Supply chain transparency required by the CRA, NIS2 and your customers

SBOM: the software parts list that is becoming mandatory

An SBOM (Software Bill of Materials) lists all components of your software in machine-readable form and makes the supply chain transparent.

  • 01Answers in minutes instead of weeks: which products contain the vulnerable component?
  • 02CRA-compliant: SBOM per Annex I, presentable to the BSI (TR-03183-2)
  • 03Automated instead of hand-maintained: SBOM generation in every pipeline (Syft, Trivy, CycloneDX, SPDX)
  • 04VEX instead of alert floods: documented exploitability assessment per vulnerability
  • 05Connected to your vulnerability management and reporting processes from 11 Sep 2026
11+Years of experience
120+Employees
540+Projects
ISO 27001certified

What is an SBOM, and why is it becoming mandatory now?

An SBOM (Software Bill of Materials) is the machine-readable parts list of a piece of software: it enumerates every component a product is built from, in-house modules, open-source libraries, purchased components and their dependencies, each with version, licence and origin. What the bill of materials has been to manufacturing for decades, the SBOM now brings to the software supply chain: verifiable transparency about what is actually inside a product.

We accompany you in developing and implementing comprehensive SBOM strategies that meet CRA requirements while creating strategic advantages through improved supply chain visibility and proactive vulnerability management.

6 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

SBOM readiness assessment

Baseline in one to two weeks: which products need SBOMs, which build processes exist, where you stand against CRA Annex I and BSI TR-03183-2.

  • Product inventory with CRA applicability per product
  • Gap rating against CRA, NIS2 and customer requirements
  • Prioritised roadmap with effort estimate
02

Tool selection and format strategy

Vendor-neutral choice: CycloneDX or SPDX, Syft, Trivy, Microsoft SBOM Tool or platform generators, matched to your build landscape.

  • Format decision aligned with customer and authority requirements
  • Tool evaluation in a PoC against your real builds
  • Container, firmware and legacy strategies
03

CI/CD integration and automation

SBOM generation as a fixed step in every pipeline: automatic, versioned, signed. Manually maintained SBOMs are outdated with the first release.

  • Pipeline integration (GitLab, GitHub, Jenkins, Azure DevOps)
  • Signing and integrity evidence for SBOM artefacts
  • Central storage versioned per product release
04

SBOM management and vulnerability integration

SBOMs create value in operation: continuous matching against CVE feeds, VEX statements, connection to your vulnerability management.

  • Dependency-Track or comparable platform set-up
  • VEX process: documented assessment instead of alert floods
  • Connection to vulnerability management and incident response
05

CRA compliance and evidence

The SBOM as part of the technical documentation under CRA Annex VII: presentable to the BSI, robust in conformity assessment.

  • Documentation structure per CRA Annex I and VII
  • Reporting processes from 11 Sep 2026 (ENISA early warning 24h/72h)
  • Preparation for market surveillance requests
06

Supplier SBOMs and procurement

Demand, validate and merge SBOMs from your suppliers: contract clauses, quality criteria and handling incomplete deliveries.

  • SBOM requirement catalogue for procurement and contracts
  • Quality checks on incoming SBOMs (NTIA minimum elements)
  • Merging into complete product SBOMs

5 phases

Our approach: SBOM adoption in five phases

We start with the products facing the earliest CRA deadlines and bring generation, management and vulnerability integration into steady state one after the other.

  1. Phase 1, readiness

    weeks 1 to 2

    product inventory, CRA applicability per product, build landscape, gap against BSI TR-03183-2.

    prioritised roadmap.

  2. Phase 2, pilot

    weeks 3 to 4

    tool selection in a PoC on a real product, format decision CycloneDX or SPDX, first automatically generated SBOM in the build.

  3. Phase 3, rollout

    pipeline integration across all affected products, central versioned storage, artefact signing.

  4. Phase 4, operation

    Dependency-Track or comparable platform, continuous CVE matching, VEX process, connection to vulnerability and reporting processes.

  5. Phase 5, supply chain and evidence

    demand and validate supplier SBOMs, CRA documentation per Annex VII, preparation for BSI and customer audits.

Sarah Richter

Your contact

Sarah Richter

Head of Information Security, Cyber Security

10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security

SBOM implementation is the key to transparent and secure supply chains in the Cyber Resilience Act. Our clients benefit from strategic SBOM approaches that not only ensure compliance but also create operational excellence through improved transparency, proactive vulnerability management, and trustworthy partnerships along the entire value chain.

Our SBOM Expertise

  • 01Comprehensive experience in strategic SBOM implementation
  • 02Proven methods for automated SBOM generation
  • 03Integrated supply chain security and vulnerability management
  • 04Long-term partnership for SBOM excellence and CRA compliance

SBOM Strategy Note

Successful SBOM implementation requires a comprehensive consideration of technology, processes, and partnerships. Automation and continuous improvement are crucial for sustainable supply chain security and CRA compliance.

8 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about SBOM (Software Bill of Materials)

What is an SBOM (Software Bill of Materials)?

An SBOM is a machine-readable inventory of all components in a piece of software: in-house modules, open-source libraries, purchased components and their dependencies, each with version, licence and origin. It makes the software supply chain transparent and answers within minutes which products contain a vulnerable component. Common formats are CycloneDX and SPDX.

Is an SBOM mandatory under the Cyber Resilience Act?

Yes. The CRA (Regulation (EU) 2024/2847) requires manufacturers to document product components, at least the top-level dependencies, as an SBOM and to present it to market surveillance authorities on request. In Germany the BSI is responsible; Technical Guideline TR‑03183‑2 specifies the requirements. Reporting obligations for actively exploited vulnerabilities apply from 11 September 2026, full CRA applicability from 11 December 2027.

What is the difference between CycloneDX and SPDX?

CycloneDX originates from the OWASP community and is designed for security use cases: vulnerability matching, VEX integration, DevSecOps toolchains. SPDX comes from the Linux Foundation, is standardised as ISO/IEC 5962 and historically strong in licence compliance. Both are machine-readable and accepted by the BSI. In practice the ecosystem decides: Dependency-Track and security tooling favour CycloneDX; licence management favours SPDX. Many tools export both.

What must an SBOM contain?

The NTIA Minimum Elements are the established baseline: component name, version, supplier, unique identifiers (such as purl or CPE), dependency relationships, SBOM author and timestamp. BSI TR‑03183‑2 adds licence information and hashes among others. Unique component identification is critical; without it, automated matching against vulnerability databases fails.

Which tools generate SBOMs?

Established open-source tools are Syft (Anchore) and Trivy (Aqua Security); both produce CycloneDX and SPDX from source code, artefacts and container images. Microsoft provides the SBOM Tool, GitLab and GitHub generate SBOMs directly in the pipeline. For management and CVE matching, Dependency-Track (OWASP) is the de-facto standard. Tooling is rarely the bottleneck; automated generation on every release is.

What is VEX and how does it complement the SBOM?

VEX (Vulnerability Exploitability eXchange) is the SBOM's counterpart: a machine-readable manufacturer statement on whether a product is actually affected by a known vulnerability. Without VEX, SBOM matching against CVE databases produces many false alarms, because a contained component is not automatically exploitable. With VEX you document 'not affected' with reasoning and focus remediation on real risk.

Do containers and firmware need SBOMs too?

Yes. Container images are the most common use case: tools like Syft and Trivy scan images including OS packages. Firmware and embedded systems are more demanding (binary analysis, Yocto and Buildroot integration), but that is exactly where the CRA applies, since products with digital elements are in scope. Manufacturers of connected devices should start early.

How do SBOM and vulnerability management connect?

The SBOM is the inventory foundation of vulnerability management for software components: continuous matching against CVE feeds shows which products are affected by new vulnerabilities, VEX assesses actual exploitability, and remediation runs through your patch and release processes. The CRA requires exactly this chain, including reporting actively exploited vulnerabilities to ENISA within 24 hours from 11 September 2026.

Certificates, partners and more

ISO 9001 CertifiedISO 27001 CertifiedISO 14001 CertifiedBeyondTrust PartnerBVMW Bundesverband MitgliedMitigant PartnerGoogle PartnerTop 100 InnovatorMicrosoft AzureAmazon Web Services

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