NIS2 and SBOMs

November 04,2025

   

The European Union’s cybersecurity landscape is undergoing a transformation. With the adoption of the NIS2 Directive, an ambitious expansion of Europe’s Network and Information Security (NIS) framework, the EU aims to create a unified and resilient digital environment. It extends the scope of regulation to new industries, enforces stricter reporting timelines, and introduces governance obligations at the board level.

While many organizations interpret NIS2 as purely regulatory, the directive represents more than compliance, it’s a catalyst for cybersecurity maturity across Europe’s digital ecosystem. Among the technologies that can materially improve compliance readiness, the Software Bill of Materials (SBOM) stands out as a foundational enabler.

An SBOM provides a detailed inventory of software components, their dependencies, and associated metadata. It allows organizations to trace vulnerabilities, manage risks, and establish trust across the software supply chain. Though NIS2 does not explicitly mention SBOMs, its requirements for transparency, risk management, and incident response are best achieved through them.

This essay explores the symbiotic relationship between NIS2 and SBOMs, showing how visibility into software components directly supports regulatory compliance, accelerates incident handling, and reduces supply chain risk. It concludes by examining how Labrador Labs’ Supply Chain Management (SCM) platform operationalizes these principles to help organizations meet and sustain NIS2 compliance efficiently.

The NIS2 Directive: Overview and Implications

What is NIS2?

The Network and Information Security Directive 2 (Directive (EU) 2022/2555) updates and replaces the original 2016 NIS Directive. Adopted in December 2022, NIS2 broadens the scope of cybersecurity regulation across the EU to cover both essential and important entities, extending oversight to sectors critical to the European economy.

The directive aims to ensure a high common level of cybersecurity across Member States by mandating risk-based security measures, increasing transparency, and promoting cooperation between national authorities.

Who Must Comply

NIS2 applies to organizations operating in 18 sectors, divided into:

  • Essential Entities: Energy, transport, banking, healthcare, digital infrastructure, public administration, and space.
  • Important Entities: Postal services, food production, chemicals, manufacturing, waste management, and other digital services.

Entities with over 50 employees or €10 million in annual turnover generally fall within scope. Smaller entities may still be included if they play a critical role in national supply chains.

Key Requirements

NIS2 introduces several critical obligations:

  1. Risk Management and Governance – Organizations must adopt technical and organizational measures to mitigate risks.
  2. Incident Reporting – Significant incidents must be reported within 24 hours of detection, followed by detailed updates.
  3. Supply Chain Security – Companies must evaluate supplier security practices and third-party dependencies.
  4. Business Continuity – Requirements include disaster recovery and crisis management planning.
  5. Accountability and Oversight – Executive management can face personal liability for failure to implement appropriate measures.

2.4 Enforcement and Penalties

National regulators will oversee compliance, supported by the European Cyber Crises Liaison Organisation Network (EU-CyCLONe). Non-compliance can lead to fines of up to €10 million or 2% of annual global revenue, alongside reputational damage.

The combination of risk management, reporting, and accountability creates an environment where visibility, particularly into digital components and dependencies, is essential. This is precisely where SBOMs become indispensable.

Understanding SBOMs: The DNA of Software Transparency

An SBOM (Software Bill of Materials) is analogous to an ingredient label on food packaging—it lists every component within a software application. In an era of pervasive open-source usage and nested dependencies, the SBOM has evolved into a central artifact for security, compliance, and trust.

What an SBOM Contains

A typical SBOM includes:

  • Component names and versions
  • Suppliers and licensing information
  • Hashes and unique identifiers
  • Dependency relationships
  • Known vulnerabilities (mapped via CVEs)

Common Standards

SBOMs are generated and exchanged using standard formats such as:

  • SPDX (Software Package Data Exchange)
  • CycloneDX
  • SWID (Software Identification Tags)

These standards ensure interoperability between tools, suppliers, and customers across ecosystems.

Benefits of SBOMs

  1. Vulnerability Management: Identifies vulnerable components immediately when new CVEs emerge.
  2. Transparency: Provides proof of software provenance and composition.
  3. Auditability: Enables verification during compliance audits.
  4. Supply Chain Security: Makes hidden third-party dependencies visible.
  5. Incident Response: Speeds containment by mapping affected assets.
  6. Operational Efficiency: Reduces the complexity of patch management.

In the context of NIS2, these capabilities directly align with regulatory objectives: proactive risk management, rapid incident response, and demonstrable accountability.

NIS2 and SBOMs: The Missing Link

Why SBOMs Matter for NIS2

Though NIS2 never names SBOMs, it requires evidence of control over software assets and dependencies. To comply, organizations must know what they run, where it comes from, and how it can fail. SBOMs provide exactly that knowledge.

Four NIS2 principles align perfectly with SBOM capabilities:

  1. Supply Chain Security – SBOMs offer transparency into third-party software used by suppliers, supporting NIS2’s call for evaluating supplier security.
  2. Incident Response – When vulnerabilities are disclosed, SBOMs allow instant identification of affected systems, enabling timely reporting within NIS2’s 24-hour window.
  3. Risk Management – SBOMs help identify components susceptible to known exploits, feeding into continuous risk assessments.
  4. Transparency and Auditing – SBOMs serve as living documentation, proving governance and compliance during inspections or customer audits.

Case Example: Log4j

The 2021 Log4Shell vulnerability exposed how deeply a single open-source component could infiltrate supply chains. Organizations lacking SBOM visibility spent weeks locating affected software. Those with SBOMs pinpointed risks within hours, demonstrating why NIS2’s goals depend on SBOM-like visibility.

Operationalizing SBOMs for NIS2 Compliance

Integrating into Risk Assessments

During procurement or onboarding of third-party software, analyze SBOM data to uncover vulnerable or outdated components. This ensures supply chain risk assessment is evidence-based, satisfying NIS2 Article 21 requirements.

Accelerating Incident Response

Maintain a centralized SBOM repository. When a new vulnerability (e.g., CVE-2025-XXXXX) emerges, query SBOMs to identify affected systems instantly, reducing mean time to detection and reporting.

Embedding SBOMs in Contracts

Include SBOM generation clauses in supplier agreements. Require periodic delivery of updated SBOMs and immediate notification of new vulnerabilities.

Supporting Regulatory Reporting

When reporting incidents under NIS2, organizations must detail affected systems and components. SBOMs provide structured data to automate this reporting.

Automation and Tooling

Integrate SBOM generation into CI/CD pipelines using tools like:

  • Syft or Trivy for automated extraction
  • Labrador Labs SCM for continuous monitoring and compliance mapping

Automation ensures SBOMs stay current – eliminating manual overhead.

Implementation Roadmap for NIS2 Entities

A structured, eight-step roadmap helps organizations embed SBOMs into compliance strategy:

  1. Define Scope and Inventory – Identify critical software assets and dependencies.
  2. Establish Governance – Assign ownership for SBOM lifecycle management.
  3. Select Tooling – Choose SBOM generation and management platforms.
  4. Integrate into CI/CD – Automate SBOM creation at build time.
  5. Correlate Vulnerabilities – Map SBOM data to CVEs for proactive patching.
  6. Enhance Supplier Oversight – Require SBOMs in contracts and audits.
  7. Test Incident Workflows – Use SBOMs in tabletop exercises for NIS2 scenarios.
  8. Audit and Improve – Maintain evidence for supervisory authorities.

This roadmap transforms SBOMs from static files into dynamic compliance assets.

Challenges and Mitigation Strategies

Data Volume and Complexity

Modern software may contain thousands of dependencies. Use automated tooling to maintain scalable SBOM repositories.

Supplier Resistance

Vendors may hesitate to share SBOMs citing intellectual property concerns. Mitigate through NDAs, partial disclosures, or SBOM data redaction for sensitive components.

Interoperability Issues

Adopt recognized standards (SPDX, CycloneDX) to ensure compatibility across ecosystems.

Maintaining Accuracy

Integrate SBOM updates into build pipelines to avoid drift. Outdated SBOMs are non-compliant SBOMs.

Regulatory Uncertainty

Each EU Member State may interpret NIS2 differently. SBOMs offer a defensible, harmonized way to demonstrate compliance regardless of jurisdiction.

The Business Value of SBOM-Driven Compliance

Beyond regulatory necessity, SBOMs yield tangible business advantages:

  • Risk Reduction: Visibility lowers exposure to supply chain attacks.
  • Operational Efficiency: Streamlined patch management and asset visibility.
  • Audit Readiness: Pre-built evidence for compliance verification.
  • Customer Trust: Demonstrates mature cybersecurity practices.
  • Competitive Edge: NIS2 readiness differentiates vendors in procurement.

Organizations that treat SBOMs as a strategic asset, not a compliance checkbox, gain agility and resilience.

How Labrador Labs‘ SCM Solution Enables NIS2 Readiness

Labrador Labs’ Supply Chain Management (SCM) platform integrates SBOM technology directly into the compliance lifecycle, bridging the gap between regulatory requirements and operational execution.

Core Capabilities

  1. Automated SBOM Generation
    SCM continuously creates SBOMs for every build, ensuring up-to-date component visibility across environments.
  2. Vulnerability Correlation
    Real-time mapping between SBOM data and global CVE databases highlights exploitable risks instantly.
  3. Third-Party Risk Intelligence
    SCM visualizes dependency chains across suppliers and flags risky software origins.
  4. Incident Response Integration
    During an event, SCM cross-references vulnerabilities and dependencies to pinpoint affected assets – crucial for NIS2’s rapid reporting requirement.
  5. Audit and Reporting Tools
    One-click export of SBOM data for regulatory or customer audits provides verifiable compliance evidence.
  6. CI/CD Integration
    SCM connects seamlessly with Jenkins, GitLab, GitHub Actions, and other CI/CD systems -embedding SBOM visibility into DevSecOps workflows.

Strategic Benefits

  • Reduces manual compliance costs.
  • Provides continuous monitoring across software supply chains.
  • Demonstrates measurable NIS2 alignment during inspections.
  • Converts SBOM data into actionable intelligence.

Through its SCM solution, Labrador Labs transforms SBOM management from a static compliance document into a living operational capability: automated, verifiable, and scalable.

Best Practices for Sustainable SBOM Programs

To maintain long-term NIS2 readiness:

  1. Make SBOMs Continuous – Automate generation at every software release.
  2. Link with Threat Intelligence – Combine SBOM data with real-time vulnerability feeds.
  3. Version Control Everything – Store SBOMs in Git-based repositories for traceability.
  4. Centralize Storage – Use secure registries or platforms like Labrador SCM to avoid fragmentation.
  5. Define KPIs – Measure remediation time, SBOM freshness, and coverage across systems.
  6. Train Teams – Ensure developers and compliance officers understand SBOM usage.
  7. Regular Audits – Validate SBOM accuracy and linkage to running assets.

Future Outlook: SBOMs Beyond NIS2

As software ecosystems grow increasingly interconnected, SBOMs will underpin global cybersecurity frameworks. The U.S. Executive Order 14028, the UK’s Cyber Resilience framework, and upcoming EU CRA (Cyber Resilience Act) all reference or imply SBOM usage.

Within the EU, the intersection between NIS2, CRA, and the AI Act will create a unified requirement for component-level visibility. Organizations building mature SBOM capabilities today will be strategically positioned to comply across all three.

Labrador Labs’ vision aligns with this convergence, providing not just tools, but a full ecosystem for secure, transparent, and compliant software development.

The NIS2 Directive is reshaping how organizations view cybersecurity. Its requirements for risk management, supply chain assurance, and transparency demand more than policies, they demand visibility.

The Software Bill of Materials (SBOM) delivers that visibility. It connects the dots between code, compliance, and accountability. It transforms cybersecurity from reactive patching to proactive governance.

Organizations that embrace SBOMs gain a dual advantage: regulatory compliance under NIS2 and a stronger, faster, more transparent software ecosystem.

Through its Supply Chain Management (SCM) platform, Labrador Labs operationalizes these concepts, automating SBOM creation, mapping vulnerabilities, enabling rapid incident response, and generating audit-ready evidence.

NIS2 compliance is not a checkbox: it’s an evolution toward cyber maturity. SBOMs are the blueprint, and Labrador Labs is the architect helping organizations build it.