CISA's 2026 SBOM Minimum Elements Update Turns "We Have One" Into the Wrong Answer TL;DR CISA's updated SBOM minimum elements now explicitly cover AI products alongside conventional, open source, and software-as-a-service products. New required fields include component hashes, licenses, SBOM-generation context, and the name of the tool used to produce it. Close to 30% of code shipping today is AI-generated, and that pace outruns any manual process built to review a bill of materials by hand. An SBOM built to the prior minimum elements no longer supports the same "we have one" answer in a board meeting, an audit, or a filing. The open question is whether an SBOM would hold up if someone with subpoena power read it, not merely whether one exists. A CFO reading a disclosure document asks whether it still matches the standard the market expects of it, not whether it matched that standard on the day it was filed. A CISO reading a software bill of materials asks...