Vendors handle SBOM requests at scale by making the SBOM a build artifact: generate one per release in a standard format, sign it, store it, and let customers fetch it through a controlled channel. Ad hoc spreadsheets and one-off exports are what break at the tenth customer.
Why do requests multiply?
Each customer writes its own questionnaire or contract clause. Some federal agencies may ask for an SBOM on request. OMB memo M-26-05 says agencies may choose contract terms requiring a producer to provide a current SBOM upon request, and for cloud platforms, an SBOM of the runtime production environment. The memo text leaves that to each agency, so asks differ by agency and by contract. Read your own contract for what applies to you.
Outside government, enterprise buyers and the EU's Cyber Resilience Act are pushing the same direction, and the same pipeline serves them all.
What should the pipeline produce?
The 2026 minimum elements give a checklist. Beyond component fields they ask for:
- an SBOM per release, regenerated whenever a build or correction changes the data (Frequency);
- coverage of all components including transitive dependencies, with no minimum depth;
- explicit marking of unknown or withheld information;
- a data format that is open, machine-processable and not deprecated, with SPDX and CycloneDX named as widely used;
- a digital signature attributable to the SBOM author;
- delivery that is prompt, through a version-specific URL, an API, a repository or alongside installation.
None of this is possible by hand across dozens of products.
How do you scale it?
Generate in CI, not on request. The SBOM is written beside the build and stored by product and version. Sign it with your existing signing infrastructure. Publish it behind access control that does not block authorized customers.
Then separate the data from the questions. Most customer questions are queries: does version 4.2 contain library X? Which products are affected by this CVE? If the SBOMs live in one searchable store, support answers in minutes and does not open each file.
Add exploitability. The same CISA document notes that advisories such as VEX and CSAF let producers say a component is vulnerable, under investigation or not affected, which saves customers wasted effort.
What does this look like in practice?
Constructed example: a vendor sells three products and has forty enterprise customers. Before, each request took a developer half a day. After the change, every release publishes a CycloneDX file and signature to a portal. Customers with API access poll it. A new library CVE arrives and the vendor's security team runs one query across all three products, publishes a VEX statement for two of them marking the flaw not affected, and notifies only the customers on the third.
What breaks first as you grow?
Usually ownership and quality. Generation works on the first three products and fails on the fourth because it uses a build system nobody planned for. Customers then receive SBOMs with missing versions or empty license fields, and trust drops.
Catch this with automated checks in the pipeline: fail the build if the SBOM lacks component versions, hashes or a timestamp, and track the share of components with unknown fields over time. The 2026 guidance says errors from author practices or inadequate tools may be considered in a customer's risk decisions, so quality is a commercial matter too, not only a technical one.
What to do
- Choose one primary format and offer a second on request.
- Generate an SBOM in CI for every release and store it by product and version.
- Sign it and record the tool name and version.
- Build a delivery channel: portal, API or per release download, with access control.
- Index the SBOMs so you can search by component across products.
- Publish VEX or advisory statements when a new CVE is announced.
- Record the unknowns instead of leaving them out.
Safeguard's SBOM and dependency scanning and compliance automation features support the generation and inventory steps. Signing, portals and customer communications remain your process.
Quick check
Is one SBOM per product enough?
No. The guidance expects an SBOM for each version or update, since components change between releases.
Do we have to publish SBOMs publicly?
Not necessarily. Guidance allows access control as long as authorized parties are not blocked. What you owe depends on contracts and law.
Sources
- OMB M-26-05, Adopting a Risk-based Approach to Software and Hardware Security (23 January 2026)
- CISA, 2026 Minimum Elements for a Software Bill of Materials (SBOM)
- European Commission, Cyber Resilience Act
Last reviewed: 18 October 2026.
