Signal, Messaging, and Compliance: A Deep Dive into Compliance with HIPAA, FedRAMP, and Broader Security

Michael Peters

3 weeks ago

End-to-end encrypted messaging apps like Signal have gained widespread traction in the news (for better or worse). The app is widely praised for its robust encryption model, minimal data collection, and open-source transparency, and journalists, activists, and security-conscious executives have turned to Signal as a trusted tool for secure communication.

But while Signal excels in privacy, does it meet the requirements for regulated industries like healthcare, government contracting, or critical infrastructure?

This article will explore whether Signal is an appropriate tool for organizations operating under major compliance frameworks such as HIPAA, FedRAMP, CMMC, CJIS, and others. The analysis is aimed at IT professionals, CISOs, compliance officers, and decision-makers evaluating communication tools in high-assurance environments.

What Is Signal?

Signal is a free, open-source messaging platform that uses the Signal Protocol for end-to-end encryption. It supports text messaging, video, and voice chats, as well as file sharing.

It’s designed to minimize metadata collection and not store message contents, contact graphs, or even logs of who communicates with whom. Governed by the Signal non-profit organization, its codebase is fully open-source, meaning it can be reviewed, audited, and even forked by the community.

Signal and Compliance Frameworks

While Signal is secure, security is not the same as compliance. Most regulatory frameworks require not just encryption but also:

Data retention and logging controls
User and role-based access management
Auditability and incident response
Formal certifications or third-party assessments
Legal agreements like BAAs or SLAs

These are enterprise and legal controls that go beyond technical security. Let’s examine how Signal performs against each significant framework.

So, with that in mind, is Signal appropriate to use as part of a compliance strategy in some of the major frameworks?

HIPAA: Not Compliant

HIPAA governs how healthcare providers and their partners handle Protected Health Information (PHI). The Security Rule provides relatively stringent requirements for any messaging or data-sharing platform holding or transmitting PHI.

To be HIPAA-compliant, a messaging tool must:

Offer a Business Associate Agreement (BAA)
Enforce access controls
Provide audit logging
Support data breach notifications
Allow for message archival (in many cases)

So, somewhat unsurprisingly, Signal does not meet HIPAA requirements (nor does it claim to). Primarily, it fails in that it has:

No BAA available
No centralized user or role management
No audit trail or logging features
No message archival or administrative access

So, while Signal encrypts everything, it doesn’t provide the required administrative or operational controls to be used legally for PHI. An organization or individual using the app to transmit protected healthcare information does so in violation of the standard.

FedRAMP: Not Authorized

FedRAMP is the gold standard for cloud service security in the U.S. federal government. It’s based on NIST SP 800-53 controls and comes in Low, Moderate, and High baselines, with each tier requiring more robust security controls. As such, software needs to incorporate a ton of technical and administrative “must haves” before it can be authorized… and, to be used by federal agencies, the software MUST be Authorized.

To work with federal agencies, cloud providers must:

Be assessed by a 3PAO (Third-Party Assessment Organization).
Receive an Authorization to Operate (ATO) from an agency or the Joint Authorization Board (JAB).
Maintain continuous monitoring, reporting, and incident response.

So, unsurprisingly, Signal fails on most of these criteria:

No FedRAMP ATO
No public 3PAO assessments
No infrastructure for continuous monitoring or auditability
Doesn’t integrate with federal identity/access systems

Also, FedRAMP is as much about transparency, traceability, and operations as it is about encryption. Signal, by design, avoids persistent data and metadata, ironically making it unsuitable for environments that require oversight and logs.

CMMC: Not Suitable

CMMC governs data protection for Controlled Unclassified Information (CUI) within systems serving the Department of Defense and related institutions in the Executive Branch. It has several specific security criteria based on NIST 800-171 and other sources, which include:

Access controls and role separation
Continuous monitoring and auditing
Multifactor authentication
Data integrity and availability protections

Like the others, Signal fails at specific control implementations that would otherwise be required to comply with CMMC requirements:

No user or role-based access control at the admin level
No way to retain, monitor, or audit messages
No logs of data access or deletion
Not designed for ITAR or DFARS flow-down clauses

Even if used within a secure enclave, Signal doesn’t offer the administrative hooks or reporting mechanisms required to show compliance during a DoD audit.

CJIS: Not Validated

The Criminal Justice Information Services (CJIS) standard is an FBI framework that governs how law enforcement agencies handle Criminal Justice Information (CJI).

While CJIS does not have a central authorization process like FedRAMP, it does require:

Advanced encryption standards
Personnel background checks
Two-factor authentication
Physical and network protections
Compliance with FBI and local CJIS Security Policies

In a clear trend, Signal does not meet the minimum requirements needed to handle CJI:

No centralized compliance validation
No documentation or certifications are accepted by state or local CJIS offices
No physical/logical separation of CJI
No administrative controls or logging

Some officers and agents use Signal informally, but official CJI systems require far more rigor than what Signal provides.

Can Signal Fit in a Secure Enterprise?

Despite not meeting formal compliance requirements, Signal can still be a valuable tool in specific business or IT environments:

Internal communication for non-regulated, privacy-conscious teams where sensitive, regulated information was not involved.
Secure messaging between executives or journalists who look to protect sources or unfold new stories.
Personal communication between employees that does not involve company or regulated data.
Organizations need confidential but informal discussion channels to protect industrial secrets.

Many CISOs advocate using Signal alongside compliant systems as a redundant or parallel layer of secure communication, particularly in sensitive or crisis scenarios.

Compliant Alternatives to Signal

If your organization must meet regulatory requirements, consider these Signal-like alternatives with enterprise and compliance controls:

Platform	Compliance Support
Microsoft Teams (Gov)	FedRAMP Moderate, HIPAA, CMMC
Zoom for Government	FedRAMP, HIPAA, CJIS (case-by-case)
Wickr Enterprise (AWS)	FedRAMP High, CJIS
Symphony	FINRA, SOC 2, HIPAA
SignalWire Work	SOC 2, HIPAA available

Understand the Difference Between Secure and Compliant with Continuum GRC

Signal is arguably one of the most secure messaging apps in the world, but it’s not designed for enterprise compliance. For organizations operating under frameworks like HIPAA, FedRAMP, or CMMC, adopting Signal without proper due diligence could expose them to audit failures, fines, or legal risks.

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 cybersecurity® 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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