Recently, there has been a lot of talk about the next version of FIPS 140 being based on ISO 19790:2012. The CMVP has even added a section to its website to address its consideration. At first glance, the differences between FIPS 140-2 and ISO 19790:2012 may not seem too bad. However, in doing a deep dive into the requirements, one finds that there are numerous changes that will directly affect every cryptographic module that has ever been validated. If vendors are caught off guard, it will be very painful to complete their next FIPS 140 validation after the transition.
For many vendors, it makes sense to consider getting a head start into integrating the new functionality required by ISP 19790:2012. However, the transition plan is not finalized (the CMVP could potentially even go a completely different direction) and it would not be prudent to completely overhaul code and design to meet the ISO requirements. There are, however, several requirements that could be considered not only because they will be required, but, they are also just good security practices. Here are a few suggestions a product vendor may wish to consider to get a head start on an ISO 19790:2012 based FIPS 140-Next.
- Password Complexity Requirements: FIPS 140-2 allows any password complexity requirement to be enforced procedurally. This will NOT be the case moving forward. Now is the time to add minimum complexity rules to your software. At minimum, even if it does not become part of FIPS 140-Next, you will prevent the dreaded one-character password. As an added bonus, this may also help with other certifications you are interested in, such as, NIAP NDPP Common Criteria evaluation.
- Default Authentication Data: If you provide default authentication data to initially access your product, ISO 19790:2012 requires that these credentials be changed after first usage. Default credentials are one of the more common ways a system in operation is compromised. Requiring the user to change these credentials will not only be necessary to validate against FIPS 140-Next but is a good security practice.
- Automated Security Diagnostic Testing: ISO 19790:2012 requires that any software/firmware in a product be run through automated testing (such as, static analysis). If you are not already performing that type of testing, now is a good time to start. Not only will you be meeting the new validation requirements, but, you may just identify and prevent a vulnerability from getting out into the field.
The list above only touches on a couple of the differences between FIPS 140-2 and ISO 19790:2012. There are a number of other differences that will directly affect product vendors’ development plans. Acumen Security has performed a detailed analysis between the two standard and put together an easily consumable white paper providing a high-level description of the differences between FIPS 140-2 and ISO 19790:2012 and some recommendations to help make the transition easier. Check out “FIPS 140-Next is coming: What does it mean and what are you going to do?,” give us a call, or drop us a note. We’d love to help you understand what this transition would mean to you and how you can minimize its impact.