The Geopolitics of Code: Navigating the U.S. Connected Vehicle Rule and the Global SBOM Shift

TL;DR

The BIS Connected Vehicle Rule, banning software linked to China and Russia, compels automotive OEMs to prove the origin of every software component in their vehicles. With 2027 deadlines fast approaching, the enforcement of this rule makes Software Bill of Materials (SBOM) transparency and automated supply chain analysis essential for compliance and market access. PlaxidityX offers a proven Software Supply Chain Security (SSCS) tool that enables OEMs to identify prohibited components and generate the evidence needed to meet evolving U.S. and global regulations.

Beginning early next year, the sale or import of connected vehicles that incorporate software linked to China or Russia will be prohibited in the US market. While the origins of this ban lie in a much broader geopolitical battle, the repercussions on OEMs are already being felt on the factory floor.

With the U.S. Department of Commerce’s BIS final rule on connected vehicles, which went into effect on March 17, 2025,  the “country of origin” for code has become as critical as the quality of the code itself. For OEMs and Tier-1s already burdened with myriad safety and cybersecurity compliance requirements, the challenge is no longer just “Is this software secure?” but also “Where exactly did this software come from?”

The enforcement of this rule will likely have a profound impact on the way OEMs manage and audit their supply chains.

What is the BIS Connected Vehicle Rule?

“BIS Rule – Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles” is intended to mitigate national security risks associated with connected vehicles and their supply chains, particularly concerning data exfiltration and remote manipulation by foreign adversaries.

This final rule establishes prohibitions on the import and sale of hardware and software in Vehicle Connectivity Systems (VCS) and Automated Driving Systems (ADS) for passenger vehicles that are designed, developed or supplied by Chinese or Russian entities. Software prohibitions apply to software subcomponents designed or manufactured after March 17, 2026.

To meet the compliance requirements, manufacturers and suppliers are required to conduct supply chain due diligence, submit Declarations of Conformity, and retain compliance documentation for up to ten years.

The Compliance Challenge for OEMs: A Race to 2027

The software-related bans take effect for 2027 model year vehicles, while hardware bans take effect for 2030 models. Since most Model Year 2027 vehicles are already designed, the time to begin auditing supply chains for compliance is now.   

As mentioned earlier, the rule obligates manufacturers to provide a declaration of conformity as well as evidence confirming that no subcomponents of their VCS and ADS software come from China or Russia. So how can OEMs produce the evidence needed to prove that this is the case? 

This brings us to the heart of the challenge. A typical software-defined vehicle (SDV) has between 50-100 ECUs, while each ECU may contain dozens of software libraries from a large number of suppliers. Due to the complexity of the automotive supply chain, OEMs and Tier 1 suppliers are not always aware of the software composition of the components they receive from their downstream suppliers. Moreover, manual audits are impossible in today’s feature-rich SDVs running systems composed of hundreds of millions of lines of code.

In many cases, the prohibited piece of software is going to be buried deep down the supply chain. Similar to software vulnerability scanning (mandatory per UNR 155), OEMs are going to need advanced tools to be able to identify software developed by forbidden entities. Once the problematic component is identified and reported, the OEM can then turn to the supplier and request an updated version or a complete replacement.

How PlaxidityX SSCS Solves the Compliance Gap

Our SW Supply Chain Security (SSCS) product provides OEMs and Tier 1s full lifecycle vulnerability management – from code development to on-the-road fleets. This unified platform combines advanced source code scanning with binary analysis to help vehicle manufacturers manage vulnerabilities in a timely and effective manner. This is crucial for compliance with cybersecurity regulations and standards such as UNR 155, ISO/SAE 21434 and the EU’s CRA.

Often, OEMs don’t have access to the information required to check for vulnerabilities (e.g., SBOM), and suppliers are not legally obliged to deliver “safe” software. This lack of visibility into the software running on dozens of components developed by multiple suppliers makes it extremely difficult for OEMs to ensure that their vehicle software doesn’t contain vulnerabilities. To solve this issue, SSCS automatically extracts Software Bill of Materials (SBOM) from compiled binaries – including AUTOSAR, Linux, and Android – to identify risks in third-party supplier or “black box” components.

To help OEMs and Tier 1s meet the BIS compliance requirements, we have enhanced our SSCS product to scan for prohibited components. This new, powerful feature performs automated SBOM scanning against the BIS Entity List and Consolidated Screening List (CSL). By extracting a complete SBOM from both source code and compiled binaries, SSCS can instantly flag components originating from restricted jurisdictions. This isn’t just about security – it’s about generating the report necessary for the Declarations of Conformity now required for U.S. market entry.

A Global Trend: Europe’s Risk-Based Approach

While the U.S. rule is the most explicit, Europe is following a similar path through a “risk-based” framework rooted in the following regulations:

• EU Cyber Resilience Act (CRA): Mandatory SBOMs and vulnerability reporting are now law, with a focus on “security by design.” Products must be delivered with a “secure by default” configuration, possess no known exploitable vulnerabilities, and limit attack surfaces. In addition, manufacturers must establish policies for coordinated vulnerability disclosure.
• UNR 155/156: These regulations already require OEMs to demonstrate supply chain transparency. 
• Strategic Autonomy: European regulators are increasingly discussing “non-technical risk factors,” similar to the logic used in the 5G “Toolbox,” which could soon restrict high-risk vendors in the automotive sector to prevent digital sabotage.

Supply Chain Transparency Is Your Key to Market Access

Whether you’re targeting the U.S. or European markets, supply chain transparency is rapidly becoming the new “license to operate.” This shift marks a new era where visibility into every software component – down to the deepest layer of the supply chain – is essential for both compliance and safety. Automated, scalable solutions, such as PlaxidityX SSCS, enable manufacturers to move beyond manual audits and toward continuous scanning and evidence-based compliance. In this new geopolitical reality, the ability to prove what’s inside your code may ultimately determine where your vehicles can be sold.