Regulatory Compliance with SBOMs

Overview

Regulatory requirements are increasing globally. Organizations must demonstrate that they understand and control the software components they use, buy, and sell. SBOMs provide the foundation for this oversight, and SBOM Observer helps you enforce compliance with regulations like NIS2, CRA, DORA, and custom requirements from customers or auditors.

Why Regulatory Compliance Matters

Regulatory bodies and customers increasingly require:

• Complete visibility into software composition and supply chains
• Risk management for vulnerabilities and security issues
• Audit trails showing compliance with specific requirements
• Incident response capabilities backed by component knowledge

Non-compliance can result in:

• Fines and penalties from regulatory bodies
• Contract breaches with customers who have compliance clauses
• Operational disruptions when non-compliance is discovered
• Reputational damage in your market

Getting Started with SBOM Observer

1. Identify Your Compliance Requirements

Determine which regulations apply to your organization:

2. Generate and Collect SBOMs

Create a comprehensive view of your software inventory:

# Generate a CycloneDX SBOM for each application (see /getting-started/observer-cli)
observer fs -o sbom.json .

For vendor software, request SBOMs as part of procurement and upload them alongside your internally generated SBOMs.

3. Map Requirements to Policies

Convert compliance requirements into SBOM Observer policies:

NIS2 Compliance Policy Example:
- All vulnerabilities with CVSS >= 7.0 must be resolved within 30 days
- Production systems must not contain end-of-life components
- All third-party components must be documented in SBOMs
- Vulnerability patches must be tracked and approved

CRA Compliance Policy Example:
- Security updates must be applied within 60 days of release
- Known vulnerabilities must not be present in released software
- Components with active security support are required

4. Define Your Baseline

Establish minimum requirements that all software must meet:

• Supported versions only - No EOL (end-of-life) components
• Known vulnerabilities - Maximum acceptable risk level
• Security patches - Maximum age of security updates
• Vendor support - Commercial support requirements
• License compliance - Acceptable license categories

5. Enforce and Monitor

SBOM Observer automatically:

• Tracks all components against your requirements
• Highlights policy violations in real-time
• Maintains audit trails of compliance status
• Generates reports for auditors

Use the Observer CLI (documented in /getting-started/observer-cli and /references/cli) to upload and analyze each SBOM inside your CI/CD pipeline:

observer upload sbom.json
observer analyze sbom.json --fail

Compliance Scenarios

Scenario 1: New Regulation Enforcement

A new regulation is announced. You need to:

1. Define the policy requirements
2. Create the policy in SBOM Observer
3. Scan all current software against new requirements
4. Prioritize remediation for critical violations

Result: You understand your regulatory exposure immediately.

Scenario 2: Vendor Risk Assessment

You're evaluating a software vendor or acquisition. You need to:

1. Request SBOM from the vendor
2. Upload to SBOM Observer
3. Check against your compliance policies
4. Generate risk report

Result: Informed decision-making with vulnerability and compliance data.

Scenario 3: Audit Preparation

An auditor requests proof of compliance. You:

1. Run compliance report in SBOM Observer
2. Export audit trail with all components and versions
3. Demonstrate policy enforcement and violations
4. Show remediation history

Result: Audit-ready documentation proving compliance efforts.

Scenario 4: Customer Requirements

A customer requires compliance with their standards. You:

1. Create customer-specific policy
2. Check your software against their requirements
3. Document compliance or identify gaps
4. Share results with customer

Result: Transparent, data-backed compliance communication.

Implementation Timeline

Phase 1: Foundation (Weeks 1-4)

• Identify applicable regulations
• Generate SBOMs for all applications
• Create baseline compliance policy

Phase 2: Enforcement (Weeks 5-8)

• Set up SBOM Observer policies
• Integrate with CI/CD pipeline
• Begin tracking compliance metrics

Phase 3: Optimization (Weeks 9-12)

• Refine policies based on findings
• Establish remediation workflows
• Create audit documentation

Best Practices

✅ Do:

• Keep compliance requirements updated
• Integrate compliance checks into CI/CD
• Review compliance violations regularly
• Train teams on compliance requirements
• Maintain clear audit trails
• Request SBOMs from all vendors
• Document compliance decisions

❌ Don't:

• Ignore policy violations
• Skip compliance checks for "internal only" software
• Assume regulatory requirements don't apply to you
• Let compliance become a one-time audit exercise
• Store compliance data inconsistently

Reporting for Compliance

SBOM Observer generates audit-ready reports:

Leverage SBOM Observer's built-in reports and exports to satisfy auditors:

• Use Reports → Compliance to download the latest policy status (see /how-to/share-sboms)
• Export component inventories or vulnerability summaries directly from the dashboard for audit packets
• Capture remediation history by linking policy violations to tickets or change records

Next Steps

1. Review your applicable regulations
2. Define your baseline policy
3. Generate SBOMs
4. Set up compliance monitoring
5. Create audit documentation

Additional Resources

• NIS2 Directive (EU-NOD 2022/2555)
• Cyber Resilience Act (CRA)
• DORA (Digital Operational Resilience Act)
• SBOM Overview & Getting Started