Requirements by context

ContextAuthority / statusWho is affectedSBOM expectation
FDA cyber devicesSection 524B · statutory requirementSponsors of covered premarket applications/submissionsProvide an inventory of commercial, open-source and off-the-shelf components.
EU Cyber Resilience ActRegulation (EU) 2024/2847 · staged applicationManufacturers of in-scope productsCreation obligation within vulnerability handling; broader application from December 2027.
U.S. federal procurementOMB M-26-05 · agency risk-based policyAgencies and suppliers under actual acquisition termsAgencies may adopt SBOM-on-request contract terms.
Customer / supplier agreementContractual requirementParties and products identified in the agreementDelivery, quality, access and updates depend on agreed terms.
CISA minimum elementsGovernment guidanceOrganizations choosing or instructed to apply itCurrent guidance is the published 2026 document.

Source: FDA · Cybersecurity in Medical Devices FAQs.

Source: European Commission · CRA legislative summary.

Source: OMB · M-26-05, January 23, 2026.

Source: CISA · July 29, 2026 release announcement.

Use precise labels

LabelMeaningWhat to record
Statutory requirementA duty created by legislationProvision, scope and applicability.
RegulationA binding rule within its jurisdiction and scopeText, dates, exclusions and amendments.
Government procurement policyInstructions or terms affecting covered acquisitionsCurrent agency policy and solicitation terms.
Government guidanceAgency recommendations or interpretationFinal/draft status and issue date.
StandardPublished technical rules or modelEdition and the applicable conformance point.
Contractual requirementA promise defined by an agreementDelivery, acceptance, correction and remedies.
Buyer recommendationA proposed purchasing safeguardBusiness rationale and negotiable priority.

A standard can become relevant through law, agency policy or contract. Its publication alone does not make every field mandatory for every software producer. A useful requirements register records both the originating source and the way it became applicable.

Build an applicability record

  1. Identify the product and its intended markets, users and distribution model.
  2. Identify your role: manufacturer, supplier, integrator, buyer or operator.
  3. Find the current primary authority and any scope exclusions.
  4. Record the exact provision, status and relevant application date.
  5. Define the artifact, recipient, accepted format and delivery timing.
  6. Assign an owner for interpretation and change monitoring.
  7. Translate the obligation into an evidence-producing workflow.

Keep assumptions visible. A connected medical device, a hospital’s purchased application and a standalone consumer product may have different duties even when they use the same library. An internal inventory policy can still apply to all three.

Do not confuse the artifact with the program

An inventory file can satisfy a particular delivery expectation while leaving vulnerability handling, configuration control or supplier monitoring unfinished. Conversely, a mature vulnerability program may still lack the artifact a regulator or customer requests. Assess those separately.

Map each required output to its generating process, validation gate, approval, delivery record and retention policy. If a supplier cannot provide an element, record the gap and its disposition under the applicable authority or agreement. Do not replace unknown information with a plausible value.

Where uncertainty remains

Product scope, legacy releases, connected services and modifications can require case-specific interpretation. Standards and implementation work continue to evolve. This resource provides source-based orientation; organizations need a documented applicability decision for their own facts.

The CRA implementation timeline and FDA publication record should be rechecked before a submission or launch. Federal solicitations may contain agency-specific terms. A generic checklist cannot determine the controlling contract.

Turn obligations into supplier terms

Name the baseline by document and date. Specify accepted formats and versions, the covered artifact, release mapping, quality criteria and correction process. Agree whether authorized security tools can process the data and whether support continues to include updated inventories.

Use the RFP matrix to request evidence of these capabilities from an SBOM platform. Use the readiness checklist to identify who owns the resulting process. The requirement matters only if the organization can produce and use the evidence when needed.

Primary sources