Once a format is chosen, the next question is what that format must contain. The documents that define this floor are the US Minimum Elements series. Though they are recommendations, they function as the de facto standard for federal procurement, and SBOM requirements in the EU and other jurisdictions largely reference this same framework.

Lineage: From NTIA 2021 to CISA 2025

The National Telecommunications and Information Administration (NTIA) publishedThe Minimum Elements For a Software Bill of Materials (SBOM) in July 2021, under the delegation of Executive Order 14028. The document organized the minimum elements into three categories: the data fields to track per component, automation support requiring a machine-readable format, and practices and processes covering generation frequency, depth, and the like.

Stewardship of the community’s work then moved to the Cybersecurity and Infrastructure Security Agency (CISA), and two lines of revision followed. One was the third edition (September 2024) ofFraming Software Component Transparency, a reference document that defines attributes, which added License and Copyright Notice to the baseline attributes. The other was a revision of the minimum elements document itself: CISA released2025 Minimum Elements for a Software Bill of Materials as a public comment draft in August 2025, with the comment period closing on October 3, 2025. As of June 2026, this revision remains in draft status, and the date of a final version has not been confirmed.

The Data Fields and Three Categories of NTIA 2021

The NTIA 2021 minimum elements set seven per-component data fields.

The three categories are as follows.

• Data fields: The seven items above — the basic information for tracking and identifying components.
• Automation support: Specified SPDX, CycloneDX, and SWID as standard formats for automated generation and machine readability.
• Practices and processes: Covers generation frequency, depth, handling of known unknowns, distribution and delivery, access control, and how errors are accommodated.

What the CISA 2025 Draft Adds

The CISA 2025 minimum elements draft expanded the data fields to reflect the maturing state of tooling. Four core elements were newly added.

Existing items were also revised. The roles of SBOM Author and Software Producer were distinguished, “Other Unique Identifiers” was updated to “Software Identifiers,” and the access control element, previously separate, was folded into the distribution and delivery item. The trajectory of License — entering as a baseline attribute in Framing 3rd edition and hardening into a data field in the 2025 draft — shows that the SBOM is establishing itself as primary data for open source license compliance, beyond a security inventory. Behind adding Tool Name, Generation Context, and Hash together lies the concern that an SBOM produced by an untrustworthy tool cannot itself be trusted. Tool integrity is covered in5. Tools and Automation.

Practical Recommendations

The minimum elements are, as the name says, a floor. Organizations can, and should, add fields suited to their own purposes. Carrying CVE references and patch status for vulnerability identification, SPDX license identifiers and copyright notices for license management, and release and End-of-Life dates for lifecycle management, together in one SBOM, lets a single SBOM answer multiple operational questions. If you are introducing an SBOM for the first time, starting with the NTIA seven fields as a base but including the four new fields from the CISA 2025 draft — especially hash and license — from the outset saves the effort of rebuilding it later.

Sources

NTIA (2021).The Minimum Elements For a Software Bill of Materials (SBOM).https://www.ntia.gov/files/ntia/publications/sbom_minimum_elements_report.pdf. CISA (2024).Framing Software Component Transparency, Third Edition.https://www.cisa.gov/resources-tools/resources/framing-software-component-transparency-2024. CISA (2025).2025 Minimum Elements for a Software Bill of Materials (SBOM) (public comment draft).https://www.cisa.gov/resources-tools/resources/2025-minimum-elements-software-bill-materials-sbom. (All retrieved: 2026-06-14)