Five shifts are already visible: inventories become machine-readable and exchanged, build provenance becomes normal, buyers move from one-size forms to risk-based asks, AI components join the bill of materials, and software agents become identities to manage. None is a prediction about a date. Each has a document behind it.
Shift one: inventories get exchanged and compared
CISA's SBOM page now lists a 2026 update to the minimum elements for an SBOM, building on NTIA's 2021 work, plus guidance on sharing, VEX and SaaS transparency. The direction is machine-readable data that tools can compare, not a PDF attached to an email.
Expect customers to ask for your SBOM the way they ask for a pen test summary today.
Shift two: provenance moves from nice to normal
SLSA's levels describe a route from "provenance exists" to hosted, signed, tamper-resistant builds. in-toto is a CNCF graduated project for recording which steps were performed, by whom and in what order. The March 2026 axios compromise, through a hijacked maintainer account, is the kind of case where such evidence helps if the project normally publishes it.
Shift three: buying becomes risk-based
OMB M-26-05 says there is no one-size-fits-all method and tells agencies to match assurance to risk. In the EU, the Cyber Resilience Act sets reporting obligations from 11 September 2026 and main obligations from 11 December 2027. Both push vendors toward being able to show practice rather than fill a form once.
Shift four: AI joins the bill of materials
CycloneDX already lists machine learning BOMs among its capabilities, and the AI Act's timeline continues into 2027 and 2028 for high-risk systems. Models, datasets and prompts will be tracked as components. The LiteLLM compromise in March 2026 was a reminder that AI tooling sits on the same package registries as everything else.
Shift five: agents become identities
NIST's NCCoE released a concept paper on February 5, 2026 on identity and authorization for software and AI agents, proposing to treat agents as identifiable entities. The OWASP Top 10 for Agentic Applications, from December 2025, lists identity and privilege abuse and agentic supply chain issues as distinct risks.
What stays the same?
People and process. The 3CX and xz cases both turned on trust in a person or a vendor. Reviewing changes, limiting privilege and knowing what you run will matter in 2030 as much as now.
A constructed example
A procurement analyst in 2027 opens a vendor package. It holds an SBOM and a VEX file in machine-readable form, signed build provenance for the latest release, and a list of the vendor's AI components and the identities its agents use. Her tooling compares the SBOM against yesterday's advisories and flags one component. The VEX says not affected, with a reason. She approves in minutes.
How to check or apply this
- Automate SBOM generation and keep one per release.
- Publish VEX statements when you decide a flaw does not affect a product.
- Move builds to hosted, ephemeral systems that can sign provenance.
- Add models, datasets and agent tools to your inventory.
- Give each agent its own identity and scope.
- Build one evidence pack that can answer many buyers.
- Revisit this list yearly. Documents here change often.
Safeguard offers SBOM and dependency scanning, policies and gates, and agent identity controls that line up with several of these shifts.
What could change these shifts?
Policy moves fast. OMB rescinded two memos in 2026, and the EU shifted AI Act dates. Standards also evolve: CISA's minimum elements were revised within a year of the draft. Treat each shift as a direction, plan for flexibility, and avoid building a program around any single memo or deadline.
Quick check
Will SBOMs become mandatory everywhere?
No one can say. Today they are contract- and agency-dependent in the US, and guidance such as CISA's minimum elements describes what can be supplied and requested.
What is the cheapest first step?
Generate an SBOM from your build for every release and store it. Almost every other shift builds on that data.
Sources
- CISA, Software Bill of Materials
- SLSA, Build track levels
- in-toto
- OMB M-26-05 (PDF)
- European Commission, Cyber Resilience Act
- European Commission, AI Act
- CycloneDX, Capabilities
- NIST NCCoE, Software and AI Agent Identity and Authorization
- OWASP GenAI Security Project, Top 10 for Agentic Applications
Last reviewed: 18 October 2026.
