutions to simplify compliance and strengthen security, book a customized demo today.
Tom Tapley specializes in securing software supply chains for Federal environments, bringing deep expertise in aligning agency security, compliance, and operational requirements with modern technology solutions. With a proven track record in supporting mission-critical systems, he bridges the gap ...
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