Is your SBOM program FDA-ready?
Eleven questions mapped to FDA §524B and the current premarket cybersecurity guidance - now covering build provenance (SLSA), signing (Sigstore), AI-generated code, and dependency-confusion defenses. Get a score and a prioritized gap list.
Reviewed by
Christian Espinosa
Founder & CEO, Blue Goat Cyber
What SBOM format do you generate today?
What you'll see after you submit
Your answers become a 0–100 readiness score and category breakdown
- RingScore infographic: overall SBOM readiness as a percentage with tone (green/amber/red).
- Radial breakdown across format, depth, VEX, monitoring, and update cadence - see exactly which lever is dragging the score.
- Gap-by-gap remediation list mapped to FDA's premarket and postmarket expectations.
- Print/PDF view formatted for handing to a CTO or auditor.
Common misconceptions
What teams usually get wrong
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Myth: A top-level dependency list is an SBOM.
Reality: FDA expects transitive depth. The SBOM must include components your components depend on, down to the smallest unit you can practically resolve (NTIA 'minimum elements').
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Myth: SPDX and CycloneDX are interchangeable for FDA.
Reality: Both are accepted, but each has different VEX maturity, hashing conventions, and tooling support. Pick one, document why, and stay consistent across premarket and postmarket.
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Myth: Once we ship the SBOM, we're done.
Reality: §524B requires a maintained SBOM with monitoring and updates for the supported lifetime of the device. A static PDF in your submission is a postmarket deficiency in waiting.
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Myth: VEX is optional.
Reality: It's not statutorily required, but without VEX every new CVE in your SBOM looks like an open issue. FDA reviewers and customers now expect VEX to disposition non-exploitable findings.
References & further reading
Primary sources behind this tool
- The Minimum Elements For a Software Bill of Materials (SBOM) - NTIA / CISA
- SPDX 2.3 Specification - Linux Foundation / ISO/IEC 5962
- CycloneDX Specification - OWASP Foundation
- Vulnerability Exploitability eXchange (VEX) - Use Cases - CISA
- FDA Cybersecurity in Medical Devices Guidance - SBOM expectations - FDA
Recent regulatory + supply-chain activity
Tracked signals that change what reviewers expect. Items move on as new ones land.
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Apr 22, 2026CISA KEV
CISA adds use-after-free in Linux kernel netfilter to KEV (CVE-2026-0511)
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Apr 15, 2026CISA KEV
BLE pairing bypass in widely embedded Bluetooth stack added to KEV
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Jan 8, 2026CycloneDX
CycloneDX 1.6.1 errata - clarifies VEX status semantics for medical devices
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Nov 12, 2025OpenSSF
SLSA v1.1 published - tightened build-provenance language for regulated industries
Where to go next.
FDA-compliant SBOM services
SPDX/CycloneDX SBOMs generated each build with CVE/KEV/VEX maintenance.
Learn moreSBOM vs CBOM
What's actually required vs. legacy terminology reviewers still use.
Learn moreSPDX vs CycloneDX
Which format to choose for a medical device submission.
Learn moreMore tools
PCCP, 524B checker, SaMD classifier, readiness quiz.
Learn more