RFC "2025 Minimum Elements for a Software Bill of Materials"

Ludovic Courtès ludo at gnu.org
Thu Oct 2 13:49:11 UTC 2025


Hello,

FWIW, comrades and I in Guix replied to a previous CISA request for
comments on identifying software:

  https://guix.gnu.org/en/blog/2024/identifying-software/

The TLDR is:

   1. Source code can be identified through inherent identifiers such as
      cryptographic hashes—see <https://www.swhid.org/> in particular.

   2. Binary artifacts, instead, need to be the byproduct of a
      verifiable build process itself available as source code.

CISA’s “Minimum Elements for a Software Bill of Materials (SBOM)” seems
to mean “binary artifacts” rather than “source code” when it says
“software” (correct me if I’m wrong, I only skimmed through it), and
then focuses on how to identify those binary artifacts.

If that interpretation is correct, I think that’s a mistake because it
would forego verifiability as provided by reproducible builds in favor
of something that looks more like paperwork.

Ludo’.


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