A policy paper published Tuesday advocates for software bills of materials (SBOMs) for artificial intelligence as a mechanism for reducing cyber risk and improving transparency, and seeks to give lawmakers, federal agencies and others a roadmap on how to proceed.

The SBOM, commonly described as an inventory of software ingredients, emerged in the 2010s and has expanded beyond software to include hardware and AI.

But the paper from the Institute for Security and Technology, which CyberScoop is the first to report on, argues that AIBOMS require foundational work before they can be widely implemented.  This comes as some companies are already offering AIBOM services and other organizations are actively shaping AIBOM policy.

“What we’re worried about is we would end up in a ‘fire, ready, aim’ situation where everyone was doing it, but we were all doing slightly different things,” said a co-author of the paper, Allan Friedman, who has worked on SBOMs in multiple U.S. government roles. “If we don’t have a shared vision, it becomes a lot harder to have a coherent policy. It becomes a lot harder to have common tools and interoperable data and it becomes a lot harder to use the data that we’re tracking to actually deliver on the promise of supply chain transparency.”

The idea for the paper sprung from discussions with Hill aides and Pentagon staffers, Friedman said, and people like them are the target audience as well.

A key premise is that AIBOM policy needs to explore the topic from two sides.

“How do you solve the chicken-and-egg issue, where no one’s providing the data, so no one’s asking for it, and no one’s asking for it, so no one’s providing it?” Friedman told CyberScoop. “The answer is, you have to go from both supply and demand.”

On the supply side, “An AIBOM should capture relevant details about the models and datasets used for training, fine-tuning, evaluation, validation, testing, retrieval, grounding, augmentation, or other model development or operational purposes,” the paper suggests.

“The demand side begins with some form of forcing function or requirement that organizations understand what is in the products they manufacture and sell,” it states, with one such requirement potentially being an industry mandate to require the tracking of system components — for example, like the “lightweight” standards used in the payment card industry on data security that isn’t overly exact about how components should be tracked.

But it could also include government regulations or contracting conditions, Friedman argues with his Institute for Security and Technology colleague Nick Leiserson. (The scope of government directives on AI is a topic of considerable debate on Capitol Hill and within the Trump administration right now.)

Friedman said the paper isn’t meant to be the be-all, end-all, and acknowledged the prior work of organizations like the Open Worldwide Application Security Project (OWASP) and Linux Foundation.

“We’re not saying this is a brand new topic, nor are we saying that AIBOM will solve all AI security issues,” he said. “I’ve been fighting this fight for SBOM for a decade. You know, SBOM will not pick up your dry cleaning.”

And as AI continues to evolve rapidly, that means papers like the one published Tuesday are just at the beginning of the discussion, Friedman said.

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The White House has updated rules for federal agencies to keep logs of significant cyber activities in their networks, touting it as a measure to cut back on red tape and focus on how cybersecurity risks have evolved.

The Office of Management and Budget memorandum, released Friday, replaces a 2021 memo signed by then-President Joe Biden. It continues revisions that President Donald Trump has made to federal cybersecurity guidance under his predecessor.

The new memo, M-26-14, nods at the intentions of the earlier memo, M-21-31, saying that “Implementation of that memorandum improved foundational capabilities across agencies” to establish standards for logging and improve agencies’ record-keeping for the purposes of detecting and responding to cyberattacks.

“However, some requirements, such as the retention of vast quantities of logging data without clear utility, proved neither operationally feasible nor cost-effective for most agencies,” last week’s updated memo states. “To address these inefficiencies and the evolving cyber threat environment, this memorandum directs agencies to employ a risk-based, prioritized logging approach.”

There have been calls for the idea of updating the 2021 memo, and one observer praised the new version to CyberScoop. Another analyst, however, questioned how much harm the Trump administration might do by rescinding the earlier memo before having all of the new memo’s directives in place.

One directive is for the Cybersecurity and Infrastructure Security Agency to develop a “logging reference architecture” within 90 days that prioritizes the objectives of conducting continuous event monitoring and enabling investigations of forensic analysis after a known or suspected compromise.

Agencies would have another 90 days to submit a logging plan that adheres to those principles. The memo also establishes a new model for measuring agency progress in implementation. Multiple government watchdogs have concluded that agencies weren’t meeting the prior memo’s benchmarks.

The new memo “sharpens focus on real-time threat detection and the ability to investigate and recover after a cyber attack,” John Harmon, regional vice president of cyber solutions at Elastic, told CyberScoop. “It gives agencies the flexibility to build logging architectures that fit their specific mission.”

Harmon also praised the memo’s recognition of artificial intelligence risks to cybersecurity, and the revised maturity model.

But Nick Leiserson, senior vice president for policy at the Institute for Security and Technology think tank, said the timing of the replacement memo and the rescinding of the previous memo will give agencies a reason not to budget and prioritize logging for a period of time that adds up to six months or more.

“Moving from that to nothing is not ideal, and that’s essentially what this is doing,” Leiserson, who served in the Biden administration’s Office of the National Cyber Director, told CyberScoop. “This is saying ‘We’re rescinding 21-31 right now’ You won’t have any new guidance for at least 90 days, when CISA publishes this logging reference architecture, and it’s not clear to me why you would disaggregate that and not have the two of those things come out at the same time.”

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