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Introduction: Why SBOMs Still Divide the Security World
Software Bill of Materials, better known as SBOMs, were once hailed as the missing link in software supply-chain security. They promised transparency, traceability, and a way to finally understand what truly lives inside modern applications. As 2026 approaches, that promise remains alive, but heavily contested. Across the cybersecurity industry, SBOMs inspire enthusiasm, skepticism, and a growing sense of fatigue. In theory, they are elegant and necessary. In practice, they are often incomplete, inaccurate, or misunderstood. The gap between concept and execution has become impossible to ignore.
The State of SBOM Adoption in a Rapidly Changing Ecosystem
SBOMs were designed to answer a simple question: what software components are actually present in a product? Yet modern software ecosystems are anything but simple. Applications now depend on sprawling open-source libraries, dynamic build pipelines, containerized environments, and continuous deployment models. Keeping an accurate, end-to-end inventory of all components has proven far more difficult than early advocates anticipated.
Some companies have leaned fully into SBOMs as a security foundation. Docker stands out as a prominent example, embedding complete SBOMs into its Hardened Images and pairing them with strong provenance guarantees through SLSA Level 3. These images are intentionally minimal, stripping away unnecessary artifacts and offering clearer insight into what is actually shipped. The idea is straightforward: fewer components, better visibility, and stronger trust in the build process.
Despite these efforts, many organizations struggle to replicate this model. Even companies with mature development practices often generate SBOMs that are partial or outdated. A major obstacle lies upstream. Numerous open-source projects still do not publish SBOMs for their own software, forcing downstream users to guess, infer, or manually reconstruct dependency data.
Regulation Pushes Forward, Confidence Lags Behind
Governments have played a decisive role in accelerating SBOM adoption. In the United States, Executive Order 14028 positioned SBOMs as a requirement for critical software procurement. In Europe, the Cyber Resilience Act went further, mandating standardized, machine-readable SBOMs throughout the software lifecycle. Standards bodies and agencies such as CISA reinforced this direction by requiring formats like SPDX and CycloneDX to enable automation.
Yet regulation has not translated into universal confidence. For many security professionals, SBOMs feel more like compliance artifacts than operational tools. The question has shifted. Organizations no longer ask whether a vendor can provide an SBOM. They ask whether that SBOM is accurate, timely, and useful for real risk decisions.
Accuracy, Context, and the Timing Problem
One of the most persistent criticisms of SBOMs is when and how they are created. In many cases, SBOMs are generated at the very end of the build process. By then, critical context has already been lost. Components may have been optimized away, statically linked, or altered during compilation. The resulting manifest reflects what should exist, not necessarily what does.
This issue is especially pronounced in embedded and compiled software. These environments often blend open-source, proprietary, and third-party components in ways that automated tools struggle to detect. As a result, teams resort to manual processes that are slow, error-prone, and difficult to maintain at scale.
Security leaders increasingly acknowledge a hard truth: an SBOM alone does not reduce risk. Without accuracy and context, it becomes a static document disconnected from real-world vulnerabilities and exploit paths.
When Transparency Creates a False Sense of Security
Another emerging concern is overreliance on SBOMs as a single source of truth. If the build system itself is compromised, the SBOM generated by that system cannot be fully trusted. This paradox has led some experts to argue that independent software composition analysis tools, even if imperfect, may provide a healthier counterbalance. At least they observe the final artifact from the outside, rather than trusting the same pipeline that produced it.
This tension highlights a deeper issue. SBOMs were never meant to replace other security controls. Yet in some organizations, they have become a checkbox that distracts from securing build infrastructure, access controls, and developer workflows.
Beyond SBOMs: Provenance, SLSA, and the Next Layer of Trust
As enthusiasm for SBOMs becomes more measured, attention is shifting toward complementary frameworks. Supply-chain Levels for Software Artifacts, or SLSA, has gained traction as a way to harden build systems themselves. Rather than focusing solely on what components exist, SLSA emphasizes how software is built, who touched it, and whether those steps can be verified.
The Linux Foundation’s release of SLSA 1.2 reflects this evolution. By separating build and source provenance into distinct tracks, the framework offers more granular visibility into how binaries and source code move through the pipeline. For many teams, this approach feels more actionable than static inventories.
The Concept Expands: From Software to AI Bills of Materials
The idea of ingredient transparency is now extending into artificial intelligence. As AI models become integral to software products, organizations are experimenting with AI Bills of Materials. These documents aim to capture training datasets, model versions, algorithms, dependencies, and governance processes.
Unlike traditional software, AI systems evolve continuously. Small changes in data, parameters, or dependencies can introduce new risks overnight. AI BOMs are emerging as an attempt to bring the same accountability to machine learning that SBOMs promised for software, though they face similar challenges around accuracy, tooling, and standardization.
What Undercode Say:
SBOMs are not failing because the idea is flawed. They are struggling because the industry treated them as a destination instead of an instrument. Transparency without trust, context, and enforcement becomes paperwork. The core mistake was assuming that listing components would automatically translate into better security outcomes.
In reality, SBOMs are only valuable when they are deeply integrated into development and security workflows. They must be generated continuously, validated independently, and tied directly to vulnerability intelligence and remediation processes. Anything less turns them into static snapshots of a moving target.
The regulatory push was necessary, but it came too early in the tooling lifecycle. Many teams are being asked to comply before they have the skills, automation, or upstream cooperation required to do it well. This explains the frustration and ambivalence seen across the industry.
The more promising path forward is convergence. SBOMs should coexist with SLSA, hardened build pipelines, reproducible builds, and external verification. Together, these layers create a system of checks and balances that no single artifact can provide.
Looking ahead, AI BOMs will likely repeat the same cycle. Early enthusiasm, rushed mandates, uneven tooling, and eventual recalibration. The lesson from SBOMs is clear: visibility must be paired with integrity, and documentation must be backed by verifiable process. Otherwise, transparency becomes an illusion rather than a defense.
Fact Checker Results
SBOM mandates in the US and EU are accurately represented and verifiable. ✅
Industry criticism around SBOM accuracy and timing reflects documented expert consensus. ✅
Claims about AI BOMs align with current security research and vendor guidance. ✅
Prediction
SBOMs will survive 2026, but as supporting actors, not leading heroes. 🔍
SLSA adoption and build-system hardening will outpace standalone SBOM initiatives. 📈
AI Bills of Materials will face early resistance before becoming a regulated expectation. 🤖
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