FIPS 140-2 vs FIPS 140-3

What is FIPS 140 

FIPS 140 (Federal Information Processing Standard 140) is a U.S. government standard that defines the security requirements for cryptographic modules—hardware, software, or firmware—that protect sensitive information. Published by NIST, it ensures that cryptographic products meet rigorous criteria for secure design, implementation, and operation. Organizations use FIPS 140-validated modules to comply with federal regulations and industry standards, helping guarantee trust in encryption, key management, and authentication systems. 

What are HSMs

A Hardware Security Module (HSM) is a dedicated, tamper-resistant device designed to generate, protect, and manage cryptographic keys. It performs secure operations like encryption, decryption, digital signing, and authentication while ensuring that private keys never leave the protected hardware. HSMs are widely used to safeguard sensitive data, secure transactions, and maintain compliance with standards such as FIPS 140-2 or FIPS 140-3.

FIPS 140 and Hardware Security Modules (HSMs)

Scope of Modules 

• FIPS 140-2 was originally scoped primarily around hardware cryptographic modules, though later Information Guides allowed some hybrid or software implementations 
• FIPS 140-3 explicitly expands the category to include hardware, firmware, software, hybrid software, and hybrid firmware modules—offering much greater flexibility and modern applicability.

Security Assurance Enhancements
FIPS 140-3 introduces enhanced criteria, such as:

• Stricter tamper-evident coatings, improved resistance to probing, and enclosure protections against physical penetration, especially for Level 3 modules.
• Requirement to actively destroy sensitive security parameters (like private keys) if tampering is detected, especially at Level 4.
• Enhanced lifecycle controls for software and firmware components, including version tracking, developer testing, and automated diagnostics.

Post-Quantum Cryptography (PQC) 

• Explicit Support in FIPS 140-3
  While FIPS 140-3 itself doesn’t define PQC algorithms, it is the only standard under which PQC algorithms can be validated. Modules aiming to support PQC (e.g., adhering to SP 800208) must be certified under FIPS 140-3.
• No PQC Path in FIPS 140-2
  FIPS 140-2 does not accommodate PQC algorithms; any module wishing to incorporate PQC must transition to FIPS 140-3. 

Multi-Factor Authentication (MFA) 

Role and Authentication Model Changes 

• FIPS 140-2 required support for roles like Operator, Maintenance, or Crypto Officer, but allowed procedural enforcement of some access controls.
• FIPS 140-3 mandates only the Crypto Officer role; multi-factor, identity-based authentication is required, especially when using a trusted channel instead of the earlier “trusted path” model.
• Trusted Channel Enhancements
  FIPS 140-3 replaces the older “trusted path” communication approach with a stronger trusted channel, requiring authenticated, multi-factor interactions between the module and the endpoint.

Multi-Tenancy

• Although neither standard explicitly calls out “multitenancy,” FIPS 140-3’s broader scope—supporting hybrid and software-based modules—makes it better suited for modern cloud and virtualized, multi-tenant environments.
• FIPS 140-2’s hardware-centric design is inherently less flexible, limiting reusable certification in multitenant or virtualized system deployments. 

FIPS 140-2 Retirement Timeline & Transition

• Official Retirement Date
  All FIPS 140-2 certificates will be placed on the Historical List by September 21, 2026, and will no longer be considered valid for new module acquisitions or validations.
• Transition Guidelines 
• • FIPS 140-3 became effective on September 22, 2019, with testing accepted starting September 22, 2020.
  • FIPS 140-2 testing ended for new submissions by April 1, 2022, although ongoing reports in queue were still honored.

This means that while modules validated under FIPS 140-2 remain usable for existing deployments, any new implementations or updates must comply with FIPS 140-3. 

Summary Table