Strengthening Supply Chain Resilience: CISA’s Hardware Bill of Materials Framework

Jessica Sweet
Hunter Strategy
Published in
5 min readNov 8, 2023

In a rapidly evolving digital landscape, cyber supply chain security has become a paramount concern for both public and private sectors. The U.S. Cybersecurity and Infrastructure Security Agency (CISA) has recently taken a significant step towards enhancing supply chain security by introducing the Hardware Bill of Materials (HBOM) Framework. This framework provides valuable insights for all organizations, especially small businesses, and aligns with the goals of the Office of Management and Budget (OMB) Memorandum M-22–18 to enhance the security of software and hardware supply chains.

The Hardware Bill of Materials (HBOM) is a comprehensive listing of all the components that make up a hardware product. It’s a detailed inventory that includes information on each element’s source, manufacturer, specifications, and firmware or software dependencies. CISA’s HBOM Framework emphasizes the importance of having this detailed inventory to improve supply chain risk management. This information is invaluable when assessing the security and integrity of hardware components. While supply chain security is crucial for all organizations, small businesses often face unique challenges due to limited resources. The HBOM Framework offers significant benefits for small businesses, as it enables them to:

· Mitigate supply chain risks through identification and mitigation of vulnerabilities in their hardware components, reducing the risk of supply chain attacks

· Enhance Competitiveness, instilling trust in their partners and customers

· Comply with Regulatory Requirements, making it easier for small businesses to meet emerging compliance requirements

· Streamline procurement and make informed decisions about the components they source, ensuring the security and integrity of their supply chain, and

· Strengthen relationships with strategic partners and government agencies.

Relevance to OMB Memorandum M-22–18

CISA’s HBOM Framework closely aligns with the objectives of OMB Memorandum M-22–18, which focuses on enhancing the security of both software and hardware supply chains. The memorandum not only underscores the importance of secure software development practices, but it also recognizes that hardware plays a pivotal role in supply chain security.

The anticipation of hardware bills of materials for critical government procurements, including for operational technology and industrial control systems, would be a significant step forward. The memorandum emphasizes that a holistic approach to supply chain security should encompass both hardware and software components.

Formatting of HBOMs and Mapping to SBOM Formats

One of the critical aspects of CISA’s HBOM Framework is its emphasis on the format and structure of HBOMs. By following a standardized format, HBOMs facilitate better management and understanding of the hardware supply chain. For organizations that are already familiar with SBOMs, the concept of HBOMs may seem somewhat analogous. SBOMs are inventories of software components, including details about their origins and dependencies. Both HBOMs and SBOMs are pivotal tools for enhancing supply chain security.

However, it’s important to recognize that HBOMs and SBOMs differ in some significant ways, given the distinct nature of hardware and software components. Mapping HBOMs to SBOM formats can be a valuable approach, especially for organizations that already have established SBOM practices. This alignment can enable more comprehensive and continuous monitoring of bills of materials, enhancing overall supply chain security.

Data standardization and harmonization allows for consistent and meaningful cross-referencing. Integrating HBOM data into existing software and hardware supply chain management systems, where SBOMs might already be in use, also enables a more comprehensive view of the entire supply chain. Further, establishing protocols for incident response and mitigation in the event of a supply chain breach or vulnerability where mapped data can be promptly and effectively employed to pinpoint the affected hardware and software components. This anticipatory shift brings about several key implications that organizations, including small businesses, should consider as they prepare to align with these emerging standards to safeguard supply chain integrity.

First and foremost, the inclusion of HBOM requirements in critical procurements represents a recognition of the undeniable link between hardware security and the overall cybersecurity posture of an organization. Hardware components, whether they relate to critical infrastructure, operational technology, or everyday computing devices, play a fundamental role in the digital ecosystem. Acknowledging this fact signifies a new level of commitment to supply chain security. Moreover, as these requirements become more widespread, organizations will likely find themselves in an environment where supply chain security is not just a best practice but a mandatory aspect of doing business. This shift in expectations means that organizations must prepare to meet these standards not only for compliance but also to remain competitive and reliable partners within their respective industries.

Small businesses, in particular, stand to benefit from this proactive approach. While the task of aligning with emerging supply chain security standards might seem daunting, it can provide small businesses with a framework to enhance their competitiveness. By taking these steps to meet new HBOM requirements, small businesses can demonstrate their commitment to security and their capability to handle complex supply chain challenges.

Furthermore, aligning with these emerging standards represents a proactive and forward-thinking approach to risk management. The digital landscape is constantly evolving, and the threat environment is becoming more sophisticated. Embracing HBOM requirements is a means of future-proofing an organization’s supply chain security practices, ensuring that they remain effective in the face of new and evolving threats. The significance of these emerging standards also extends to the relationships organizations hold with strategic partners and government agencies. Demonstrating a commitment to supply chain security and readiness to align with these emerging requirements fosters trust and collaboration. Such organizations become preferred partners in an era where security is a shared responsibility, and a collective approach to defending against cyber threats is crucial.

In conclusion, as the industry anticipates the incorporation of hardware bills of materials into critical procurements, organizations, including small businesses, should embrace this transformation as an opportunity to fortify their supply chain security. These emerging standards not only signify a commitment to the integrity of the digital ecosystem but also offer a strategic advantage. By proactively aligning with these requirements, organizations can secure their position as trusted partners, promote supply chain resilience, and stand prepared to confront the dynamic and evolving challenges of the digital age.

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