Despite widespread regulatory mandates, 48% of security professionals admit their organizations are falling behind SBOM (Software Bill of Materials) requirements. The real crisis isn’t adoption rates—it’s compliance theater. Organizations are generating SBOMs as checkboxes for auditors while software supply chain attacks doubled in 2025, costing $60 billion globally. Most SBOMs are produced too late in the development lifecycle, fail to reflect what’s actually shipped, and provide zero runtime context. They’re expensive paperwork, not operational security tools.
Developers are caught in the middle: forced to generate SBOMs for compliance while lacking the tools and processes to make them useful. Meanwhile, 70% of organizations experienced supply chain attacks in 2025, and only 21% have complete dependency visibility. 2026 marks the turning point where the industry must shift from “SBOM as static document” to “SBOM as living operational artifact.”
SBOM Compliance Gap: 48% Falling Behind
The 48% compliance gap masks a deeper problem: organizations generating SBOMs aren’t using them. According to Dark Reading’s December 2025 analysis, “Most companies that are required to provide SBOMs are generating them as the last step in a build process, producing inaccurate SBOMs to check a compliance box.” This creates security theater—compliance documents that don’t improve security posture.
The barriers are stark. 69% cite lack of knowledge and expertise as the top obstacle, especially among developers forced to generate SBOMs without training. Only 21% of organizations have complete dependency visibility despite mandates. Furthermore, 80% view limited adoption as “the most fundamental concern,” and 54% believe organizations fall short on SBOM regeneration, treating them as static documents rather than living artifacts.
CISA Senior Advisor Allan Friedman captured the problem: “SBOM implementation presents a chicken and egg problem—no one was asking for it so no one was supplying it; no one was supplying it so no one was asking for it.” Regulatory mandates attempted to break this cycle, but compliance without operational integration just moved the problem downstream.
$60 Billion: The Cost of Supply Chain Attacks
Software supply chain attacks more than doubled in 2025, with 70% of organizations experiencing at least one incident. Cybersecurity Ventures projects global losses will hit $60 billion for 2025. Supply chain breaches now cost an average of $4.91 million ($10.22 million in the US), and remediation costs run 17 times higher than direct attacks.
The attack surge is quantifiable. From early 2024 through March 2025, supply chain attacks averaged around 13 per month. However, in April 2025, that number spiked to 31 attacks. Since then, attacks have averaged 26 per month—twice the earlier rate. Gartner forecasts that 45% of organizations will experience a supply chain breach by the end of 2025.
Real incidents paint the cost picture. SolarWinds affected 18,000+ organizations, costing victims an average of 11% of revenue. MOVEit Transfer compromised 620+ organizations, including the BBC and British Airways. Moreover, a 2025 ransomware attack on a Swedish HR software provider disrupted 200 municipalities, multiple regional administrations, and universities. SBOMs were supposed to prevent this. The fact that attacks doubled while organizations checked compliance boxes exposes the fundamental flaw.
Why SBOM Implementation Fails: Three Fatal Flaws
Current SBOM practices fail on three critical fronts. First, timing: organizations generate SBOMs at the final build step when it’s too late to capture build-time dependencies. An SBOM generated at release doesn’t reflect the development environment, transitive dependencies, or build artifacts that never make it to production but still pose risk.
Second, accuracy: “Many SBOMs today are generated too late in the life cycle, lack context about how components are actually used, or fail to reflect what’s truly shipped,” according to industry research. Existing SBOMs are riddled with inconsistencies, bugs, and incomplete data. Container base images get missed. Additionally, dynamically loaded libraries don’t appear in build-time scans. The “naming problem”—multiple versions tracked using numerous syntax forms—makes comprehensive tracking nearly impossible.
Third, staleness: 54% believe organizations fall short on regeneration. An SBOM never updated doesn’t reflect patched vulnerabilities or newly discovered CVEs in dependencies. Consequently, treating SBOMs as static compliance artifacts means the document becomes outdated the moment a developer updates a single package.
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2026 Shift: Living Operational Artifacts vs Static Docs
By 2026, leading organizations will shift from treating SBOMs as compliance documents to operational security tools with four key capabilities. First, continuous updating: generate SBOMs on every build, not just releases. Second, runtime correlation: track what’s actually running, not just what was declared. Third, attestations: provide cryptographic proof of software provenance. Fourth, observability integration: correlate SBOMs with behavioral telemetry showing which components are invoked and how often.
“By 2026, SBOMs will function as living operational artifacts rather than static compliance documents, continuously updated, validated, and correlated with runtime behavior,” according to recent industry predictions. Runtime telemetry provides essential context for risk assessment—teams can see which components are actually used, what data they access, and whether behavior has changed.
This is the paradigm shift that separates security theater from real security. The OpenSSF notes that “attestations offer a cryptographically verifiable way to ensure software provenance, security practices, and compliance, validating build processes and runtime integrity.” Static SBOMs tell you what was declared; runtime SBOMs tell you what’s executing. Attestations prove provenance; continuous updates catch dependency drift.
Practical SBOM Implementation Guide for Developers
Practical guidance exists for developers stuck between compliance mandates and broken implementations. Generate SBOMs in CI/CD pipelines, not at release. Integrate SBOM generation into automated workflows where builds already happen. Use open-source tools like Syft for fast generation or Trivy for integrated scanning, then upload results to Dependency-Track for centralized vulnerability monitoring.
Format choice matters: federal contracts often mandate SPDX for licensing compliance, while security vendors prefer CycloneDX for vulnerability management. Many organizations need both. Start with high-risk projects rather than attempting to SBOM everything at once. Indeed, a 90% accurate SBOM for critical components beats a 100% inaccurate SBOM for every application.
The workflow should be: developer commits code → CI pipeline triggered → build completes → SBOM tool scans artifacts → SBOM generated in CycloneDX format → uploaded to Dependency-Track → automated alerts on new CVEs → security team triages based on runtime context. This isn’t compliance theater—it’s operational security.
Key Takeaways
- 48% of organizations are falling behind SBOM mandates because they’re treating them as compliance checkboxes rather than operational security tools, creating a disconnect between “compliant” and “secure”
- Software supply chain attacks doubled in 2025, costing $60 billion globally, while remediation runs 17 times more expensive than direct breaches—SBOMs were supposed to prevent this
- The three fatal flaws: SBOMs generated too late (final build step), lacking accuracy (don’t reflect what’s shipped), and never regenerated (static documents instead of living artifacts)
- 2026 marks the shift to continuous verification with runtime correlation, attestations for provenance, and integration with observability platforms—moving from static compliance to dynamic operational security
- Developers should generate SBOMs in CI/CD pipelines using tools like Syft or Trivy, upload to Dependency-Track for centralized monitoring, and integrate with vulnerability scanning workflows rather than storing PDFs in compliance folders
The choice for 2026 is clear: evolve SBOMs into operational artifacts with continuous verification and runtime integration, or continue bleeding billions while checking compliance boxes. The attacks aren’t slowing down.
