Supply Chain Security Requirements: Preparing for Executive Order 14028

Executive Order 14028, signed in May 2021, marks a watershed moment in the evolution of cybersecurity standards for organizations that do business with the U.S. federal government. The order lays out rigorous supply chain security requirements for government contractors and their software vendors, fundamentally changing how software is developed, maintained, and delivered. In this comprehensive guide, we’ll examine the mandate’s core requirements, why software supply chain security is now front and center, and how organizations can accelerate compliance with practical strategies and frameworks.

Understanding Executive Order 14028: The Shift in Supply Chain Security

Executive Order 14028, titled “Improving the Nation’s Cybersecurity,” responds to a wave of high-profile supply chain attacks (e.g., SolarWinds, Colonial Pipeline) that exposed deep vulnerabilities in government and critical infrastructure software supply chains. The order emphasizes the need for:

• Enhanced visibility into software origins (provenance)
• Secure development and delivery practices for software and services
• Mandatory adoption of Software Bills of Materials (SBOMs)
• Supply chain risk management throughout the lifecycle

Contractors bidding for federal work—or those supplying software to them—must demonstrate compliance with these requirements, backed by auditable evidence. The goal is to mitigate risks arising from compromised dependencies, hidden vulnerabilities, and insecure build environments.

Key Security Requirements for Government Contractors

1. Software Bill of Materials (SBOM)

One of the linchpins of EO 14028 is the requirement to produce and maintain a Software Bill of Materials for every application and component delivered. The SBOM lists all software dependencies, including third-party libraries, direct and transitive dependencies, and associated metadata. This transparency enables:

• Rapid vulnerability identification and remediation
• Supply chain provenance tracking
• Compliance with NIST’s SSDF (Secure Software Development Framework)

How to Implement:

• Use tools such as Syft, CycloneDX, or SPDX to automate SBOM generation as part of your CI/CD pipeline.
• Integrate SBOM checks into artifact release workflows to ensure completeness.
• Store and manage SBOMs in a tamper-resistant, queryable repository.

2. Secure Development Practices Aligned with NIST SSDF

EO 14028 requires adherence to NIST’s Secure Software Development Framework (SSDF). These best practices encompass:

• Threat modeling and design reviews
• Automated vulnerability scanning
• Code signing and artifact integrity verification
• Secure code review policies

Takeaway: Adopt static application security testing (SAST) and dynamic application security testing (DAST) tools, enforce code signing for builds, and ensure build pipelines are themselves hardened against compromise.

3. Vulnerability Management and Patch Response

Contractors are expected to maintain robust processes for identifying, reporting, and remediating vulnerabilities within supplied software.

• Regular vulnerability scanning (both pipeline and runtime)
• Integration of CVE databases for quick impact analysis
• Automated patching and release management

Example: Utilize OSV Scanner for open source vulnerability checks and integrate these scans into your pull request workflow.

4. Secure CI/CD Pipelines and Supply Chain Controls

CI/CD pipelines must be protected against intrusion and tampering. Minimum requirements include:

• Role-based access control and strong authentication for all pipeline agents
• Immutable build environments (e.g., ephemeral containers)
• Provenance logging for every artifact

Configuration Sample:

jobs:
  build:
    runs-on: ubuntu-latest
    environment:
      name: ephemeral
      resources:
        limits:
          cpu: 2
          memory: 4096
    steps:
      - name: Checkout code
        uses: actions/checkout@v2
      - name: Generate SBOM
        run: syft . --output cyclonedx-json > sbom.json
      - name: Security scan
        run: osv-scanner --sbom=sbom.json

5. Third-Party Risk Assessment and Management

Relying on external dependencies means risks can propagate upstream. Contractors must:

• Assess and track the security posture of vendors
• Require suppliers to provide SBOMs and attestations (e.g., SLSA, SSDF compliance)
• Monitor for dependency updates and security advisories

Takeaway: Create an inventory of critical open source and commercial components, and set up notification triggers for newly published vulnerabilities.

Industry Frameworks: SLSA, CIS Controls, and Zero Trust

Several recognized standards can accelerate compliance and improve your risk posture:

• SLSA (Supply Chain Levels for Software Artifacts): SLSA offers a progressive set of maturity levels for supply chain controls, covering everything from source code provenance to reproducible builds.
• CIS Controls: The Center for Internet Security prescribes practical controls for asset management, vulnerability management, and secure configuration.
• Zero Trust Security: EO 14028 calls for the adoption of Zero Trust principles, ensuring least-privilege access and continuous verification.

Reference official documentation for more details:

• NIST SSDF
• SLSA Framework
• CIS Controls

Practical Steps for Compliance

1. Assess Your Current Maturity

Use supply chain maturity assessment tools to establish a baseline across SBOM management, pipeline integrity, and vulnerability response. Quaerens.dev offers a comprehensive Software Supply Chain Maturity Assessment to help teams benchmark progress.

2. Automate and Integrate Security Checks

Embed SBOM generation, dependency scanning, and code signing into your CI/CD pipelines to reduce manual effort and ensure consistent compliance.

3. Educate and Train Teams

Security is a team sport. Institute recurring training on supply chain risks, secure coding, and incident response.

4. Monitor Regulatory Updates

Federal requirements are rapidly evolving. Subscribe to official government advisories and update your policies accordingly.

5. Document and Demonstrate Compliance

Be prepared to present evidence of compliance during audits—including SBOMs, SLSA attestations, and security artifacts produced by your pipelines.

Real World Case Study: SolarWinds Attack

The 2020 SolarWinds supply chain compromise remains a cautionary tale. Attackers gained access to the CI/CD pipeline, injected malicious code, and signed it as legitimate, impacting thousands of organizations. Had SBOMs, secure builds, and provenance logging been in place, the attack might have been detected earlier.

Conclusion

Executive Order 14028 has redefined supply chain security for government contractors. SBOMs, CI/CD integrity, and vulnerability management are not just regulatory demands—they are essential for building resilience against supply chain attacks. By adopting industry frameworks, automating security controls, and fostering a culture of continuous compliance, organizations can not only meet the mandate but significantly reduce their exposure to modern threats.

For government contractors looking to accelerate EO 14028 compliance, now is the time to assess, automate, and mature your supply chain security practices. Visit quaerens.dev for tools, best practices, and expert guidance on your compliance journey.