Maintaining software security is more critical than ever in today's digital landscape. Regulatory bodies across the globe have recognized this, mandating comprehensive cybersecurity compliance frameworks. A key artifact in these frameworks is the Software Bill of Materials (SBOM), a list detailing the components that make up a software product.
SBOM has become pivotal in cybersecurity, and compliance with several regulations now requires it explicitly.
Let's explore the role of SBOM in major regulations such as the Cyber Resilience Act, FDA cybersecurity compliance, Executive Order 14028, and how it supports compliance with NIS2, DORA, and PCI DSS 4.0, even though it’s not a mandatory artifact in some cases.
SBOM as a Required Artifact
Cyber Resilience Act (CRA)
The European Union's Cyber Resilience Act aims to establish clear cybersecurity standards for products with digital elements. The Act explicitly mandates the inclusion of an SBOM to ensure manufacturers, developers, and operators understand the software’s components, helping mitigate risks from vulnerabilities in third-party software. The SBOM acts as a critical document for transparency and accountability.
FDA Cybersecurity Compliance
The U.S. Food and Drug Administration (FDA) now mandates an SBOM as part of premarket submissions for medical devices. This requirement, effective as of October 2023, ensures that all software and components in a medical device are disclosed. This helps identify and mitigate potential cybersecurity risks, thus protecting patient safety.
Executive Order 14028
This executive order, issued by President Biden in May 2021, aims to improve the nation’s cybersecurity posture. A core requirement is that federal agencies procure software that includes an SBOM. This policy promotes transparency and enables better vulnerability management across software supply chains.
SBOM for Broader Compliance: NIS2, DORA, and PCI DSS 4.0
Although SBOM is not a required artifact in some regulations, it is still an immensely useful tool for meeting compliance. Here's how it plays a role in key frameworks:
NIS2 Directive
The EU's NIS2 Directive focuses on strengthening critical infrastructure cybersecurity across the union. Although SBOM is not explicitly mandated, having an SBOM can be a valuable asset to demonstrate due diligence in securing software supply chains. With SBOMs, organizations can show a deeper understanding of their software’s vulnerabilities and take proactive measures to mitigate risks.
Digital Operational Resilience Act (DORA)
DORA aims to strengthen the cyber resilience of financial entities within the EU. While the Act doesn’t explicitly mandate the use of an SBOM, incorporating one into the software lifecycle enables financial institutions to better manage third-party risks. SBOMs enhance compliance by improving the transparency of software components, which is essential for quickly addressing vulnerabilities.
DORA places a strong emphasis on robust ICT risk management frameworks to ensure operational resilience. An SBOM supports these efforts by creating a comprehensive inventory of software components and identifying known vulnerabilities. Furthermore, DORA requires effective risk management across the entire ICT supply chain. SBOMs facilitate this by highlighting malicious, deprecated, end-of-life, or vulnerable components within the supply chain, providing a clearer view of potential risks.
The Act also mandates resilience testing and incident response capabilities. SBOMs are designed to minimize response times for zero-day vulnerabilities by tracking software components and their associated vulnerabilities.
Additionally, DORA aligns with global standards like the NIS2 Directive. SBOM adoption helps bridge compliance with both frameworks, promoting unified practices while preparing organizations for other software transparency requirements, such as the Cyber Resilience Act’s SBOM mandates.
PCI DSS 4.0
The latest version of PCI DSS focuses on securing payment card data in an increasingly complex threat landscape. While SBOM is not directly required, it can significantly streamline compliance by providing a clear understanding of third-party software components and any potential vulnerabilities. This aligns with PCI DSS 4.0's emphasis on maintaining robust controls over software to safeguard sensitive data.
Timelines
Each regulation has its timeline for when these cybersecurity requirements come into effect. Here are the known dates for several key regulations:
- FDA Cybersecurity Compliance: Effective October 2023
- Digital Operational Resilience Act (DORA): Effective January 17 2025
- PCI DSS 4.0: Enforced starting March 2025, with some flexibility for entities to transition.
- NIS2 Directive: Member states have until October 2024 to implement the directive into national law.
- Cyber Resilience Act (CRA): The final implementation deadline is still evolving but is expected by 2025.
- Executive Order 14028: The SBOM requirements are currently enforced for federal agencies acquiring software, and the guidelines are updated regularly.
In the evolving landscape of cybersecurity regulations, SBOM has become a critical tool for managing vulnerabilities and ensuring compliance. It is a required artifact for frameworks like the Cyber Resilience Act, FDA cybersecurity compliance, and Executive Order 14028, where transparency in software composition is vital. While regulations like NIS2, DORA, and PCI DSS 4.0 are not required, SBOM provides significant value in ensuring resilience, transparency, and faster incident response, making it a strategic asset for compliance across various sectors.
Understanding the different implementation timelines and requirements can help organizations proactively prepare to meet these standards and enhance their cybersecurity posture.
