EU Cyber Resilience Act: How SBOMs Move From ‘Nice-to-Have’ to Must-Have by 2027

Imagine waking up to a €15 million fine simply because you overlooked an obscure software documentation detail. Sounds dramatic? Welcome to the EU's newly adopted Cyber Resilience Act (CRA), the law transforming Software Bills of Materials (SBOMs) from a mere compliance recommendation to a critical regulatory requirement by 2027.

When SBOMs took center stage in the CRA

In April 2025, the European Union formally adopted the Cyber Resilience Act, dramatically shifting security obligations onto digital product providers. Companies now face stringent obligations, mandating detailed SBOMs to ensure software transparency and resilience. Neglect this requirement, and companies risk severe financial penalties, up to €15 million or 2.5% of global annual revenue, whichever is higher.

Remember the infamous smart-lock recall incident of mid-2024? A routine security flaw spiraled into an eight-week market freeze primarily because the vendor lacked a proper SBOM. Had a detailed SBOM been available, identifying the vulnerability and swiftly rectifying the issue would have been straightforward. This is exactly the scenario the CRA aims to prevent.

Key CRA requirements for SBOM compliance

Under CRA Article 10, companies must embrace "security-by-design," meticulously documenting software components. SBOMs must:

• Clearly list all software components and dependencies.
• Regularly update with security vulnerabilities (VEX documentation).
• Ensure availability upon customer request and regulatory audits.

Importantly, the CRA covers nearly all digital products but explicitly excludes certain defense and national security-related software. Additionally, small and medium businesses (SMBs), often unaware of these obligations, face considerable risks if they remain unprepared.

For specific, detailed guidelines, the Open-Source Security Foundation (OpenSSF) published essential "CRA-Ready" guidance in June 2025.

Competitive advantage of early CRA compliance

The CRA’s SBOM mandate isn't just a regulatory hurdle; it's a strategic opportunity. Organizations embracing early compliance enjoy considerable advantages:

• Enhanced trust and transparency: Build unparalleled confidence with customers and stakeholders by proactively demonstrating software integrity.
• Faster product approvals: Streamlined compliance processes translate into accelerated product launches and quicker market entry.
• Reduced risk exposure: Early identification and management of software vulnerabilities significantly decrease operational and financial risks.