Summary and Background

This is the second installment in the Care and Feeding of SBOMs series. The inaugural article, SBOM Adoption at Scale: Burden or Opportunity?, introduced the role and impact that Software Bill of Materials (SBOMs) play across development, enterprise, and regulatory application stakeholders. For a more literal SBOM definition, check out SBOM 101: What is an SBOM?.   

This article explores how SBOM generation can be scaled across development teams and environments. We discuss which roles benefit from SBOM generation, which tooling and formats are worth considering, and how to overcome operational challenges. 

Intro

SBOMs have become a critical component of modern software supply chain security. High-profile breaches like SolarWinds and Log4j have revealed the need for detailed visibility into software dependencies. An SBOM provides this visibility by creating a detailed software inventory, enabling organizations to understand what’s inside their software and respond quickly to vulnerabilities.

What do we mean by “scale” in the context of “building SBOMs at scale?” Scale is the ability to generate accurate SBOMs automatically and consistently across an unbounded number of applications, environments, teams, and releases without manual bottlenecks or performance degradation. For development teams focused on functional requirements, the goal is to make SBOM generation a seamless background task – ideally a “lights out” process requiring minimal active management, allowing them to concentrate on core feature delivery.

This article will:

• Identify key stakeholders who benefit from scalable SBOM generation
• Outline practical steps for automating and scaling SBOM creation
• Call out essential tooling capabilities and format options
• Offer practices shown to be effective in overcoming technical and organizational challenges

Who Needs Scalable SBOM Generation?

Organizations that rely upon the reliability and transparency of the software they produce cannot afford to jeopardize the quality or trust in their work “in the last mile” of delivery. Scalable SBOM generation speeds delivery, eliminates human error, and guarantees package transparency and accuracy. 

DevOps and CI/CD Teams

Integrating scalable SBOM generation tooling into CI/CD pipelines provides DevOps teams assurance and transparency by automatically creating real-time software inventories. Automating the creation and validation process is fundamental to achieving a “lights out operation,” minimizing developer interaction by requiring attention only for critical alerts like errors or policy violations. Moreover, this automation drives consistent quality; applying the same rules and tools systematically for every build eliminates manual variability and ensures the accuracy of the generated software inventories, leading to more reliable compliance and security postures.

Software Vendors and SaaS Providers

Offering SBOMs as part of a security package builds customer trust and streamlines audits. For highly regulated industries, third-party software package SBOMs are more than a “nice to have.” Increasingly, regulators are requiring new applications to include SBOMs (examples include the Food and Drug Omnibus Reform Act of 2022 (FDORA) and the EU Cyber Resilience Act). Scalable SBOM generation increases market confidence, simplifies auditing, shortens time-to-market, and increases competitive advantage. 

Open-Source Software (OSS) Project Owners

Publishing SBOMs alongside releases enhances transparency, builds trust with users, and can increase enterprise adoption by lowering perceived risks. Beyond transparency, automating SBOM creation and publication reduces maintainer workload, especially when new vulnerabilities are announced. By automatically generating and publishing up-to-date SBOMs to accessible public locations—such as the project’s website, artifact repository, or even public SBOM databases—maintainers enable downstream users to self-serve. Consumers can quickly check the published software inventory to determine if their specific version is affected by a new vulnerability, rather than overwhelming maintainers with individual support requests and inquiries. Scalable SBOM integration into OSS builds reduces risk and ensures consistency across diverse and distributed development efforts. 

Managed Service Providers (MSPs)

MSPs manage diverse environments. Scalable SBOM tooling enables them to support client compliance across a wide range of stacks and technologies. 

Scalable SBOM Generation: Key Steps

1. Choose a Standard Format

• SPDX (Software Package Data Exchange)
  • Why? It’s a comprehensive, widely adopted ISO/IEC standard (ISO/IEC 5962:2021), particularly strong in open-source communities.
  • Details: Excels at detailing component licenses, copyrights, and file-level provenance. Its breadth makes it robust for compliance and legal reviews, though it can sometimes be more verbose than other formats.
• CycloneDX
  • Why? It’s a lightweight standard from OWASP, specifically designed for security use cases and identifying supply chain risks.
  • Details: Focuses strongly on identifying known vulnerabilities associated with components. Its security-centric design and integration with many security tools make it popular for vulnerability management and risk assessment within CI/CD pipelines.
• SWID (Software Identification) Tags
  • Why? It’s an ISO standard (ISO/IEC 19770-2:2015) primarily suited for enterprise IT asset management and tracking installed software.
  • Details: Often used to create an inventory of software deployed on endpoints for lifecycle management and compliance. While valuable for asset tracking, it’s generally less common than SPDX or CycloneDX for embedding directly into development build pipelines for dependency tracking purposes.

Choose a format (or support multiple) based on your primary use cases (e.g., license compliance vs. vulnerability management vs. asset tracking), downstream tool compatibility, and specific customer or regulatory reporting requirements. Many modern tools support generating SBOMs in multiple formats like SPDX and CycloneDX.

2. Select Tools That Scale

Look for SBOM automation tools with the following features:

• Unlimited Usage Models: Avoid tools that limit scans or seats – this reduces friction and supports cross-team adoption.
• Deep Dependency Analysis: Tools should uncover transitive dependencies at depth (e.g., 10+ layers). 
• Typo-Squatting Detection: Identify deceptive packages that mimic legitimate names. 
• CI/CD Integrations: Support for GitHub Actions, GitLab, Jenkins, etc. 
• Cryptographic Attestation: SBOMs should be signed to verify authenticity (e.g., via Sigstore).
• Historical Archiving: Tools should store SBOMs for each build, enabling audits and incident response. 
• API and CLI Access: These facilitate integration into varied workflows and scripts for unexpected or niche scenarios.

When choosing a tooling strategy, it’s important to understand how SBOM data is generated. Most tools use one or more of the following methods:

Source Code Analysis (SCA)

• What it does: Parses manifest files (like package.json, pom.xml, or requirements.txt) and sometimes the source code itself.
• Strengths: Fast, language-aware, good for detecting declared dependencies.
• Limitations: May miss packages installed dynamically or introduced during the build process.

Build Process Integration

• What it does: Hooks into the build system (e.g., Maven, Gradle, npm) to detect dependencies as they are resolved.
• Strengths: Provides highly accurate SBOMs tied to real build outputs.
• Limitations: Requires access and control over the build process, which may not be possible in all environments.

Binary Analysis

• What it does: Inspects compiled artifacts like executables, libraries, or container images.
• Strengths: Can detect dependencies not declared in manifests (e.g., vendored, statically linked, or third-party components).
• Limitations: May struggle with obfuscated code or deeply optimized binaries.

Tip: The most comprehensive SBOM tools combine two or more of these methods to balance speed, accuracy, and completeness.

3. Integrate into CI/CD Pipelines

SBOMs should be treated as a build artifact. In practical terms:

• Add an SBOM generation step to your pipeline configuration (YAML or script-based).
• Add an SBOM validation step before deployment to ensure completeness.
• Store SBOMs with each release tag or container push.

Integrating SBOMs into DevSecOps workflows ensures security and compliance become continuous practices – not one-time checks. Again, the key objective for developers here is “lights out” automation. Once configured in the pipeline, SBOM generation and validation should execute seamlessly in the background. Alerts should only surface for critical issues (e.g., generation failures, high-severity vulnerabilities found, license policy violations), minimizing disruption to core development activities focused on building product features.

4. Validate and Attest

Generating an SBOM provides the necessary software inventory, but two further steps are crucial for making it truly useful: validation and providing context on findings, sometimes referred to as attestation.

Validation: This process confirms the SBOM itself is well-formed and complete according to the chosen standard’s specification (e.g., SPDX or CycloneDX schema). Validation checks ensure all required fields are present, data formats are correct, and the SBOM is structured properly. A valid SBOM is essential for reliable processing by downstream tools used for vulnerability scanning, license compliance checks, or other analyses.

Attestation (Vulnerability Exploitability Context): Beyond just listing components, providing attestation about the status of identified vulnerabilities adds important context. This involves analyzing if and how a vulnerability within a dependency actually affects your specific product. You might attest that your product is not_affected because the vulnerable_code_not_in_execute_path, or provide other justifications. Formats like VEX (Vulnerability Exploitability eXchange) are designed to convey this analysis alongside the SBOM, often including details like:

JSON

// Example VEX-like snippet showing vulnerability status

{

  “vulnerability_id”: “CVE-2023-1234”,

  “product_status”: “not_affected”,

  “justification”: “vulnerable_code_not_in_execute_path”,

  “action_statement”: “No remediation required as the vulnerability is not exploitable in this product.”,

  “component_purl”: “pkg:maven/org.apache.logging.log4j/log4j-core@2.14.1”

}

This type of attestation is invaluable for consumers of your SBOM (including your own internal teams). It helps prioritize remediation efforts on genuinely exploitable issues, significantly reduces alert fatigue caused by theoretical vulnerabilities, and provides auditable justification for risk acceptance decisions.

Integrating both structural Validation of the SBOM and contextual Attestation regarding vulnerability status makes the overall package significantly more actionable and trustworthy for managing software supply chain risk.

5. Store and Reuse

Store generated SBOMs in artifact registries (e.g., JFrog Artifactory) or SBOM repositories (e.g., SOOS SBOM Manager). These enable:

• Retrospective audits
• Regulatory submissions
• Real-time SBOM vulnerability tracking (using tools like DependencyTrack, OSS Index, or integrated solutions such as SOOS’s vulnerability and risk assessment dashboard).

Addressing Key Challenges

Incomplete Dependency Visibility

Problem: Many tools miss deeply nested or obfuscated dependencies. 

Solution: Use scanners that support deep-tree analysis and include peer-reviewed or curated vulnerability data. 

Tooling Fragmentation & Input Diversity

Problem: Organizations rarely use a single technology stack. Even small teams often work with multiple programming languages, package managers, and build processes. This results in a wide variety of input sources (e.g., different manifest file types like package.json, pom.xml, requirements.txt; source code; compiled binaries; container images) that SBOM generation tools need to accurately analyze. On top of this input diversity, different teams might adopt tools that produce incompatible SBOM output formats or lack consistent capabilities, making organization-wide analysis difficult.

Solution: Address both input and output challenges. Standardize on tooling that demonstrably supports the diverse range of languages, package ecosystems, and artifact types (source, binary, container) used within your organization. Simultaneously, ensure that the chosen tooling can consistently generate SBOMs in standardized output formats (like SPDX and CycloneDX) to facilitate uniform consumption and analysis by downstream security tools and compliance processes.

Pipeline Complexity

Problem: Introducing new steps for SBOM generation and validation can increase CI/CD pipeline complexity, potentially leading to delays or failures if not managed carefully.

Solution: Refine SBOM steps using declarative configurations and test changes thoroughly in non-production environments. Additionally, prioritize tools offering a powerful and flexible Command Line Interface (CLI). A robust CLI provides granular control, allowing teams to easily script specific actions—like triggering scans precisely when needed or exporting SBOMs in particular formats—and integrate them seamlessly into any CI/CD workflow, even highly customized or complex ones. This CLI flexibility significantly simplifies the setup and maintenance of SBOM tasks within the pipeline, making the “lights out” automation goal more achievable across diverse environments.

Organizational Buy-In

Problem: Gaining broad organizational buy-in requires addressing distinct stakeholder perspectives. Non-technical stakeholders (legal, product, sales) may not immediately grasp the operational importance or prioritize the effort involved. Simultaneously, technical teams, focused on delivering features, may resist SBOM generation as additional overhead not directly contributing to functional enhancements.

Solution: Tailor the value proposition to each group:

• For Non-Technical Stakeholders: Focus on the business drivers. Clearly communicate the benefits related to compliance, significant reduction in security and licensing risks, streamlined audits (saving time and effort), and increased customer trust which can be a competitive differentiator.
• For Technical Teams: While emphasizing that the goal is automated, low-friction, “lights out” integration is essential to minimize workflow disruption, also highlight the direct developer intelligence benefits gained from the process. The tooling required for generating SBOMs often provides valuable development insights as a side benefit, including:
  • Easier Troubleshooting & Faster Zero-Day Triage: Quickly pinpointing exact component versions during incidents.
  • Clear Dependency Visibility: Understanding library usage, versions, and introduction paths across projects.
  • Proactive Maintenance: Easily identifying components that need updates or are nearing end-of-life. Positioning SBOM generation not just as a compliance task but also as a source of practical development insights can significantly improve developer acceptance and adoption.

Resource Allocation and Cost

Problem: Implementing and maintaining SBOM generation at scale isn’t free. Costs include tooling (licenses or SaaS fees), initial implementation effort (integrating into pipelines, configuring tools), ongoing maintenance (updates, addressing tool findings), and potentially personnel time for training and managing the process.

Solution: Factor SBOM initiatives into budget planning. Evaluate tools based on total cost of ownership, including ease of integration and maintenance. Clearly articulate the return on investment (reduced security risk, improved compliance, faster audits, increased customer trust) to secure necessary resources and organizational buy-in.

Establishing Baselines for Deployed Equipment

Problem: For organizations producing physical equipment with embedded software (e.g., industrial controls, medical devices, automotive components), a major hurdle is establishing an accurate software inventory for devices already deployed in the field. Historically, meticulous records of exact software versions shipped with specific hardware units may not exist, and these devices might not be easily accessible for remote auditing or updates. This lack of historical data makes creating accurate baseline SBOMs for the existing deployed fleet incredibly challenging – you can’t easily generate an inventory for software you haven’t historically tracked or can’t readily access.

Solution: Addressing this requires a pragmatic, often resource-intensive approach. Strategies may include: conducting manual audits or firmware analysis on returned or accessible units where feasible, leveraging any existing partial deployment records or manufacturing data, potentially using representative sampling for risk assessment across legacy fleets, and accepting that complete historical accuracy might be unattainable for the oldest equipment. Critically, the focus must be on implementing rigorous SBOM generation and record-keeping processes for all new deployments and software updates moving forward to avoid perpetuating this visibility gap.

Best Practices for Scalable SBOM Generation

Knowledge Review: Common Questions About Scalable SBOM Generation

Q1: Why is automation essential?
A: Automation ensures accuracy, reduces manual effort, integrates into CI/CD pipelines for consistency, enables a low-touch ‘lights out’ approach for developers, and supports rapid vulnerability response.

Q2: What features should organizations prioritize in tools?
A: Look for tools with support for major SBOM formats, deep dependency visibility, CI/CD integrations via flexible CLI tooling, and cryptographic signing.

Q3: How does integrating SBOM generation into CI/CD benefit teams?
A: It ensures every build includes a validated SBOM, accelerates delivery cycles, reduces risk exposure, and supports audit readiness.

Q4: What role do SBOMs play in vulnerability remediation?
A: Acting as a detailed software inventory, SBOMs help teams quickly identify which components are affected by disclosed vulnerabilities and prioritize remediation efforts accordingly.

Takeaways

Scalable SBOM generation is no longer an aspirational goal – it’s a core requirement for secure software delivery and operational maturity. As regulations tighten and threat actors evolve, the ability to automatically generate, validate, and store SBOMs across every release isn’t just smart development; it’s becoming table stakes.

Organizations that implement robust, automated SBOM generation practices now will be better prepared not only to navigate compliance and reduce supply chain risk, but also to build essential customer trust. Furthermore, this capability provides tangible business advantages: it can streamline sales cycles by readily providing the software transparency increasingly demanded by enterprise customers, and significantly facilitate M&A due diligence by demonstrating operational maturity and offering clear visibility into software assets for potential investors or acquirers. Mature SBOM practices are rapidly becoming a key indicator of a well-governed, secure software organization.

Next up, we’ll explore how to ingest and manage SBOMs at scale, including version tracking, real-time vulnerability monitoring, and responding to new disclosures. Stay tuned!