How to Respond When Your Customers Require an SBOM (and Even Write It Into the Contract!)

Your sales team just got off a call with a major prospect. The customer is asking for an SBOM—a software bill of materials—and they want it written directly into the contract. The request is escalated to the executive team and from there directly into your inbox. Maybe it’s a government agency responding to new federal mandates, a highly regulated enterprise implementing board-level security requirements, or a large EU-based SaaS buyer preparing for upcoming regulatory changes.

Suddenly, a deal that seemed straightforward now hinges on your ability to deliver comprehensive software supply chain transparency. If this scenario sounds familiar, you’re definitely not alone. SBOM requirements are increasing across industries, fueled by new regulations like the US Executive Order 14028 and the EU Cyber Resilience Act. For most software vendors, this represents entirely new territory where the stakes—revenue, reputation, and customer trust—are very real.

This development isn’t entirely negative news, however. Organizations that proactively build robust SBOM capabilities are discovering they’re not just avoiding lost deals—they’re actually building a significant competitive advantage. Early adopters consistently report faster sales cycles with security-conscious prospects and access to previously unreachable government contracts that require supply chain transparency. 

Don’t believe me? I’ve brought the receipts:

We’re seeing a lot of traction with data warehousing use-cases. Security is absolutely critical for these environments. Being able to bring an SBOM to the conversation at the very beginning completely changes the conversation and allows CISOs to say, ‘let’s give this a go’.

—CEO, API Management Vendor

>> Read whole customer case study here >>

This blog post will walk you through the critical steps needed to meet customer SBOM demands effectively, help you avoid costly implementation mistakes, and even show you how to turn compliance requirements into genuine business advantages.

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5-Minute Decision Framework: Are SBOMs Urgent for Your Organization?

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Why Customers Are Demanding SBOMs—And What That Means For You

SBOMs aren’t a passing trend. In fact, the regulatory pressure from governments around the world are steadily driving SBOM adoption outside of the public sector. These new regulations have forced vendors, especially those selling to the US government and in the EU, to scrutinize what’s in the software.

• US Government: EO 14028 requires federal agencies to collect SBOMs from vendors
• EU Enterprises: The EU Cyber Resilience Act (CRA) requires an SBOM for any enterprise that sells “products with software components” in the EU market
  • BUT won’t be fully enforced until December 2027—you still have time to get ahead of this one!
• Highly regulated industries: Meaning defense (continuous ATO), healthcare (FDA approval) and finance (DORA, PCI DSS 4.0) all require SBOMs

But what are your customers really after? Most are looking for:

• A clear, standardized inventory of what’s in your software (open source, third-party, proprietary)
• Evidence you’re proactively remediating supply chain vulnerabilities
• A baseline for risk assessment and future incident response

Some customers will have strict formats or frequent asks; others are just “checking the box.” It’s important to clarify what’s really required.

Decoding the Request for an SBOM: What’s Actually Required?

When a customer asks for an SBOM, don’t assume you know what they want. Here’s how to get clarity:

Ask these questions

• Format: Do you require SPDX, CycloneDX, or will any standard SBOM format do?
• Update Frequency: Is a one-time SBOM sufficient, or do you require continuous updates with every new release?
  • NOTE: If your customer is FedRAMP authorized or a US federal agency (including DoD) continuous monitoring (ConMon) is required
• Depth: Do you want only direct dependencies, or transitive (all sub-dependencies) as well?
• Delivery: How do you want to receive the SBOM—portal, API, email, physical media?

Minimum requirements

Most regulated buyers accept SPDX or CycloneDX formats as long as they meet the NTIA’s Minimum Elements. One SBOM per major release is typical, unless otherwise specified.

Red Flags

• Unreasonably frequent update requests (e.g., “every nightly build”)
• Requests for highly granular or proprietary information you can’t legally or safely disclose

Contract language examples

• “Vendor shall provide an SBOM in SPDX or CycloneDX format at product release.”
• “Vendor will update the SBOM within 30 days of any significant component change.”

Key Risks and Negotiation Tactics

The biggest risk? Overcommitting—contractually agreeing to deliver what you can’t. 

Contract negotiations around SBOM requirements present unique challenges that combine technical complexity with significant business risk. Understanding common problematic language and developing protective strategies prevents overcommitment and reduces legal exposure.

Here’s how to stay safe:

Risks

• Operational: You lack fully instrumented software development pipeline with integrated SBOM generation and can’t meet the update frequency as promised.
• Legal: You don’t have complete supply chain transparency and risk exposing proprietary or third-party code you’re not allowed to disclose.
• Reputational: Missing deadlines or failing to deliver undermines customer trust.

Red flags in contracts

1. Unlimited liability clauses for SBOM accuracy 

• 100% accurate SBOMs create impossible standards—no automated tool achieves this level of accuracy, and manual verification is prohibitively expensive

2. Penalty clauses for incomplete or inaccurate SBOMs

• You should be able to remediate mistakes in a reasonable timeframe

3. Real-time or continuous SBOM update requirements ignoring practical development and release cycles
4. Requirements for complete proprietary component disclosure 

• May violate third-party licensing agreements or expose competitive advantages

5. No provision for IP protection

• If you’re increasing their supply chain transparency they need to reciprocate and protect your interests

6. Vague standards (“must provide industry best-practice SBOMs” without specifics)

How to negotiate

Push back on frequency: 

“We can provide an updated SBOM at each major release, but not with every build.”

Standard delivery timelines should align with existing release cycles—quarterly updates for stable enterprise software, per-release delivery for rapidly evolving products.

Don’t roll over on accuracy:

“We can generate SBOMs automatically as part of our normal software development process, provide reasonable manual validation and correct any identified issues.”

Reasonable accuracy standards acknowledge tool limitations while demonstrating good faith effort.

Protect sensitive info: 

“SBOM details do not extend to proprietary components or components protected by confidentiality.”

Redact or omit sensitive components, and communicate this upfront.

Quick-Start: Fast Path to SBOM Compliance (for Resource-Constrained Teams)

You don’t need to boil the ocean. Here’s how to get started—fast:

First Five Moves

1. Clarify the ask: Use the questions above to pin down what’s really required.
2. Inventory your software: Identify what you build, ship, and what major dependencies you include.
3. Choose your tooling:

• For modern apps, consider open source tools (e.g., Syft) or commercial platforms (e.g., Anchore SBOM).
• For legacy systems, some manual curation may be needed.

4. Assign ownership: Clearly define who in engineering, security, or compliance is responsible.
5. Pilot a single SBOM: Run a proof of concept for one release, review, and iterate.

Pro tips:

• Automate where possible (integrate SBOM tools into CI/CD).
• Don’t over-engineer for the first ask—start with what you can support.

Handling legacy/complex systems:

Sometimes, a partial or high-level SBOM is enough. Communicate limitations honestly and document your rationale.

Efficient Operationalization: Making SBOMs Work in Your Workflow

When you’re ready to operationalize your SBOM initiative, there are four important topics to consider:

1. Automate SBOM creation:
   Integrate tools into your build pipeline; trigger SBOM creation with each release.
2. SBOM management:
   Store SBOMs in a central repository for easy search and analysis.
3. Version and change management:
   Update SBOMs when major dependencies or components change.
4. Delivery methods:
   • Secure portal
   • Customer-specific API
   • Encrypted email attachment

This is also a good time to consider the build vs buy question. There are commercial options to solve this challenge if building a homegrown system would be a distraction to your company’s core mission.

Turning Compliance into Opportunity

SBOMs aren’t just a checkbox—they can help your business:

• Win deals faster: “Having a ready SBOM helped us close with a major public sector buyer ahead of a competitor.”
• Shorten security reviews: Automated SBOM delivery means less back-and-forth during customer due diligence.
• Build trust: Demonstrate proactive risk management and transparency.

Consider featuring your SBOM readiness as a differentiator in sales and marketing materials.

SBOM Readiness Checklist

::Checklist::

Have we clarified the customer’s actual SBOM requirements?

✅: Continue

❌: Send request back to customer account team with SBOM requirements

Do we know which SBOM format(s) are acceptable?

✅: Continue

❌: Send request back to customer account team with SBOM requirements

Have we inventoried all shipped software and dependencies?

✅: Continue

❌: Send to engineering to build a software supply chain inventory

Have we selected and tested an SBOM generation tool?

✅: Continue

❌: Send to engineering to select and integrate an SBOM generation tool into CI/CD pipeline

Do we have clear roles for SBOM creation, review, and delivery?

✅: Continue

❌: Work with legal, compliance, security and engineering to document SBOM workflow

Are our contractual obligations documented and achievable?

✅: Continue

❌: Work to legal to clarify and document obligations

Do we have a process for handling sensitive or proprietary code?

✅: You’re all good

❌: Work with engineering and security to identify sensitive or proprietary information and develop a redaction process

Conclusion: From Reactive to Strategic

SBOM requirements are here to stay—but meeting them doesn’t have to be painful or risky.

The most forward-thinking organizations are transforming SBOM compliance from a burden into a strategic advantage. By proactively developing robust SBOM capabilities, you’re not just checking a box—you’re positioning your company as a market leader in security maturity and transparency. As security expectations rise across all sectors, your investment in SBOM readiness can become a key differentiator, driving higher contract values and protecting your business against less-prepared competitors.

Ready to take the first step?