10 Requirements for SBOM Components under SEBI CSCRF As financial institutions increasingly depend on complex software ecosystems, software supply chain security has become a regulatory priority. Applications today are rarely built from scratch; they rely on open-source libraries, third-party frameworks, and externally maintained components. While this accelerates innovation, it also introduces hidden risks. To address these challenges, SEBI introduced the Cybersecurity and Cyber Resilience Framework (CSCRF), placing strong emphasis on transparency, traceability, and accountability in software usage. At the core of this approach is the Software Bill of Materials, or SBOM. Under SEBI CSCRF, SBOM acts as a foundational control that enables organizations to understand what software they are running, where it comes from, and how secure it is. The framework outlines specific requirements that every SBOM must satisfy to support effective risk management and regulatory compliance.
1. Component Name and Version Identifier Each software component must be uniquely and accurately identified. ● Component name as defined by the publisher or community ● Exact version number deployed in production ● Clear distinction between proprietary and open-source components Accurate identification ensures that known vulnerabilities can be matched precisely to affected components, enabling faster remediation.
2. Supplier or Vendor Information Traceability across the software supply chain is a key expectation under SEBI CSCRF. ● Name of the software supplier or open-source project ● Vendor contact or reference details, where applicable ● Ownership or maintenance responsibility This information supports third-party risk assessments and strengthens accountability during audits or incidents.
3. License Information Licensing risks can lead to legal, operational, and reputational consequences if not managed properly. ● Type of license (open-source, commercial, proprietary) ● License version and usage conditions ● Restrictions that may affect distribution or modification Documenting license details in the SBOM helps ensure compliance with legal and regulatory obligations.
4. Cryptographic Hash and Integrity Data Maintaining software integrity is critical for preventing tampering and supply chain attacks. ● Hash values such as SHA-256 or equivalent ● Verification status of deployed components ● Reference to approved or trusted sources Integrity data allows organizations to validate that software has not been altered post-deployment.
5. Dependency Relationships Modern applications contain layered dependencies that can amplify risk.
● Top-level dependencies used directly by the application ● Transitive dependencies introduced indirectly ● Clear mapping of dependency chains This visibility enables rapid impact analysis when a vulnerability is discovered in any component.
6. Update Frequency and Patch Status Knowing how actively a component is maintained is essential for risk prioritization. ● Last update or release date ● Current patch level ● End-of-life or unsupported status, if applicable Outdated components with no patch support significantly increase cyber risk and must be addressed proactively.
7. Encryption and Security Control Metadata Security controls applied at the component level must be documented. ● Encryption standards used for data at rest or in transit ● Authentication or access control mechanisms ● Compliance with internal security policies This metadata helps assess whether sensitive data is adequately protected within applications.
8. Known “Unknowns” or Gaps SEBI CSCRF recognizes that full visibility may not always be immediately achievable. ● Components with incomplete metadata ● Dependencies that cannot be fully identified ● Areas requiring further investigation or validation Explicitly documenting gaps promotes transparency and continuous improvement rather than false confidence.
9. Access and Change-Log Metadata Governance and auditability are integral to SBOM management. ● Record of who created or modified SBOM entries ● Timestamped change history ● Approval or validation checkpoints These logs support forensic analysis, internal audits, and regulatory reviews.
10. Business-Critical System Linkage SBOM data must be contextualized within business operations. ● Mapping components to critical applications or services ● Identification of systems supporting core market functions ● Alignment with business impact analysis This linkage allows organizations to prioritize response efforts based on operational and financial impact.
Why SBOM Matters for SEBI-Regulated Entities SBOM is more than a compliance checkbox — it is a strategic enabler of cyber resilience. By maintaining accurate and up-to-date SBOM records, financial institutions can: ● ● ● ●
Detect and respond to vulnerabilities faster Reduce exposure to software supply chain attacks Demonstrate regulatory compliance with confidence Improve coordination between security, IT, and risk teams
However, managing SBOM manually across large and dynamic environments is neither scalable nor reliable. Automated SBOM generation and centralized management can significantly reduce operational overhead while improving accuracy. Organizations that embed SBOM into their development and security workflows are better positioned to meet SEBI CSCRF expectations without slowing innovation. For institutions looking to strengthen their software supply chain security posture, adopting a structured and automated SBOM approach can transform regulatory requirements into a long-term security advantage.
