SEBI SBOM Mandate

Back in August 2024, the Securities and Exchange Board of India (SEBI), India’s capital markets regulator introduced the Cybersecurity and Cyber Resilience Framework (CSCRF). SEBI is the authority that oversees stock exchanges, depositories, mutual funds, brokers, and pretty much every major financial market participant in India. Its role is to protect investors, ensure fair market practices, and strengthen trust in the financial system.

As part of this new framework, SEBI has made one thing clear: Software Bill of Materials (SBOMs) are no longer optional, they’re mandatory. This puts India’s financial sector in line with global best practices for software supply chain security

But first, what is SBOM?

Consider SBOM to be your software’s nutrition label. Every component is listed, including proprietary materials, third-party code, and open-source libraries.

Why does SEBI care? Because with an SBOM, you can:

• Spot vulnerabilities before they’re exploited.
• Keep tabs on licensing issues.
• Respond faster when something goes wrong.
• Show regulators and customers that your software supply chain isn’t a black box.

A CIO I spoke with recently said, “We always knew we had blind spots in our stack, but we didn’t know how to expose them. SBOM gives us that flashlight.” That pretty much nails it

The Non-Negotiables Under SEBI’s CSCRF 

Here’s what the SBOM mandate means in practice:

1. Mandatory SBOM Documentation
   • All critical software systems must have SBOMs.
   • Applies to new, existing, and legacy systems.
2. Standardized Formats
   • SBOMs must be generated in SPDX or CycloneDX formats.
   • Non-standard or partial exports may fail audits.
3. Continuous Monitoring
   • SBOMs must be updated with every patch, release, or component change.
   • Integrated into CI/CD pipelines for real-time compliance.
4. Third-Party Software Visibility
   • Vendors must supply SBOMs for COTS and proprietary software.
   • Organizations must validate and map these SBOMs internally.
5. Audit Readiness
   • SBOMs must be available on demand during audits.
   • Signed attestations and versioned reports are recommended.

Why SBOMs Are a Big Deal for Finance

Let’s be real: financial institutions are juicy targets. Attackers don’t need to break your castle walls if they can sneak in through a vulnerable open-source library.

SBOMs change the game because they provide:

• Early Vulnerability Detection: They help uncover risks in third-party libraries before attackers can exploit them.
• Reduced Supply Chain Risk: Clear visibility into dependencies cuts down on hidden threats that often go unnoticed.
• Faster Incident Response: When something goes wrong, knowing exactly what’s in your stack makes containment and recovery much quicker.
• Regulatory Alignment: SBOMs also demonstrate compliance with SEBI’s growing set of expectations.

I’ve seen teams scramble during audits, pulling all-nighters to trace dependencies manually. It’s painful. With SBOMs baked into your process, that nightmare goes away.

The Deadline (and Why You Shouldn’t Wait)

SEBI has set August 31, 2025, as the cut-off date for SBOM compliance, and it’s almost here.

Here’s what you really need for:

• Picking the right SBOM tools.
• Training your teams so SBOM doesn’t feel like extra work.
• Automating the generation and updates.
• Building it into your DevSecOps flow.

How Regulated Entities Can Get Started

Some practical steps (from seeing what’s working in the field):

• Tools like SBOMApp can save a ton of manual effort—automatic generation, vulnerability scanning, CI/CD integration.
• Don’t only generate SBOMs for release; track them throughout the SDLC.
• Use a centralized dashboard to avoid juggling SBOMs between teams.
• Lock down third-party vendor compliance with clear SBOM requirements in contracts.

Final Thoughts

SEBI’s SBOM rule is more than just a checkbox; it is a deliberate change towards proactive software supply chain security. SBOMs are currently required by regulated entities to ensure compliance, resilience, and trust.

Products such as SBOMApp will automate SBOM generation, integrate with CI/CD workflows, and confirm audit-readiness, making compliance effortless and scalable.

Are you still unsure how SBOM impacts your organization? Seeing it in action makes all the difference. Want to learn more about SBOM or explore SBOMApp? Contact us today.

References:

SEBI CSCRF Compliance Deadline Extended