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Jul 21 2026
Artificial Intelligence

What Is an AI Bill of Materials?

As regulations and risks increase, these directories of AI components help boost confidence.

When an AI system makes a “bad decision,” most organizations can’t really explain why. They aren’t entirely sure which data trained it, where the error was, which version it was running or which third-party components were involved. This is an ethical and regulatory blind spot that creates risk for tech leaders in institutions of all sizes, and it’s driving interest in a newer framework called the AI bill of materials.

If you’ve ever seen a software bill of materials, or SBOM, then you already understand the concept. But many organizations have not yet thought about applying that framework and process to the AI systems they use. That will change: Regulations are prompting implementation of AIBOMs, according to Arpita Soni, a senior member of the technology professional society IEEE. “I’m seeing a lot of stress on the inventory, on BOM models around it because of increased guardrails,” Soni says. “Organizations are bending more toward this model because they need to be part of compliance and audits.”

For some, the decision follows former President Joe Biden’s 2024 executive order on AI usage and development, among other factors. Given increases in regulatory mandates — and the overall desire to mitigate risk — here’s why AIBOMs are on the rise, and what institutions should consider as they build and implement them.

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What Is an AI Bill of Materials?

The National Institute of Standards and Technology calls AIBOMs “enablers for AI software transparency and security,” pointing to their ability to also “foster trust” and “facilitate innovation.” Specifically, an AIBOM is a “repository or inventory,” Soni says, “that can be read by your machines, by your systems, and it comprises components including your data sets, your prompts, your models, your specific configurations, version history, pipelines and third-party dependencies.” 

Katie Norton, research manager for DevSecOps and software supply chain security at IDC, says that for organizations already using SBOMs, AIBOMs are a logical next step: “While an SBOM provides visibility into application code, libraries and dependencies, an AIBOM captures the components that define AI behavior.” 

DISCOVER: Proper governance is the first step to a successful AI strategy.

What Goes Into an AI Bill of Materials?

AIBOMs typically have similar components, though they might vary a bit based on an institution’s size, needs and systems.

Norton says that these structured, machine-readable inventories document multiple layers of the AI systems an organization uses and includes components and questions to ask for each:

  • The data layer includes training and validation data sets, provenance, licensing and sensitivity. This layer answers the questions, “Where did your training data come from? What are the licensing terms? Does it contain personally identifiable information?” 
  • The model layer includes architecture, weights, hyperparameters, versioning and lineage. It answers the questions, “What architecture? What version? What was the training configuration?”
  • The infrastructure and dependency layers include frameworks and hardware required to run the model, answering the question, “What frameworks and libraries does the model rely on, and where does it run?”
  • The governance metadata layer includes intended use, known limitations and risk mitigations. It answers the questions, “What is this model supposed to do? What are its limitations? What safeguards are in place?”

Norton emphasizes that AIBOMs are needed in addition to SBOMs. “An SBOM alone is insufficient for AI systems because it only inventories code,” she says. “AI systems are data-driven and often nondeterministic; their behavior emerges from training data and model configuration rather than explicitly written logic. Without an AIBOM, IT leaders lack visibility into the ‘cognitive layer’ of the system, making it difficult to audit decisions, reproduce results or assess supply chain risk.”

LEARN MORE: Is your infrastructure equipped to handle your AI workloads?

Why the AI Bill of Materials Is Gaining Traction Now

AI is not new, so why is the AIBOM just starting to become more widely adopted? Soni says that because AI has to be “ethical, transparent and fair,” a framework is needed to analyze those principles, and AIBOMs have begun to do just that — especially important at a time when “blind spots” have become apparent and the need for regulatory compliance is growing.

Norton points to three things converging to create the need for AIBOMS now: “First, generative AI made it trivially easy for developers to drop open-source models into applications without anyone in security knowing about it. Organizations suddenly realized they had no idea what models were running in production. Second, regulators caught up. The EU AI Act and NIST AI Risk Management Framework now expect transparency around training data and model lineage — things SBOMs were never designed to capture.”

And last, “the tooling finally exists. Standards like the Software Package Data Exchange (SPDX) and CycloneDX now have AI-aware profiles, so generating an AIBOM is no longer a custom engineering project. The risk was always there; now we have the means to address it,” Norton explains.

While Gartner predicts SBOM adoption will rise from 56% among large organizations in 2025 to 85% by 2028, the adoption rate for AIBOMs is yet to be determined.

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