At least on first reading, I find this unpersuasive. He correctly lists a variety of problems. But he doesn't explain how his proposed solution, listing all the components of a technological product, would make a practical difference. Creating a list is valuable only if people a) read the list, b) recognize problems, and c) do something based on that. And for some of the examples he gives, it seems pretty obvious to…
In my mind SBOM is similar to food ingredients being listed on the packaging. FDA or someone requires them, very few read them or cares what is in there. BUT now that they are listed on every food product, those who care can read them and make informed decisions. And raise alarm when it is found that someone uses unhealthy amounts of whatever in their cakes or sausages. As for software, if I had up to date reliable S…
And sue them if they lie about it. I think a lot of the benefit of these types of regulations is to force businesses to commit active frauds instead of passive frauds. Not doing something you were supposed to do is incompetence. Lying on a form about doing something that you haven't is deceit.
The profits from incompetence and deceit are equal until one gets caught, then the lesser punishment for incompetence as compared to deceit makes deceit more expensive. Smart businesses will choose incompetence every time, and engineer it into the system everywhere where fraud would be profitable.
Of course, they can also hire temps to sign forms, like the banks did in 2008[1], but the current administration has to really want you to get away with it for that to work.
[1] https://www.nolo.com/legal-encyclopedia/false-affidavits-for... Note: it was strangely difficult to find information on this still on the web.
-----