by Michael Peters
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FedRAMP and Encryption

A critical component of the FedRAMP framework is its adherence to cryptographic standards, specifically the Federal Information Processing Standard (FIPS) 140-3. Data privacy is essential to compliance, and the National Institute of Standards and Technology has clearly defined the requirements for just how a FedRAMP-compliance organization encrypts its data. 

This article will cover those requirements and how to approach them in your organization.

 

FIPS 140-3 and the Evolution of Federal Encryption

FIPS 140-3 (“Security Requirements for Cryptographic Modules“) is a U.S. government standard that outlines the security requirements for cryptographic modules protecting sensitive information. Approved on March 22, 2019, FIPS 140-3 supersedes its predecessor, FIPS 140-2, aligning more closely with international standards such as ISO/IEC 19790:2012. This alignment facilitates a more unified global approach to cryptographic security. 

FIPS 140-3 aligns with the international standard ISO/IEC 19790:2012, ensuring global consistency in cryptographic security requirements. The standard specifies four ascending levels of security, each designed to address a broad spectrum of applications and environments.

Within the FedRAMP framework, federal agencies must utilize cryptographic modules validated by the National Institute of Standards and Technology’s (NIST) Cryptographic Algorithm Validation Program (CAVP) as compliant with FIPS 140-3. This requirement ensures that the cryptographic solutions are robust and have undergone rigorous testing. The validation process encompasses various aspects, including the module’s design, implementation, and operational environment, to confirm its effectiveness in protecting federal information systems.

Balancing Security Patching and FIPS Validation

A significant challenge in maintaining FIPS-validated cryptographic modules is applying security patches promptly. Historically, updating a cryptographic module could invalidate its FIPS certification, as even minor changes necessitate re-validation, which can be time-consuming and resource-intensive. This predicament often placed organizations in a difficult position: choosing between running outdated yet validated modules with known vulnerabilities or applying patches that would render the module non-compliant.

Recognizing this dilemma, FedRAMP’s “Policy for Cryptographic Module Selection and Use,” published on January 16, 2025, offers a pragmatic approach. The policy emphasizes a risk-based strategy, prioritizing the remediation of known vulnerabilities through timely patches over the strict maintenance of FIPS validation status. This shift acknowledges that the security risks posed by unpatched vulnerabilities often outweigh the assurance provided by validation. Consequently, cloud service providers (CSPs) are encouraged to apply necessary updates to cryptographic modules, even if it temporarily affects their validation status, provided efforts are made to revalidate the updated modules promptly.

Navigating Update Streams and Validation Module Streams

FedRAMP encryption

The policy introduces two distinct approaches for managing cryptographic modules:

  • Update Streams: This approach involves applying the latest patches and updates to software, regardless of the modified software’s FIPS validation status. It prioritizes security by ensuring that known vulnerabilities are addressed promptly. CSPs adopting this approach must document their preference for update streams in their System Security Plan (SSP), specifically in Appendix A, SI-2 Implementation Statement. Additionally, they must retain artifacts demonstrating that updated major versions of cryptographic modules are submitted to the Cryptographic Module Validation Program (CMVP) within six months of release.
  • Validation Module Streams: This approach uses only FIPS-validated patches and updates, even if more recent, unvalidated patches are available. While this ensures continuous compliance with FIPS validation, if the update validation process is delayed, it may result in prolonged exposure to known vulnerabilities.

FedRAMP’s policy generally favors the update stream approach, advocating for the prompt application of security patches to mitigate risks associated with known vulnerabilities. However, CSPs must carefully assess their specific operational contexts and regulatory requirements to determine the most appropriate strategy.

 

Documentation and Compliance Requirements

Adherence to FedRAMP’s cryptographic module policy necessitates meticulous documentation and compliance efforts:

  • System Security Plan (SSP) Updates: CSPs must clearly articulate their chosen approach (update stream or validation module stream) within their SSP. This includes detailing the processes for applying updates, managing validation statuses, and ensuring continuous protection of federal information.
  • Appendix Q Documentation: For cryptographic modules inherited from a FedRAMP-authorized service, CSPs must document the cryptographic use cases, module names, and version numbers in Appendix Q of their SSP. This ensures transparency and traceability of the cryptographic components in use.
  • Artifact Retention: When adopting the update stream approach, CSPs must retain evidence that updated major versions of cryptographic modules have been submitted to the CMVP within the stipulated six-month timeframe. This documentation is crucial for demonstrating compliance during audits and assessments.

Collaborative Efforts and Continuous Improvement

Developing FedRAMP’s cryptographic module policy involved collaborating with stakeholders, including NIST and the FedRAMP Technical Advisory Group. This collaborative approach ensures the policy is comprehensive, addressing CSPs’ practical challenges while maintaining robust security standards. Moreover, FedRAMP actively seeks feedback from the public and industry experts to continually refine and enhance its guidelines. This iterative process fosters a dynamic security environment that adapts to emerging threats and technological advancements.

Make Sure Your Encryption is FedRAMP-Ready with Continuum GRC

Selecting and managing cryptographic modules within the FedRAMP framework requires a nuanced understanding of security imperatives and compliance obligations. By thoughtfully navigating the options of update and validation module streams and adhering to rigorous documentation practices, organizations can effectively protect federal information systems in an ever-evolving threat landscape.

Protecting CUI in hybrid cloud systems demands a proactive, multifaceted encryption strategy. Organizations can mitigate risks by classifying data, enforcing encryption at all lifecycle stages, rigorously managing keys, and integrating zero-trust principles while leveraging hybrid cloud benefits. 

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance). 

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.

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