CISA Solicits Feedback on Finer Points of Coming Software Transparency Requirement

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The agency has identified four topics—including considerations for cloud and online applications—it wants to hear more about from stakeholders. 

Over five days in July, the Cybersecurity and Infrastructure Security Agency will hold a series of listening sessions to increase visibility across the federal enterprise—a core tenet of an executive order to improve the nation’s cybersecurity—through the use of a Software Bill of Materials, or SBOM. 

“E.O. 14028 defines SBOM as, ‘a formal record containing the details and supply chain relationships of various components used in building software,’” CISA explained in a notice published in the Federal Register Wednesday. “The E.O. further notes that ‘[s]oftware developers and vendors often create products by assembling existing open source and commercial software components. The SBOM enumerates these components in a product.’”

As noted by a backgrounder produced by the House Science Committee in advance of a recent hearing on the issue, “Modern software products depend on a vast number of components from different developers, code repositories, and other sources. Suppliers of software components also use different naming schemes for the same components. As a result, identifying which vulnerabilities compromise which products can be a challenging technical feat. SBOMs may be able to address this challenge by creating a machine-readable inventory that will enable software developers and users to track software components and dependencies and make responding to vulnerabilities in the event of an incident more straightforward.”

“However,” the committee wrote, “as the Investigations and Oversight Subcommittee heard during its hearing on Supply Chain Security in May 2021, questions remain about the effectiveness of SBOMs as well as the ability of organizations to adopt them.”

Under Executive Order 14028, prospective vendors must provide agencies with the minimum elements of an SBOM, the use of which is one part of a larger collection of practices—including the use of multifactor authentication and similar security measures in development environments—the administration wants agencies to consider when purchasing software.

The notice said the agency “will not request specific outputs from meeting participants, nor is it currently CISA’s intent to use information shared during listening sessions to directly address or inform any federal policy decision.” 

Federal Chief Information Security Officer Chris DeRusha recently told Nextgov the Office of Management and Budget, the National Institute of Standards and Technology and CISA have already submitted their recommendations to the Federal Acquisition Regulatory Council on procurement laws for software, per the executive order.  

CISA said it is holding the sessions, “recognizing the importance of SBOMs in transparency and security, and that SBOM evolution and refinement should come from the community to maximize efficacy.” They “are intended to advance the software and security communities’ understanding of SBOM creation, use and implementation across the broader technology ecosystem.”

The agency welcomes additional ideas but is specifically interested in hearing about four topics: cloud and online applications, sharing and exchanging SBOMs, tools and implementation and onramps and adoption.

On the first of those, CISA said, “much existing discussion around SBOM, particularly around SBOM use cases, has focused on on-premise software. Cloud and Software-as-a-Service (SaaS)-based software comprises a large and growing segment of the software ecosystem. Potential sub-topics may include: How should the community think about SBOM in the context of online applications and modern infrastructure? How can the community integrate SBOM work into emerging cloud-native opportunities?”

The other topics will solicit discussion to guide the most effective standardization of SBOMs in federal procurement. The listening sessions will be held virtually, with connection and dial-in information available on CISA’s SBOM page.