Thoughts on ENISA's New SBOM Implementation Guide 🤔

2026-01-05

Jason Smith

I’ve been diving into the ENISA recent Call for Feedback on their SBOM Landscape Analysis: Towards an Implementation Guide.

It’s refreshing to see a guide that prioritizes practicality over just theoretical compliance. While earlier frameworks from CISA and NTIA were vital for setting the baseline and minimum requirements, ENISA is taking us further into the “how-to” for real-world environments, especially for resource-constrained organizations.

My top highlights:

1️⃣ Practical “How-to”: It provides structured implementation phases (Initiation, Planning, Execution, Monitoring & Controlling, and Closure) rather than just a list of required fields.

2️⃣ SBOM Signing is Front and Center: It treats cryptographic signing as a core requirement (and not optional) for establishing software provenance and integrity.

3️⃣ Built-in CI/CD Integration with Examples: Includes specific automation hooks for GitHub Actions and GitLab CI (using tools like Syft/Cosign) to ensure SBOMs are generated and signed at the “Build-Time” stage when they are most accurate.

4️⃣ Focus on Quality: Provides a clear Completeness Assessment Framework with specific “Minimum vs. Excellence” thresholds (for example, aiming for 95%+ transitive dependency visibility). It also introduces a three-layered validation approach (Structural, Content, and Semantic) to ensure the data is accurate, not just present.

5️⃣ The “Validation Gate”: Moves beyond just making an SBOM to verifying it before deployment to include automated checks for digital signature verification, hash consistency, and timestamp verification to ensure signatures are still valid at the time of deployment.

Supply chain security is a team sport, and this guide provides the playbook we’ve been waiting for.

A couple of additional tools to call out that it didn’t specifically include that I would recommend:

1️⃣ SBOM Signing: SecureSBOM from ShiftLeftCyber 🔗 https://shiftleftcyber.io/securesbom/

2️⃣ SBOM Quality: sbomqs from Interlynk 🔗 https://github.com/interlynk-io/sbomqs

Check out the draft and share your feedback with ENISA by January 23!

🔗 https://www.enisa.europa.eu/news/call-for-feedback-advancing-software-supply-chain-security-together

#SBOM #SupplyChainSecurity #CyberSecurity #ENISA #SecureSBOM #CyberResilienceAct #CRA #DevSecOps #SupplyChainIntegrity #SoftwareProvenance

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