
Since our previous discussion on the EU Cyber Resilience Act (CRA) and Software Bill of Materials (SBOMs), significant updates have clarified and expanded the framework for compliance. The European Parliament approved the CRA on March 12th, marking its importance in enhancing product security across the EU. This follow-up explain these developments, focusing on new guidelines and the evolving expectations for SBOM compliance.
New clarity on SBOMs from Germany: TR-03183
To provide more detailed guidance, Germany’s Federal Office of Information Security (BSI) released the Technical Guideline TR-03183: Cyber Resilience Requirements for Manufacturers and Products (Part 2: Software Bill of Materials (SBOM)), version 2.0. This 20-page document sets the groundwork for SBOM requirements under the CRA. Key highlights include:
- Mandatory SBOM Compilation: An SBOM is essential for meeting CRA compliance.
- Minimum Information Requirements: The SBOM must include the component name, version, dependencies, license (preferably using SPDX or ScanCode identifiers), and a SHA-256 hash.
- Version-Specific SBOMs: A separate SBOM must be generated for each software version, with updates made only for error corrections or new information.
- Preferred Formats: SBOMs must adhere to CycloneDX (v1.4 or higher) or SPDX (v2.3 or higher).
- Process Integration: The SBOM must be generated as part of the build process or an equivalent mechanism.
Other recommendations, such as using CSAF with a VEX profile for distributing vulnerability information, aim to enhance transparency without directly embedding vulnerabilities in the SBOM.
Challenges in SBOM Implementation
While TR-03183 provides critical guidance, several unresolved issues highlight the complexities of SBOM creation and usage:
- Identification Gaps: The absence of mandatory CPE or PURL requirements makes vulnerability reporting from SBOMs prone to errors.
- Undefined “Scope of Delivery”: The guidelines use this term to define the depth of transitive component enumeration but lack clarity on acceptable thresholds.
- SHA-256 Ambiguity: The methodology for computing a SHA-256 hash of source code remains unspecified.
- Relationship Details: While all transitive components must be recursively included, relationships among them are not explicitly required. This omission can hinder the effectiveness of SBOMs in vulnerability management.
Preparing for CRA Compliance
The CRA’s adoption signals a critical need for manufacturers and software developers to refine their compliance strategies. With enforcement set for early 2027, organisations should prioritise:
- Automating SBOM Generation: Tools like Meterian can streamline SBOM creation, ensuring accurate dependency mapping and compliance with CRA’s format requirements.
- Enhancing Vulnerability Management: Despite the lack of mandatory CPE or PURL, integrating these identifiers into internal processes can improve accuracy.
- Staying Updated: Monitoring updates to technical guidelines like TR-03183 will be vital as CRA implementation progresses.
Looking ahead
The CRA represents a significant step forward in securing the digital ecosystem. By leveraging clear guidelines and robust tools, organisations can align with compliance requirements while strengthening their cybersecurity posture. The publication of TR-03183 marks progress but also underscores the need for continued refinement as industry feedback shapes the future of SBOM practices.
Navigating the complexities of SBOM creation and CRA compliance doesn’t have to be overwhelming. Meterian provides automated solutions designed to simplify the generation and management of SBOMs, ensuring:
- Effortless Compliance: Meterian supports both CycloneDX format, helping you meet the CRA’s technical requirements with ease.
- Comprehensive Dependency Mapping: Automatically scans your codebase to identify all components and transitive dependencies, ensuring nothing is missed.
- Ongoing Vulnerability Monitoring: Integrates seamlessly with vulnerability databases to keep your SBOMs updated and your products secure.
- Time-Saving Automation: Embeds SBOM generation into your build processes, reducing manual effort and increasing efficiency.
With Meterian, you can confidently meet CRA requirements while enhancing your overall security posture. Contact us to learn how we can support your journey toward compliance and beyond.






