Understanding Software Bill of Materials (SBOM) Requirements
A few years ago, asking a software vendor for a list of every component in their product would have been an unusual request. Today it is becoming a routine part of procurement, contracting, and regulatory compliance. The Software Bill of Materials, or SBOM, has moved from a niche supply chain concept to an expected piece of documentation across regulated industries.
For finance, healthcare, and other compliance-driven sectors, understanding SBOM requirements is no longer optional. This post explains what an SBOM is, why it has become a focal point of cybersecurity policy, and what a practical SBOM strategy looks like for firms that build, buy, or rely on software.
What an SBOM Actually Is
An SBOM is a structured inventory of the components that make up a piece of software. That includes open-source libraries, third-party dependencies, embedded modules, and the version information for each. The closest non-technical analogy is the ingredient list on a food package: it does not tell you whether the product is good or bad, but it gives anyone who needs to evaluate it a clear starting point.
SBOMs are typically expressed in machine-readable formats such as SPDX or CycloneDX, both of which are recognized standards. The point of having a standard is that downstream consumers, whether buyers, auditors, or regulators, can read SBOMs from many different vendors using the same tools. Without that standardization, the inventory loses much of its value.
Why SBOMs Have Become a Regulatory Focus
Several events over the past few years have pushed SBOMs from a good idea to a required practice. The Log4j vulnerability disclosed in late 2021 made vivid how a single component buried deep inside thousands of products could create a global incident. Without an SBOM, organizations spent weeks trying to figure out which of their applications even contained the affected library.
That experience accelerated policy work that was already underway. The U.S. executive order on cybersecurity in 2021 directed federal agencies to include SBOM requirements in software purchasing, and subsequent guidance from the National Telecommunications and Information Administration, the Cybersecurity and Infrastructure Security Agency, and the National Institute of Standards and Technology has steadily formalized expectations. For regulated industries such as financial services and healthcare, those expectations are increasingly flowing into industry-specific examination and audit frameworks.
The trend reflects a broader principle that we explore in our overview of how IT compliance has evolved: regulators are moving from rule-following to risk management, and SBOMs fit that movement squarely.
What an SBOM Should Contain
A useful SBOM is not just a list of names. To support the decisions it is meant to support, it has to be detailed and structured enough that downstream tools and people can act on it without guessing.
The minimum elements established by NTIA guidance are widely accepted as a baseline, though many industries are adding their own extensions. When evaluating an incoming SBOM from a vendor, or designing one for your own software, the items to expect include:
The name and version of each component
The supplier or origin of the component
Cryptographic hashes that allow integrity verification
Relationship information showing which components depend on which others
License information for each component
A timestamp indicating when the SBOM was generated
When all of these are present in a standard format, the SBOM becomes a working document. When pieces are missing, the value drops sharply because consumers cannot trust or correlate the data.
Five Practical Steps Toward SBOM Readiness
Most firms do not need to become SBOM experts overnight. They need a practical path that builds capability over time and aligns with whatever regulatory or contractual obligations apply to them. The following sequence is what we typically recommend.
1. Identify Where SBOMs Apply to Your Firm
The first step is to map where your firm sits in the software supply chain. Are you primarily a buyer, a builder, or both? If you procure software, your priority is requesting and reviewing SBOMs from vendors. If you develop software, including in-house tools and integrations, your priority is producing SBOMs for the artifacts you ship.
2. Inventory the Software You Already Run
Before SBOMs become useful, you need to know what software is in your environment. That includes commercial applications, internally developed tools, open-source utilities, and any embedded systems. An incomplete inventory makes any SBOM program incomplete by extension.
3. Update Procurement Language
Contractual language is where SBOM expectations become enforceable. Updated procurement terms should specify the format you require, the timing of updates (typically with each release or material change), and the way SBOMs will be delivered. Working with your legal and procurement teams on this language is a one-time investment that pays off across every future vendor relationship.
4. Build an Internal Process for Review
An SBOM you do not look at is a file on a server. To realize value, build a lightweight process for reviewing incoming SBOMs against known vulnerability data, license requirements, and your own risk thresholds. The first version of this process can be manual. Tooling can come later.
5. Connect SBOM Work to Broader Risk Management
SBOMs are most valuable when they are integrated with the rest of your security and risk program rather than treated as a stand-alone exercise. Ties to vulnerability management, incident response, and vendor risk all multiply the return. The NIST risk management framework for information systems is a useful organizing structure for that integration.
These five steps can be sequenced over months rather than weeks, and they build a foundation that scales as requirements evolve.
How SBOMs Fit Into Compliance for Regulated Industries
For firms operating under specific regulatory regimes, SBOM expectations are increasingly being incorporated into examination and audit work. The SEC and FINRA compliance landscape for financial services firms is one example where supply chain transparency is becoming part of broader cybersecurity expectations. Healthcare, federal contracting, and critical infrastructure sectors are seeing similar movement.
The practical implication is that firms in regulated industries should not wait for an explicit mandate before starting their SBOM work. The capability takes time to build, and being ready when an examiner or contracting party asks is far easier than scrambling at the moment of the request.
Where Strategic IT Advisors Add Value
Most firms do not need a full-time SBOM specialist. They need someone who can take a clear position on what their SBOM posture should look like given their size, their industry, and their software profile, and then help them get there.
A strategic IT advisor brings three things to the SBOM conversation. The first is a defensible point of view on which standards and tools to adopt, so the firm is not navigating that landscape alone. The second is integration of SBOM work with adjacent security functions such as secure software development practices, patch management, and threat operations. The third is the ability to translate SBOM concepts into language that boards and executives can engage with, so program decisions get the attention and funding they need.
Conclusion
SBOMs are not a passing compliance fashion. They are a structural response to a real change in how software is built and distributed, and they are becoming part of the standard expectations that regulators, clients, and partners apply to the firms they work with.
At Pendello Solutions, we turn technology hurdles into powerful assets. Our technology solutions fuel growth, productivity, and efficiency, through continuous innovation and strategic solutions, empowering your business beyond the imaginable. Contact us today to discover the Pendello Method.