From SBOM Generation to SBOM Management: the Next Software Supply Chain Challenge

SBOMs have become central to software transparency but generating complete and reliable SBOMs is only the first challenge. As organizations begin to master the generation of SBOMs, enterprises are turning their attention to managing SBOMs. This is the next challenge and an opportunity for organizations to turn them into living, strategic assets instead of static documents gathering dust.

SBOM Generation Is Just the Beginning

SBOMs are an expected part of software development and governance in response to growing demands for transparency from customers, regulators, and internal compliance teams. Over time, they’ve evolved from a basic compliance checkbox into a critical tool, providing organizations with a snapshot of their open source and third-party components. However, for many organizations, the SBOM story ends there, at the generation stage. Teams produce an SBOM to check a box, satisfy customer requests, or meet procurement and regulatory requirements, and then move on to other tasks. The snapshot quickly becomes stale due to shifting dependencies, changes in the build, and the introduction of new vulnerabilities. Without proper management (including versioning, updating, and monitoring), SBOMs risk becoming outdated static files rather than the living, actionable artifacts they’re meant to be. It’s time for organizations to close this gap and start treating SBOMs as an ongoing practice, not just a one-off task.

The Importance of SBOM Management

An SBOM is meant to answer a simple question: What’s inside this software? But as we know, software is never static. With CI/CD pipelines in full swing and AI coding assistants being more widely adopted, new dependencies are added, vulnerabilities are discovered, and even a minor patch can change a build. For example, an SBOM created on release day might already be outdated one minute later by the time the next pull request comes in and is merged.

At FossID, we work with some of the largest global enterprises and have seen firsthand how some organizations get caught during audits or security incidents, unable to confidently answer questions such as: Does this SBOM reflect what’s running in production? Or which version is affected by this CVE? The Heartbleed bug was a wake-up call for many organizations to reflect on their SBOM practices and consider improvements. Without tying SBOMs directly to builds and keeping them up to date, compliance, security, and risk management leave too much guesswork. Furthermore, there are intensifying regulatory and market pressures, making the management of SBOMs an organizational priority.

A Shifting Landscape

The urgency around SBOM management is real, and regulators have made their expectations clear.

• In the U.S., Executive Order 14028 and OMB’s M-22-18 memorandum require federal software suppliers to provide SBOMs
• The EU Cyber Resilience Act and the emerging AI Act emphasize transparency, traceability, and secure supply chains
• NIST’s Secure Software Development Framework (SSDF) outlines SBOM-related practices as part of a secure software development process

At the same time, enterprise customers are demanding more: they want Software Composition Analysis (SCA) vendors who can show exactly what’s in their software and how it’s managed. As supply chain attacks grow more sophisticated, organizations have to move beyond simply producing SBOMs and start treating them as strategic assets. Meeting such high expectations means that organizations must first address some practical challenges and operationalize SBOM management as part of their day-to-day operation.

Five Challenges of SBOM Management

There are five particular challenges we identified as part of operationalizing SBOM management:

1. Versioning and Traceability: An SBOM should tie to a specific artifact, such as a container image, a binary, or a Git commit. Organizations can’t confirm with certainty what is in production, what has been released to customers, or what changed between any two releases unless this connection is established.
2. Storage and Retrieval: Many organizations store SBOMs as flat files in shared drives, document management tools, or other means, making them difficult to locate during audits or security incidents. There is a clear need for a proper storage system to store SBOM centrally and make them searchable.
3. Continuous Monitoring: It is common for vulnerabilities to surface months after a release has been deployed. If organizations don’t monitor SBOMs over time, they won’t be able to know which versions are affected.
4. Workflow Integration: SBOMs should show up where people work. Developers need them when managing dependencies, security teams during triage, and legal and compliance teams for license reviews.
5. Governance and Automation: At scale, governance requires clear ownership and automation. Policies like “No deployment without an SBOM” need to be implemented, communicated, supervised, and enforced without disrupting productivity.

By addressing these challenges, organizations can elevate SBOM practices from a basic checkbox to a resilient and scalable part of their operations.

Seven Steps to Mature SBOM Management

Organizations that treat SBOMs as dynamic, strategic assets experience tangible improvements in their open source governance, compliance, and security. Such organizations tend to share some key common traits: their processes are automated, integrated into everyday workflows, and accessible to all relevant teams (legal, compliance, security, and engineering).

Here are seven practical recommendations that organizations can follow and implement in their journey to move toward mature SBOM management:

1. Appoint an owner: Designate someone responsible for driving the SBOM strategy, implementation, and day-to-day execution. This leader should collaborate across engineering, security, compliance, and legal teams to ensure alignment and accountability. Their focus daily is the management of the end-to-end SBOM lifecycle.
2. Automate generation and traceability: Embed SBOM creation directly into your CI/CD pipelines so it happens with every build, not just at release, and tie each SBOM to a specific artifact using container hashes, Git commits, or build IDs. This not only ensures traceability but also supports reproducible builds – making it easier to track and verify patches across versions.
3. Use standard formats: Adopt widely-accepted SBOM formats such as SPDX (ISO/IEC 5962) from the Linux Foundation or CycloneDX from the Open Web Application Security Project (OWASP) to ensure interoperability and ease of exchange.
4. Centralize storage and versioning: Store SBOMs in a searchable, versioned repository that includes metadata (owner, creation date, environment, platform) for easy retrieval during audits, incident response, or customer inquiries.
5. Monitor continuously: Implement or integrate SCA tools with your development environment to allow the detection of new vulnerabilities, license changes, or other risks (dependency changes, for instance) over time, ensuring SBOMs remain accurate and actionable even after release.
6. Integrate into workflows: Make SBOMs accessible through developer portals, dashboards, or APIs so developers, security, legal, and compliance teams can use them effectively as part of their daily work.
7. Align with standards: Map your SBOM practices to industry initiatives such as OpenChain (ISO/IEC 5230 for OSS compliance), NTIA’s minimum SBOM elements, OpenSSF’s SLSA framework, and the Common Security Advisory Framework (CSAF) for vulnerability advisories.

By implementing these recommendations, organizations can transform their SBOM practices from a mere compliance checkbox into a core operational element of their governance, compliance, security, and risk management strategy while also meeting evolving regulatory and customer expectations.

Looking Ahead

SBOMs initially emerged as a compliance requirement, but they can deliver significantly more value than originally thought. When organizations treat SBOMs as strategic assets, they enable faster, more confident incident response, simplify audits, build trust with customers and regulators, and strengthen their security practices.

The good news? The standards, tools, and best practices are already in place and continue to mature quickly. The question is now whether your organization is ready to transition from just generating SBOMs to also managing them. By moving beyond just generation and also achieving mature SBOM management, organizations can turn transparency into a competitive advantage and ensure resilience in an increasingly complex software supply chain.

If your organization is ready to move beyond SBOM generation toward mature SBOM practices, start by ensuring the quality and completeness of your SBOMs today. FossID helps you produce high-quality SBOMs and integrate compliance checks into your workflows, laying the foundation for scalable and robust SBOM management. Contact us today to learn how we can help you take the next step.