The SBOM Just Became a Liability With a Date on It When a best practice becomes a product requirement, it stops being a security artifact and starts being a financial one. The question now is whether the document you are obligated to produce is true. The EU Cyber Resilience Act is moving the software bill of materials from a best practice to a product security requirement, with the law’s full application arriving in December 2027 . If your company ships software into the EU, the character of one of your obligations just changed. The software bill of materials you used to produce because it was responsible is becoming one you are legally required to produce because a regulator says so. That is not a procedural change. It moves the bill of materials off the security team’s task list and onto the company’s books, and most organizations have not adjusted to what that means. A best practice and a requirement are not the same liability Every CFO understands that an unmanaged liability is a ...