Contents
The Indian Computer Emergency Response Team (CERT-In) under MeitY issued Version 2.0 of its Technical Guidelines on SBOM, QBOM & CBOM, AIBOM and HBOM on 9 July 2025. Section 9 introduces an AI Bill of Materials, an inventory of the models, data sources, datasets, software dependencies, hardware, licences and vulnerabilities behind an AI system, lists 19 minimum elements, and recommends that government, public-sector and essential-services organisations require an AIBOM in every AI procurement. The guidelines are recommendations, not binding rules. CERT-In has also issued a May 2023 advisory on the security implications of AI language applications and, on 25 May 2026, a Blueprint on defending against AI-assisted exploitation of vulnerabilities, which recommends AIBOMs and governance of enterprise AI use.
Legal effect: this guideline, advisory or order is not legally binding by itself. It may describe or request action; obligations arise only where a statute, rule or court order says so.
What it asks
- CERT-In's Version 2.0 guidelines of 9 July 2025 cover an AI Bill of Materials (AIBOM) alongside software, quantum, cryptographic and hardware BOMs.
- An AIBOM is an inventory of the models, algorithms, data sources, datasets, dependencies, hardware, licences, known vulnerabilities and intended uses behind an AI system; Table 10 lists 19 minimum elements.
- CERT-In recommends that government, public-sector and essential-services organisations include AIBOM requirements in all AI procurement and that AI solutions supplied to them must be accompanied by an AIBOM.
- Formats should follow standards such as SPDX or CycloneDX, and suppliers should issue VEX documents (not affected, affected, fixed, under investigation) after a vulnerability is found.
- The guidelines are recommendatory; MediaNama noted that a government mandate in procurement could turn them into an industry standard, and no such mandate was reported.
- CERT-In's May 2023 advisory warned of generative-AI misuse for malware, phishing, fake apps and deepfake text, and its 25 May 2026 Blueprint recommends AIBOMs, AI asset inventories, governance of 'shadow AI' and deepfake-response procedures.
- The documents treat AI as a cyber-security and supply-chain subject; they do not regulate content, copyright or model behaviour, which are handled by MeitY's IT Rules and other instruments.
Background
CERT-In is the Indian Computer Emergency Response Team, the national cyber-security incident-response body within the Ministry of Electronics and Information Technology. Version 2.0 of its Technical Guidelines, dated 9 July 2025, covers the Software Bill of Materials (SBOM), a list of the components in a piece of software, together with Quantum and Cryptographic BOMs (QBOM and CBOM), an AI Bill of Materials (AIBOM) and a Hardware Bill of Materials (HBOM).1
The guidelines are addressed to entities in the public sector, government and essential services, and to organisations in software export and services, and say departments and organisations 'are encouraged' to make an SBOM a mandatory standard practice in software procurement and development.1 AI was added because AI systems have their own supply chains of pre-trained models, datasets and frameworks, and a flaw or an undocumented dependency in any of them is a security risk.
CERT-In's first AI-specific document was Advisory CIAD-2023-0015, 'Security implications of AI language based applications', issued on 9 May 2023. It warned that threat actors could use generative AI tools to write malicious code, scan networks, escalate privileges and build malware and ransomware, to generate human-like text for fake news, scams, misinformation, phishing messages and 'deepfake text', and to create fake websites and apps that impersonate AI tools; it also noted that models trained on internet data may collect personal information without consent. Its recommendations included verifying domains and apps claiming to be AI tools, not entering sensitive data, applying content filtering, strengthening monitoring, regular audits, multi-factor authentication and incident-response plans.3
Contents of the AIBOM chapter
Section 9 of the guidelines defines an AIBOM as a comprehensive list of the components used in building, training and deploying AI models, 'typically' including hardware such as servers, sensors and GPUs, software such as models, frameworks and development tools, and data sources.1 It identifies four benefits: security (finding vulnerabilities in models and their components and speeding incident response), transparency (documenting algorithms and data sources so stakeholders understand how a system was built), compliance (helping demonstrate adherence to privacy, regulatory and ethical requirements) and risk management (identifying dependencies and failure points).1
Table 10 sets out the minimum elements of an AIBOM:1
| Group | Elements |
|---|---|
| Identity | Model name, model version, model type, model developer |
| Licensing and provenance | Model licensing information; data source (proprietary, public, real-time or synthetic data); datasets (names, versions, formats, limitations, and compliance with privacy and licensing rules) |
| Technical composition | Software dependencies; ML models and algorithms; hardware; input; output |
| Performance and security | Model performance metrics; security requirements (encryption and access control); known vulnerabilities, with severity ratings and CVE references; attestations (digital signature for the model or AIBOM) |
| Use and impact | Intended usage; out-of-scope usage; environmental impact (energy, resource use and carbon footprint) |
Section 9.4 contains thirteen recommendations and six best practices. The recommendations say that government, public-sector and essential-services organisations, and organisations involved in AI-driven development and services, should include AIBOM requirements in all AI procurement; that AI solutions supplied to them must be accompanied by an AIBOM containing the specified elements; that they must ensure an AIBOM is kept for all AI systems used, procured and developed; that AIBOMs follow standards such as SPDX or CycloneDX; that suppliers issue VEX documents after a vulnerability or security issue; that consumers build internal AIBOMs from the supplier's and integrate them with vulnerability databases, CERT-In vulnerability notes and threat-intelligence platforms; that AIBOM data be encrypted and access-controlled; and that the AIBOM be updated through the lifecycle. The best practices include keeping a comprehensive inventory, standardised formats, automating AIBOM generation in development pipelines, supporting reproducibility with scripts, weights and configuration, prioritising critical models and tracking model lineage (versions, retraining and modifications).1
Adoption and legal status
The guidelines are framed as recommendations and technical guidance. Their operative language is that organisations 'should' include AIBOM requirements in procurement and that supplied solutions 'must' be accompanied by one, but they are not rules under the IT Act and carry no penalty. MediaNama described them as guidelines and noted that if the government 'ends up mandating' AIBOMs in procurement, that could set a broader industry standard; it reported no such mandate.2 The sources reviewed did not identify any procurement rule, tender condition or scheme that requires an AIBOM.
MediaNama also quoted lawyer Archana Iyer on a practical limit: an AIBOM's benefits depend on what suppliers disclose and on contract terms, for example whether the buyer can tie licensing information in the AIBOM to an indemnity.2
Significance and criticism
The AIBOM guidelines ask suppliers to document training data provenance, licensing and limitations, which bear directly on copyright and privacy compliance as well as on security. By placing the burden on suppliers to disclose models, datasets and dependencies in a structured, machine-readable form, and by tying the request to public procurement, CERT-In works through the government's purchasing power rather than through regulation.1
Limits are visible. The guidelines are voluntary and aimed at procurement by government and essential services rather than the private sector at large, and they depend on supplier honesty and capacity to produce accurate AIBOMs for third-party or proprietary foundation models.2 They sit within a cyber-security frame: they do not address model behaviour, bias, content harms or intellectual property directly, which are treated by MeitY's IT Rules, advisories and AI Governance Guidelines and by the DPDP Act and copyright law. MediaNama's coverage of the guidelines reported no formal criticism of the AIBOM requirement itself; its report on the 2026 Blueprint described that document as advisory rather than mandatory and noted that no mechanism links it to CERT-In's audit guidelines.25
Current status
Version 2.0 of the Technical Guidelines of 9 July 2025 is the operative text. The sources reviewed do not report a later version, a procurement mandate or any enforcement of the AIBOM recommendations as of 15 October 2026. The May 2026 Blueprint reinforces the AIBOM idea for enterprises, and MeitY's reported plan to tighten AI incident reporting, first reported in September 2026, has not been notified in the sources reviewed.46
Timeline
- Apr 2022
CERT-In cyber-security directions
CERT-In issues directions requiring specified cyber incidents to be reported within six hours (as described in later MediaNama reporting).
- May 9, 2023
Advisory CIAD-2023-0015
CERT-In issues its first advisory on the security implications of generative AI language applications.
- Jul 9, 2025
Technical Guidelines Version 2.0
CERT-In issues guidelines on SBOM, QBOM, CBOM, AIBOM and HBOM, recommending AIBOMs in government AI procurement.
- Jul 15, 2025
AIBOM guidelines reported
MediaNama reports on the AIBOM guidelines and what they mean for AI procurement.
- Aug 20, 2025
Home Affairs committee report
The committee asks CERT-In to coordinate monitoring and issue deepfake detection alerts.
- Nov 5, 2025
India AI Governance Guidelines
MeitY releases guidelines that recommend a voluntary national AI incident database.
- May 25, 2026
CERT-In Blueprint on AI-assisted exploitation
CERT-In publishes Version 1.0 of its Blueprint, recommending AIBOMs and AI governance controls.
- Sep 21, 2026
AI incident-reporting plan reported
Economic Times reports that MeitY plans to revise the norms, timeframe and content of AI incident reporting.
Sources
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Pacta AI Observatory, “CERT-In Technical Guidelines on SBOM, QBOM & CBOM, AIBOM and HBOM (Version 2.0, 9 July 2025) and CERT-In AI security guidance,” last updated October 15, 2026, https://aiobservatory.pacta.in/wiki/cert-in-aibom-guidelines.