Security Technology Group

Computer Security Division

National Institute of Standards and Technology

Gaithersburg, MD 20899-8930

June, 2001

U.S. Department of Commerce

Donald L. Evans, Secretary

Technology Administration

National Institute of Standards and Technology

Karen H. Brown, Acting Director

A COMPARISON OF THE SECURITY REQUIREMENTS

Ray Snouffer

Arch Oldehoeft

FOR CRYPTOGRAPHIC MODULES

IN

FIPS 140-1 AND FIPS 140-2

Annabelle Lee

NIST Special Publication 800-29
FIPS 140-1&2 Differences 

i 

TABLE OF CONTENTS 

1. THE CRYPTOGRAPHIC MODULE VALIDATION PROGRAM AND FIPS 140-2 ................... 1 

2. SUMMARY OF DIFFERENCES BETWEEN FIPS 140-1 AND FIPS 140-2 ............................ 3 

2.1. Security Requirements...................................................................................................... 4 

2.1.1. Cryptographic Module Specification .......................................................................... 4 

2.1.2. Cryptographic Module Ports and Interfaces .............................................................. 4 

2.1.3. Roles, Services, and Authentication .......................................................................... 4 

2.1.4. Finite State Model...................................................................................................... 4 

2.1.5. Physical Security........................................................................................................ 5 

2.1.6. Operational Environment ........................................................................................... 5 

2.1.7. Cryptographic Key Management ............................................................................... 5 

2.1.8. Electromagnetic Interference/ Electromagnetic Compatibility (EMI/EMC) ................ 5 

2.1.9. Self-Tests................................................................................................................... 6 

2.1.10. Design Assurance...................................................................................................... 6

2.1.11. Mitigation of Other Attacks......................................................................................... 6 

2.1.12. Appendixes ................................................................................................................ 7 

3. DETAILED DIFFERENCES BETWEEN FIPS 140-1 AND FIPS 140-2 ................................... 8 

3.1. Documentation Requirements........................................................................................... 8 

3.2. Noteworthy Differences in Terminology............................................................................ 8 

3.3. Differences in Specific Security Requirement Areas ........................................................ 8 

3.3.1. Cryptographic Module Specification .......................................................................... 8 

3.3.2. Cryptographic Module Ports and Interfaces ............................................................ 10 

3.3.3. Roles, Services, and Authentication ........................................................................ 11 

3.3.4. Finite State Model.................................................................................................... 12

3.3.5. Physical Security...................................................................................................... 13 

3.3.6. Operational Environment ......................................................................................... 13 

3.3.7. Cryptographic Key Management ............................................................................. 18 

3.3.8. Electromagnetic Interference/Electromagnetic Compatibility (EMI/EMC) ............... 20 

3.3.9. Self-Tests................................................................................................................. 21 

3.3.10. Design Assurance.................................................................................................... 23 

3.3.11. Mitigation of Other Attacks....................................................................................... 25 

4. DIFFERENCES IN APPENDIXES ......................................................................................... 26 

5. ANNEXES TO THE STANDARD ........................................................................................... 27 
FIPS 140-1&2 Differences 

1 

1. THE CRYPTOGRAPHIC MODULE VALIDATION PROGRAM 

AND FIPS 140-2 

Federal agencies, industry, and the public now rely on cryptography to protect information and 

communications used in critical infrastructures, electronic commerce, and other application areas. 

Cryptographic modules are implemented in these products and systems to provide cryptographic 

services such as confidentiality, integrity, non-repudiation and identification and authentication. 

Adequate testing and validation of the cryptographic module against established standards is 

essential for security assurance. Both Federal agencies and the public benefit from the use of 

tested and validated products. Without adequate testing, weaknesses such as poor design, weak 

algorithms, or incorrect implementation of the cryptographic module, can result in insecure 

products. 

On July 17, 1995, NIST established the Cryptographic Module Validation Program (CMVP) that 

validates cryptographic modules to Federal Information Processing Standard (FIPS) 140-1 

Security Requirements for Cryptographic Modules, and other FIPS cryptography based 

standards. The CMVP is a joint effort between NIST and the Communications Security 

Establishment (CSE) of the Government of Canada. Products validated as conforming to FIPS 

140-1 are accepted by the Federal agencies of both countries for the protection of sensitive 

information. Vendors of cryptographic modules use independent, accredited testing laboratories 

to test their modules. NIST’s Computer Security Division and CSE jointly serve as the validation 

authorities for the program, validating the test results. Currently, there are several National 

Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratories that perform FIPS 

140-1 compliance testing. These labs are listed at the web site: http://csrc.nist.gov/cryptval. As 

of January 2001 over 150 cryptographic modules from more than forty separate vendors have 

been validated through the program. The number of validated modules has nearly doubled each 

year of the program’s existence. 

The underlying philosophy of the CMVP is that the user community needs strong independently 

tested and commercially available cryptographic products. The CMVP must also work with the 

commercial sector and the cryptographic community to achieve security, interoperability and 

assurance. Directly associated with this philosophy is the goal of the CMVP to promote the use 

of validated products and provide Federal agencies with a security metric to use in procuring 

cryptographic modules. The testing performed by accredited laboratories provides this metric. 

Federal agencies, industry, and the public can choose products from the CMVP Validated 

Modules List and have confidence that the products meet the claimed level of security. The 

program validates a wide variety of modules including general encryption products, secure radios, 

Virtual Private Network (VPN) devices, Internet browsers, cryptographic tokens and modules that 

support Public Key Infrastructure (PKI). Currently, validation services are provided for FIPS 140-1 

& 2, the Data Encryption Standard (DES and Triple DES), the Digital Signature Standard, the 

Secure Hash Standard, and the Skipjack Algorithm. 

The CMVP offers a documented methodology for conformance testing through a defined set of 

security requirements in FIPS 140-1&2 and other cryptographic standards. NIST developed the 

standard and an associated metric (the Derived Test Requirements for FIPS 140-1) to ensure 

repeatability of tests and equivalency in results across the testing laboratories. The five 

commercial laboratories provide vendors of cryptographic modules a choice of testing facilities 

and promotes healthy competition. (Note, there is no limit to the number of testing laboratories, 

and additional testing laboratories may be added to the program.) 

A government and industry working group composed of both users and vendors developed FIPS 

140-1. The working group identified eleven areas of security requirements with four increasing 

levels of security for cryptographic modules. The security levels allow for a wide spectrum of data 

sensitivity (e.g., low value administrative data, million dollar funds transfers, and health data), and 
FIPS 140-1&2 Differences 

2 

a diversity of application environments (e.g., a guarded facility, an office, and a completely 

unprotected location). Each security level offers an increase in security over the preceding level. 

These four security levels allow cost-effective solutions that are appropriate for different degrees 

of data sensitivity and different application environments. This structure also allows great 

flexibility when specifying or identifying users needs. Modules may meet different levels in the 

security requirements areas (e.g., a module meets level 2 overall, level 3 physical security with 

additional level 4 requirements). The Validated Modules list now contains modules representing 

all four security levels. 

FIPS 140-1&2 define a framework and methodology for NIST's current and future cryptographic 

standards. The standard provides users with: 

• a specification of security features that are required at each of four security levels; 

• flexibility in choosing security requirements; 

• a guide to ensuring the cryptographic modules incorporate necessary security features; 

and 

• the assurance that the modules are compliant with cryptography based standards. 

The Secretary of Commerce has made FIPS 140-1 mandatory and binding for U.S. Federal 

agencies and organizations. The standard is specifically applicable when a Federal agency 

determines that cryptography is necessary for protecting sensitive information. The standard is 

used in designing and implementing cryptographic modules that Federal departments and 

agencies operate or are operated for them. FIPS 140-1 is applicable if the module is 

incorporated in a product, application or functions as a standalone device. 

From the beginning, the CMVP has been dynamic with a constant reexamination of the 

underlying standard, test methodology, reporting structure, and associated documentation. In 

addition, questions from the vendor and user communities have provided valuable input and an 

implementation perspective. NIST and CSE have continually kept pace with new security 

methods, changes in technology, and required interpretations of the standard by issuing official 

Implementation Guidance and Policy for FIPS 140-1 and associated Derived Test Requirements

(DTR). The Implementation Guidance covers program policy, technical questions, and general 

guidance needed for module validation. 

In addition to constant reexamination, the standard is officially reexamined and reaffirmed every 

five years. In the fall of 1998, FIPS 140-1 entered a regularly scheduled 5-year review to 

consider new and/or revised requirements needed to meet technological and economic change. 

A request for comments on FIPS 140-1 was published on October 23, 1998 in the Federal 

Register. The official comment period for the request closed January 21, 1999. A revised draft 

standard was produced based on the public comments received, previously issued 

implementation guidance and a "line by line" review by the NIST, CSE, and testing laboratory 

staff. A second request for comments on the resulting FIPS 140-2 draft was published on 

November 17, 1999 in the Federal Register with a closing date of February 15, 2000. In 

December 2000, the FIPS 140-1 update to FIPS 140-2 was completed. The implementation 

schedule for FIPS 140-2 begins with the approval date or date of signature. The effective date is 

six months after the approval date and marks the beginning of a six month transition period. This 

transition period enables agencies to develop acquisition plans for procuring FIPS 140-2 

compliant modules. At the end of the transition period, modules will no longer be tested against 

FIPS 140-1. (Note: all FIPS 140-1 testing labs will become FIPS 140-2 testing labs.) However, 

FIPS 140-1 validated modules may continue to be procured. This paper gives an overview of the 

substantive differences between FIPS 140-1 and FIPS 140-2. 

Section 2 of this document provides a summary analysis of the changes between FIPS 140-1 and 

140-2. Section 3 of this document includes the specific requirements documented in FIPS 140-2 

and the previous versions specified in FIPS 140-1. The FIPS 140-2 requirements are displayed 

in a box for easy reference. 
FIPS 140-1&2 Differences 

3 

2. SUMMARY OF DIFFERENCES BETWEEN FIPS 140-1 AND FIPS 

140-2 

FIPS 140-1 is one of NIST’s most successful standards and forms the very foundation of the 

CMVP. FIPS 140-1 is widely recognized as the “defacto” standard for cryptographic modules and 

is referenced and/or used in its entirety by numerous standards bodies and international testing 

organizations. Therefore, great care was given to the update process beginning with a complete 

“line by line” review and examination of the standard and all Implementation Guidance issued 

during FIPS 140-1’s initial five years. The underlying question asked by the authors of FIPS 140-

2 was “how does one improve a successful and proven standard?” The answer was simple – 

include lessons learned from questions and comments, reflect changes in technology, and 

strengthen the standard, but do not change the focus or emphasis. The authors also took the 

opportunity to improve the format of the standard by minimally restructuring the content (see the 

table below), standardizing the language and terminology to add clarity and consistency, 

removing redundant and extraneous information to make the standard more concise, and revising 

or removing vague requirements. Looking to the future, the authors added a section detailing 

new types of attacks on cryptographic modules that currently do not have specific testing 

available. The end result is a stronger, more concise, and readable standard that still embodies 

the spirit of the original standard. 

Tables of Content 

FIPS 140-1 FIPS 140-2 

1. Overview 1. Overview 

2. Glossary of Terms and Acronyms 2. Glossary of Terms and Acronyms* 

3. Functional Security Requirements 3. Functional Security Requirements 

4. Security Requirements 4. Security Requirements 

 4.1 Cryptographic Modules 4.1 Cryptographic Module Specification* 

 4.2 Cryptographic Module Interfaces 4.2 Cryptographic Module Ports and 

Interfaces 

 4.3 Roles and Services 4.3 Roles, Services, and Authentication* 

 4.4 Finite State Machine Model 4.4 Finite State Model 

 4.5 Physical Security 4.5 Physical Security* 

 4.6 Software Security 4.6 Operational Environment* 

 4.7 Operating System Security 4.7 Cryptographic Key Management 

 4.8 Cryptographic Key Management 4.8 EMI/EMC 

 4.9 Cryptographic Algorithms 4.9 Self-Tests* 

 4.10 EMI/EMC 4.10 Design Assurance* 

 4.11 Self-Tests 4.11 Mitigation of Other Attacks* 

Appendixes Appendixes 

A: Summary of Documentation 

Requirements 

A: Summary of Documentation 

Requirements 

B: Recommended Software Development 

 Practices 

 B: Recommended Software Development 

Practices* 

C: Selected References C: Cryptographic Module Security Policy* 

 D: Selected Bibliography* 

 * Section added or significantly revised. 
FIPS 140-1&2 Differences 

4 

The following provides a brief discussion of each of the requirements areas and summary of the 

major changes. 

2.1. Security Requirements 

This section summarizes the changes from FIPS 140-1 to FIPS 140-2. 

2.1.1. Cryptographic Module Specification 

This section defines those requirements for identifying and establishing the cryptographic 

boundary of the module. This includes the specification of the hardware, software, and/or 

firmware; the module interfaces; manual or logical controls; identification of the implemented 

algorithms and modes of operation; and the module’s security policy. 

The primary modification to this section is the inclusion of the approved cryptographic algorithms 

and security functions. FIPS 140-1 separated the algorithm identification into a short standalone 

section. However, given that the cryptographic algorithm is the basis of the module, inclusion of 

the algorithm specification in the first section of FIPS 140-2 was a logical restructuring. 

2.1.2. Cryptographic Module Ports and Interfaces 

This section defines the requirements used to restrict information flow and physical access to the 

logical interfaces for all entry and exit points both internal and external to the module. The 

standard defines four specific logical interfaces including data input, data output, control input, 

and status output, and the associated requirements by security level. 

The major change in this section involves the underlying requirement for plaintext input/output 

(I/O) to be separated from other types of I/O. FIPS 140-1 met this requirement by specifying the 

use of physically separate ports beginning at security level 3 for plaintext I/O. Due to changes in 

technology (e.g., timing separation, dedicated threads, multiplexing, etc.), the standard now 

allows both physically separate ports and logical separation within existing physical ports via 

trusted path.

2.1.3. Roles, Services, and Authentication 

This section is divided into three subsections covering the requirements for the authorized 

operator roles; services, functions and operations provided by the module; and the authentication 

needed to obtain these services. 

The major modification to this section is the addition of strength of mechanism requirements for 

authentication. This represents a strengthening of the standard and the first time the concept of 

strength of mechanism has been specified. These new requirements address minimum 

probabilities for guessing authentication data (e.g., pins, passwords, etc.), false acceptance error 

rates and restrictions placed on the feedback of authentication data to the user.

2.1.4. Finite State Model 

This section specifies the underlying design requirements for the identification and specification of 

the module’s operational and error states and associated transitions between states. The name 

of this section was changed from Finite State Machine (FSM) to Finite State Model to more 

accurately reflect the requirements. FIPS 140-1 mandated the use of an FSM Model in the 

module’s design. The FSM is often associated with hardware design and development. To better 

represent both hardware and software modules, this section now includes the concept of utilizing 

a Finite State Model or an equivalent design methodology. 
FIPS 140-1&2 Differences 

5 

2.1.5. Physical Security

This section details all of the requirements surrounding the physical security of the cryptographic 

module. Cryptographic modules are separated into three different embodiment categories: single 

chip, multi-chip embedded, and multi-chip standalone. 

The majority of changes to this section involve a re-organization of the sub-sections that define 

the requirements for the three different module embodiments. FIPS 140-1 was structured with a 

separate section of requirements for each of three module embodiments, plus a subsection 

detailing the Environmental Failure Protection (EFP)/Environmental Failure Testing (EFT) 

requirements for security level 4. For consistency and clarity, FIPS 140-2 moves all of the 

redundant requirements from the three embodiments into a general section defining requirements 

applicable to all. The requirements that are unique to each of the embodiments follow the 

general section concluding with EFP/EFT. In addition to the restructuring, new requirements 

were added for single chip and multi-chip embedded modules to allow the use of physical 

enclosures for the protection of the module. 

2.1.6. Operational Environment 

This section details the requirement specific to modules where an operator can load and execute 

software or firmware that was not included as part of the module validation. An example of a 

cryptographic module for which the operational environment requirements apply is a generalpurpose computer running cryptographic software as well as untrusted user-supplied software 

(e.g., a spreadsheet or word processing program). In this case, the hardware, operating system, 

and cryptographic software are considered part of the module. FIPS 140-2 relies on an evaluated 

operating system to mitigate part of the security concerns over “Trojan Horse” attacks, where the 

user-supplied software or firmware can access, obtain, or corrupt the module’s critical security 

parameters (e.g., cryptographic keys, passwords, etc.). 

The major modification to this section was the replacement of criteria for evaluating operating 

systems. FIPS 140-1 required evaluated operating systems that referenced the Trusted 

Computer System Evaluation Criteria (TCSEC) classes C2, B1 and B2. The TCSEC is no longer 

in use and has been replaced by the Common Criteria. Consequently, FIPS 140-2 now 

references the Common Criteria for Information Technology Security Evaluation (CC), ISO/IEC 

15408:1999. 

2.1.7. Cryptographic Key Management 

This section contains the security requirements for cryptographic key management that 

encompasses the entire lifecycle of the cryptographic keys used by a cryptographic module. This 

includes random number generation, key generation, establishment, entry/output, storage, and 

zeroization. The requirements are applicable to modules that implement secret key and/or public 

key algorithms. 

The major modification to this section was the addition of requirements for Over-The-AirRekeying (OTAR) for radio communication modules. Other modifications included: clarification of 

the deterministic and nondeterministic random number generators (RNGs) sub-section to allow 

RNGs approved for classified processing for use in key generation; addition of strength of 

mechanism requirements in the Key Establishment subsection; and the deletion of the Key 

Archive sub-section. 

2.1.8. Electromagnetic Interference/ Electromagnetic Compatibility (EMI/EMC) 

This section specifies the Federal Communications Commission (FCC) requirements applicable 

to cryptographic modules. These requirements are specific to the module’s ability to operate in a 
FIPS 140-1&2 Differences 

6 

manner that does not interfere electromagnetically with other devices. Requirements necessary 

to mitigate cryptographic attacks based on electromagnetic emanations (TEMPEST) are not 

included in this section. The Mitigation of Other Attacks section of the standard contains the 

requirements related to TEMPEST attacks. 

During the update process, the EMI/EMC section was modified to reflect minor changes in FCC 

requirements and references. 

2.1.9. Self-Tests 

This section provides the requirements necessary to ensure that the module is functioning 

properly. Self-testing is required at both module power-up and when specific conditions are met. 

These tests include public/private key generation, software/firmware loading, manual key entry, 

random number generation, and cryptographic bypass (plaintext in, plaintext out). 

The update to the standard resulted in no dramatic change in scope or format for self-test 

requirements; however, previously issued guidance was included. The major changes in the 

Self-Test section were strengthening the required tests and better addressing the bypass mode of 

operation. To strengthen the requirements, the new standard now mandates all four statistical 

random number generator tests. FIPS 140-1 only required one of the four. Further, the statistical 

limits for passing these tests were tightened to provided additional assurance for random number 

generation. Public comments recommended that the Self-Test section better address modules 

(i.e., routers) that are designed to automatically switch between bypass and secure mode 

(plaintext in, ciphertext out). This was accomplished by including requirements specific to the 

secure operation of the module during the switch between modes. These new requirements 

facilitate the underlying requirement of fail-secure, where plaintext information is not released 

inadvertently. In addition, FIPS 140-1 tested bypass capabilities only at module power-up. The 

new standard moves bypass to the conditional testing area. 

2.1.10. Design Assurance 

The Design Assurance section, which was formerly Software Security in FIPS 140-1, defines the 

requirements for configuration management, delivery and operation, development and guidance 

documents. The intent of this section is to provide security assurance from design and 

development of the module through delivery and initial start-up. 

Originally this section only specified requirements for software, but to provide greater security 

assurance the section has now been expanded to address software, hardware, and firmware. 

Though the entire section was re-written, the consolidated design assurance requirements found 

in FIPS 140-1 forms the base. These requirements included reviews of source code, functional 

specifications, and formal modeling. Requirements new to the standard include configuration 

management, correct delivery and start-up, and mandatory guidance documents for users and 

cryptographic officers. 

2.1.11. Mitigation of Other Attacks 

This section is the first new section of the standard and provides information, recommendations, 

and requirements for several new types of cryptographic attacks. Susceptibility to these attacks 

depends on module type, implementation, and implementation environment. These attacks are 

of particular concern for cryptographic modules implemented in hostile environments or where the 

attackers may be the users of the module. Generally, these types of attacks rely on the analysis 

of information obtained from sources physically external to the module. In all cases, the attacks 

attempt to determine some knowledge about the cryptographic keys and critical security 

parameters (CSPs) contained in the module. This section was developed as a direct result of 

numerous public comments recommending that power analysis, timing analysis, fault induction, 
FIPS 140-1&2 Differences 

7 

and TEMPEST attacks be addressed by FIPS 140-2. Certain types of cryptographic modules 

may be susceptible to these attacks (e.g., tests for power analysis, timing analysis, and fault 

induction), but testable security requirements were not available at the time this standard was 

issued or the attacks were outside of the scope of the standard (e.g., TEMPEST attacks). The 

new standard specifies that if a cryptographic module is designed to mitigate one or more specific 

attacks, then the module’s security policy shall specify the security mechanisms employed by the 

cryptographic module to mitigate the attack(s). The existence of these mechanisms and their 

proper functioning will be validated when requirements and associated tests are developed. Brief 

summaries of currently known attacks are provided in the standard. 

2.1.12. Appendixes 

FIPS 140-1 contains three appendixes, A, B, and D below. Appendix C has been added to FIPS 

140-2. 

A. Summary of Documentation Requirements

 

This section was updated to reflect modifications in the standard. 

B. Recommended Software Development Practices

This section was updated to reflect current practices. 

C. Security Policy

Appendix C specifies the information and structure of the required cryptographic module security 

policy. This document is available by request and often provides the only information users have 

access to prior to purchasing the module. FIPS 140-1 required a security policy, which contained 

the security rules of the module. However, no format or specific content requirements were 

mandated. Therefore cryptographic module security policies submitted by vendors often varied 

greatly in detail and quality. FIPS 140-2 mandates more stringent requirements for both the 

contents of a security policy and the structure. The vendors now must provide information 

concerning the identification and authentication, access control, and physical security 

mechanisms, and any mechanisms implemented for mitigation of other attacks. Two types of 

security policies may exist. A proprietary security policy used by the testing laboratory to perform 

necessary tests and a required non-proprietary version, which is available to public release. 

D. Selected Bibliography

This section was updated to reflect current standards and documents.
FIPS 140-1&2 Differences 

8 

3. DETAILED DIFFERENCES BETWEEN FIPS 140-1 AND FIPS 

140-2 

This section summarizes the documentation and terminology changes and lists the specific 

requirements changes by section of FIPS 140-2. 

3.1. Documentation Requirements 

In all security requirement areas, FIPS 140-2 explicitly specifies requirements for documentation 

by the vendor of a cryptographic module. Some of these documentation requirements are implicit 

in FIPS 140-1 (being made explicit by requirements for conformance testing). In this comparison, 

differences are noted only for those cases where FIPS 140-2 requires documentation that is new 

or is a notable extension of the requirements in FIPS 140-1. 

3.2. Noteworthy Differences in Terminology 

Changes have been made to the terminology so that the Standard may be easily adapted by 

other standards bodies. In particular, in FIPS 140-2, the terms “Approved” (used only in 

capitalized form) and “Approved security functions” are adopted in place of the corresponding 

FIPS 140-1 terms “FIPS-Approved” and “FIPS approved security method.” 

The supporting FIPS 140-2 definitions are: 

Approved: FIPS-Approved and/or NIST-recommended. 

Approved security function: for this standard, a security function (e.g., cryptographic 

algorithm, cryptographic key management technique, or authentication technique) that is 

either 

(a) specified in an Approved standard, 

(b) adopted in an Approved standard and specified either in an appendix of the 

Approved standard or in a document referenced by the Approved standard, or 

(c) specified in the list of Approved security functions. 

Other standards bodies need only to re-define “Approved”, without having to make significant 

changes to the body of the standard. 

FIPS 140-2 is explicit in stating that for purpose of validation a cryptographic module is required 

to implement at least one Approved security function used in an Approved mode of operation: a 

mode of the cryptographic module that employs only Approved security functions (not to be 

confused with a specific mode of an Approved security function, e.g., DES CBC mode). 

(Other algorithms or security functions may also be included for use in non-Approved modes of 

operation in a cryptographic module but will not be tested in the validation process.) 

3.3. Differences in Specific Security Requirement Areas 

This section lists the specific requirements included in FIPS 140-1 and the associated revised (or 

new) requirements included in FIPS 140-2. (Note: the format of the FIPS 140-2 requirements 

included in this document may vary from the standard for ease of reviewing.) 

3.3.1. Cryptographic Module Specification 

The area has been renamed (from Cryptographic Modules in FIPS 140-1 to Cryptographic 

Module Specification in FIPS 140-2) to more accurately reflect the content of the material. 
FIPS 140-1&2 Differences 

9 

The FIPS 140-1 definition of cryptographic module: 

(Levels 1, 2, 3, and 4) “A cryptographic module shall be a set of hardware, software, 

firmware, or some combination thereof, that implements cryptographic logic or processes.” 

has been clarified in FIPS 140-2: 

(Levels 1, 2, 3, and 4) “ A cryptographic module shall be a set of hardware, software, 

firmware, or some combination thereof that implements cryptographic functions or processes, 

including cryptographic algorithms and, optionally, key generation, and is contained within a 

defined cryptographic boundary.” 

The FIPS 140-1 definition of a cryptographic boundary: 

(Levels 1, 2, 3, and 4) “If a cryptographic module contains software or firmware, the 

cryptographic boundary shall be defined such that it contains the processor which executes 

the code.” 

has been clarified in FIPS 140-2: 

(Levels 1, 2, 3, and 4) “If A cryptographic boundary shall consist of an explicitly defined 

perimeter that establishes the physical bounds of a cryptographic module.” 

The contents of the FIPS 140-1 Section entitled “Cryptographic Algorithms,” consisting of the 

single statement: 

(Levels 1, 2, 3, and 4) “Cryptographic modules shall employ FIPS-approved cryptographic 

algorithms.” 

has been subsumed by this section of FIPS 140-2 in the following requirements: 

(Levels 1, 2, 3, and 4) “A cryptographic module shall implement at least one Approved 

security function used in an Approved mode of operation.” 

(Levels 1, 2, 3, and 4) “The operator shall be able to determine when an Approved mode of 

operation is selected.” 

(Levels 1 and 2) “The cryptographic module security policy may specify when a cryptographic 

module is performing in an Approved mode of operation.” 

(Levels 3 and 4) “A cryptographic module shall indicate when an Approved mode of operation 

is selected. (Approved security functions are listed in Annex A to this standard.)”

(Levels 1, 2, 3, and 4) “Documentation shall list all security functions, both Approved and 

non-Approved, that are employed by a cryptographic module and shall specify all modes of 

operation, both Approved and non-Approved.” 

FIPS 140-2 is more explicit in its requirements for general documentation of hardware, software 

and and firmware components. The FIPS 140-1 requirement (moved from the section entitled 

“Software Security”): 

(Levels 1, 2, 3, and 4) “Documentation shall include a detailed description of the design of 

software within the module” 

has been extended in FIPS 140-2: 
FIPS 140-1&2 Differences 

10 

(Levels 1, 2, 3, and 4) “Documentation shall specify the design of the hardware, software, 

and firmware components of a cryptographic module. High-level specification languages for 

software/firmware or schematics for hardware should be used to document the design.” 

FIPS 140-2 explicitly requires documentation of information contained in cryptographic modules 

that must be protected: 

(Levels 1, 2, 3 and 4) “Documentation shall specify all security-related information, including 

secret and private cryptographic keys (both plaintext and encrypted), authentication data 

(e.g., passwords, PINs), other CSPs, and other protected information (e.g., audited events, 

audit data) whose disclosure or modification can compromise the security of the 

cryptographic module.” 

Documentation requirements involving interfaces to the cryptographic module, manual and logical 

controls, and physical or logical status indicators, that appear in “Module Interfaces” area of FIPS 

140-1, have been moved without substantive modification to this area of FIPS 140-2. 

3.3.2. Cryptographic Module Ports and Interfaces 

This area has been renamed (from Module Interfaces in FIPS 140-1 to Cryptographic Module 

Ports and Interfaces in FIPS 140-2) to more accurately reflect the content of the material. 

The security requirements involving a “maintenance access interface” and a “maintenance 

access role”, specified in Section 2 (Module Interfaces) of FIPS 140-1, have been moved to the 

Physical Security and Roles, Services, and Authentication, areas of FIPS 140-2. 

The higher security level requirements involving the ports used for the input and output of 

plaintext security-relevant data have been revised. Specifically, the FIPS 140-1 requirements: 

(Levels 3 and 4) “The data input and output port or ports used for plaintext cryptographic key 

components, plaintext authentication data, and other unprotected critical security parameters 

shall be physically separated from all other ports of the module. Furthermore, these ports 

shall allow for direct entry of plaintext cryptographic key components, plaintext authentication 

data, and other unprotected critical security parameters, as required in Section 4.8.3.” 

have been replaced in FIPS 140-2 by: 

(Levels 3 and 4) 

• “The physical port(s) used for the input and output of plaintext cryptographic key 

components, authentication data, and CSPs shall be physically separated from all other 

ports of the cryptographic module 

or 

• the logical interfaces used for the input and output of plaintext cryptographic key 

components, authentication data, and CSPs shall be logically separated from all other 

interfaces using a trusted path, 

and 

• plaintext cryptographic key components, authentication data, and other CSPs shall be 

directly entered into the cryptographic module (e.g., via a trusted path or directly attached 

cable). (See Section 4.7.4.)” 
FIPS 140-1&2 Differences 

11 

3.3.3. Roles, Services, and Authentication 

The area has been renamed (from Roles and Services in FIPS 140-1 to Roles, Services, and 

Authentication in FIPS 140-2) to more accurately reflect the content of the material. 

3.3.3.1. Roles 

There are no major changes to the requirements in this subsection. 

3.3.3.2. Services 

In addition to the “Show Status” and “Perform Self-Tests” services, FIPS 140-2 explicitly requires 

the following service of a cryptographic module: 

Perform Approved Security Function: Perform at least one Approved security function used in an 

Approved mode of operation. 

In FIPS 140-2, for cryptographic modules that implement a bypass capability, the “Show Status” 

indicator must also indicate an alternating state. Specifically, the requirement in FIPS 140-1: 

(Levels 1, 2, 3, and 4) “If a cryptographic module implements a bypass capability, then the 

current status of the module (e.g., the response to a ‘Show Status’ service request) shall 

indicate whether or not the bypass capability is activated.” 

has been replaced by the following requirement in FIPS 140-2: 

(Levels 1, 2, 3, and 4) “If a cryptographic module implements a bypass capability, where 

services are provided without cryptographic processing (e.g., transferring plaintext through 

the module without encryption), then 

• the module shall show status to indicate whether 

1) the bypass capability is not activated, and the module is exclusively providing 

services with cryptographic processing (e.g., plaintext data is encrypted), 

2) the bypass capability is activated and the module is exclusively providing services 

without cryptographic processing (e.g., plaintext data is not encrypted), or 

3) the bypass capability is alternately activated and deactivated and the module is 

providing some services with cryptographic processing and some services without

cryptographic processing (e.g., for modules with multiple communication channels, 

plaintext data is or is not encrypted depending on each channel configuration).” 

FIPS 140-2 also requires the vendor to specifically cite the services that can be performed by a 

module for an operator who does not assume a role supported by the module: 

(Levels 1, 2, 3, and 4) “Documentation shall specify any services provided by the 

cryptographic module for which the operator is not required to assume an authorized role, 

and how these services do not modify, disclose, or substitute cryptographic keys and CSPs, 

or otherwise affect the security of the module.” 

3.3.3.3. Operator Authentication 

Implicit in FIPS 140-1, FIPS 140-2 explicitly requires the identification of “other means” to control 
FIPS 140-1&2 Differences 

12 

“initial” crypto-officer access to the cryptographic module:

(Levels 1,2, 3, and 4) “If a cryptographic module does not contain the authentication data 

required to authenticate the operator for the first time the module is accessed, then other 

authorized methods (e.g., procedural controls or use of factory-set or default authentication 

data) shall be used to control access to the module and initialize the authentication 

mechanisms.” 

FIPS 140-2 specifies requirements for the strength of authentication mechanisms for a 

cryptographic module: 

• (Levels 2, 3, and 4) “For each attempt to use the authentication mechanism, the 

probability shall be less than one in 1,000,000 that a random attempt will succeed or a 

false acceptance will occur (e.g., guessing a password or PIN, false acceptance error 

rate of a biometric device, or some combination of authentication methods).” 

• (Levels 2, 3, and 4) “For multiple attempts to use the authentication mechanism during a 

one-minute period, the probability shall be less than one in 100,000 that a random 

attempt will succeed or a false acceptance will occur.” 

• (Levels 2, 3, and 4) “Feedback of authentication data to an operator shall be obscured 

during authentication (e.g., no visible display of characters when entering a password).” 

• (Levels 2, 3, and 4) “Feedback provided to an operator during an attempted 

authentication shall not weaken the strength of the authentication mechanism.” 

(Levels 1, 2, 3, and 4) “Documentation shall specify: 

• the authentication mechanisms supported by a cryptographic module, 

• the types of authentication data required by the module to implement the supported 

authentication mechanisms, 

• the authorized methods used to control access to the module for the first time and 

initialize the authentication mechanisms, and 

• the strength of the authentication mechanisms supported by the module.” 

For Security Level 1, a cryptographic module is not required to employ authentication 

mechanisms to control access to the module. In this case, FIPS 140-2 requires the following: 

(Security Level 1) “If authentication mechanisms are not supported by a cryptographic 

module, the module shall require that one or more roles either be implicitly or explicitly 

selected by the operator.” 

3.3.4. Finite State Model 

The area has been renamed (from Finite State Machine Model in FIPS 140-1 to Finite State 

Model in FIPS 140-2). 

The FIPS 140-1 requires a correspondence between a “maintenance access interface” and 

corresponding finite state machine “maintenance states.” This is modified in FIPS 140-2 by a 

requirement of a correspondence between a “maintenance role” and “maintenance states.” More 

precisely, the FIPS 140-1 requirement: 
FIPS 140-1&2 Differences 

13 

(Levels 1, 2, 3, and 4) “If a cryptographic module contains a maintenance access interface, 

then it shall include maintenance states.” 

has been replaced by the FIPS 140-2 requirement: 

(Levels 1, 2, 3, and 4) “If a cryptographic module contains a maintenance role, then a 

maintenance state shall be included.” 

3.3.5. Physical Security 

The security requirements in this area have been reorganized to eliminate the redundancies 

found in FIPS 140-1. A new subsection entitled General Security Requirements captures for 

each security level those requirements that are applicable to all three physical embodiments: 

single-chip, multiple-chip embedded, and multiple-chip standalone cryptographic modules. 

Most of the discussion on the maintenance access interface, found in the area entitled Module 

Interfaces of FIPS 140-1, has been moved to this area of FIPS 140-2. 

FIPS 140-2 clarifies the lower security level requirements for (procedural and automatic) 

zeroization of plaintext secret and private keys and other CSPs when performing physical 

maintenance: 

(Levels 1 and 2) “When performing physical maintenance, all plaintext secret and private 

keys and other unprotected CSPs contained in the cryptographic module shall be zeroized. 

Zeroization shall either be performed procedurally by the operator or automatically by the 

cryptographic module.” 

The documentation requirements have been extended to include how the zeroization takes place 

when accessing the maintenance access interface. 

(Level 1, 2, 3, and 4) “Documentation shall specify the maintenance access interface and 

how plaintext secret and private keys and CSPs are zeroized when the maintenance access 

interface is accessed.” 

At Security Level 2 in FIPS 140-2, the physical embodiments for multiple-chip embedded 

cryptographic modules have been extended to include the use of a tamper-evident enclosure as 

an alternative to the use of a tamper-evident coating. 

3.3.6. Operational Environment 

This area has been renamed (from Operating System Security in FIPS 140-1 to Operational 

Environment in FIPS 140-2) to more accurately reflect the content of the material. 

The substantive changes made to the operating system requirements involve: 

• Adoption of Recommended CC Protection Profiles functional requirements evaluated at 

Evaluation Assurance Level (EAL) 2 with additional functional and assurance 

requirements (in place of the TCSEC C2, B1, and B2 functional and assurance 

requirements). (Note that TCSEC labeling requirements are no longer required for 

Security Levels 3-4.) 

• Discretionary access control mechanisms that are explicitly role-based as opposed to 
FIPS 140-1&2 Differences 

14 

operator and/or process-based, and 

• Requirements for audit capabilities and run-time auditing. 

General

The criteria for applicability of the operating system requirements has been expanded in FIPS 

140-2. In particular, the FIPS 140-1 requirement: 

(Levels 1, 2, 3, and 4) “The operating systems requirements in this section apply to a 

cryptographic module only if the module provides a means whereby and operator can load 

and execute software or firmware that was not included as part of the validation of the 

module.” 

has been replaced by the FIPS 140-2 requirements: 

(Levels 1, 2, 3, and 4) “If the operational environment is a modifiable operational 

environment, the operating system requirements in Section 4.6.1 shall apply. If the 

operational environment is a limited operational environment, the operating system 

requirements in Section 4.6.1 do not apply. A limited operational environment refers to a 

static non-modifiable virtual operational environment (e.g., JAVA virtual machine or a nonprogrammable PC card) with no underlying general purpose operating system upon which 

the operational environment uniquely resides.” 

FIPS 140-2 is explicit in documentation requirements regarding the strength of the operating 

system: 

(Levels 1, 2, 3, and 4) “Documentation shall specify the operational environment for a 

cryptographic module, including, if applicable, the operating system employed by the module, 

and for Security Levels 2, 3, and 4, the Protection Profile and the CC assurance level.” 

Security Level 1

The FIPS 140-1 requirements that exclude the use of multiuser, multiprocess systems: 

(Level 1 only) “Use of the cryptographic module shall be limited to a single user at a time.” 

(Level 1 only) “Use of the cryptographic module shall be dedicated to the cryptographic 

process during the time the cryptographic process is in use.” 

have been replaced by a set of requirements that achieve the same security within the context of 

current multiprocess operating systems: 

(Level 1 only) “The operating system shall be restricted to a single operator mode of 

operation (i.e., concurrent operators are explicitly excluded).” 

(Level 1 only) “The cryptographic module shall prevent access by other processes to plaintext 

private and secret keys, CSPs, and intermediate key generation values during the time the 

cryptographic module is executing/operational. Processes that are spawned by the 

cryptographic module are owned by the module and are not owned by external 

processes/operators. Non-cryptographic processes shall not interrupt a cryptographic 

module during execution.” 

The FIPS 140-1 requirements on the internal storage of cryptographic software have been 

generalized in FIPS 140-2 and extended to include firmware. Specifically, the FIPS 140-1 
FIPS 140-1&2 Differences 

15 

requirement: 

(Levels 1, 2, 3, and 4) “All cryptographic software shall be installed only as executable code 

in order to discourage scrutiny and modification by users.” 

has been replaced in FIPS 140-2 by: 

(Levels 1, 2, 3, and 4) “All cryptographic software and firmware shall be installed in a form 

that protects the software and firmware source and executable code from unauthorized 

disclosure and modification.” 

The application of an Approved integrity technique for software has been extended in FIPS 140-2 

to also include firmware. Specifically, the FIPS 140-1 requirement: 

(Levels 1, 2, 3, and 4) “A cryptographic mechanism using a FIPS approved authentication 

technique (e.g., the computation and verification of a data authentication code or NIST digital 

signature algorithm) shall be applied to the cryptographic software within the cryptographic 

module.” 

has been replaced in FIPS 140-2 by: 

(Levels 1, 2, 3, and 4) “A cryptographic mechanism using an Approved integrity technique 

(e.g., an Approved message authentication code or digital signature algorithm) shall be 

applied to all cryptographic software and firmware components within the cryptographic 

module.” 

Security Level 2

In FIPS 140-2, the functional security requirements of the OS are those specified by the 

Recommended Protection Profiles evaluated at the CC EAL2. More precisely, the FIPS 140-1 

requirements: 

(Level 2 Only) “All cryptographic software, cryptographic keys and other critical security 

parameters, and control and status information shall be under the control of an operating 

system that provides controlled access protection (i.e., C2 protection in accordance with the 

Trusted Computer System Evaluation Criteria (TCSEC), or FIPS approved equivalent). Only 

operating systems that have been evaluated by a NIST accredited evaluation authority and 

against a FIPS approved criteria shall be used.” 

have been replaced by the FIPS 140-2 requirements: 

(Level 2 Only) “All cryptographic software and firmware, cryptographic keys and CSPs, and 

control and status information shall be under the control of 

! an operating system that meets the functional requirements specified in the Protection 

Profiles listed in Annex B and is evaluated at the CC evaluation assurance level EAL2, or 

! an equivalent evaluated trusted operating system.” 

The discretionary access control mechanisms of an OS have been clarified in FIPS 140-2 as 

being “role based” rather than “operator and/or process based” in FIPS 140-1. The applicable 

FIPS 140-2 requirements are as follows: 
FIPS 140-1&2 Differences 

16 

(Levels 2, 3, and 4) “To protect plaintext data, cryptographic software and firmware, 

cryptographic keys and CSPs, and authentication data, the discretionary access control 

mechanisms of the operating system shall be configured to specify the set of roles that can 

! execute stored cryptographic software and firmware, 

! modify (i.e., write, replace, and delete) the following cryptographic module software or 

firmware components stored within the cryptographic boundary: cryptographic programs, 

cryptographic data (e.g., cryptographic keys and audit data), CSPs, and plaintext data, 

! read the following cryptographic software components stored within the cryptographic 

boundary: cryptographic data (e.g., cryptographic keys and audit data), CSPs and 

plaintext data and 

! enter cryptographic keys and CSPs.” 

The FIPS 140-1 requirements for OS audit capabilities at Security Levels 3 and 4 have been 

extended to Security Level 2 in FIPS 140-2: 

(Levels 2, 3, and 4) “The operating system shall provide an audit mechanism to record 

modifications, accesses, deletions, and additions of cryptographic data and CSPs.” 

FIPS 140-2 specifies the set of events that must be must be audited by the OS: 

(Levels 2, 3, and 4) “The following events shall be recorded by the audit mechanism: 

– attempts to provide invalid input for crypto officer functions, and 

– the addition or deletion of an operator to/from a crypto officer role.” 

FIPS 140-2 specifies the set of events that must be auditable by the OS: 

(Levels 2, 3, and 4) “The audit mechanism shall be capable of auditing the following events: 

– operations to process audit data stored in the audit trail, 

– requests to use authentication data management mechanisms, 

– use of a security-relevant crypto officer function, 

– requests to access user authentication data associated with the cryptographic module, 

– use of an authentication mechanism (e.g., login) associated with the cryptographic 

module, 

– explicit requests to assume a crypto officer role, and 

– the allocation of a function to a crypto officer role.” 

Security Level 3

In FIPS 140-2, the functional security requirements of the OS are those specified by the 

Recommended Protection Profiles evaluated at the CC EAL3. More precisely, the FIPS 140-1 

requirements: 

(Level 3) “All cryptographic software, cryptographic keys and other critical security 

parameters, control and status information shall be labeled and under the control of an 

operating system that provides labeled protection (i.e., B1 protection in accordance with the 

Trusted Computer System Evaluation Criteria (TCSEC), or FIPS approved equivalent). Only 

operating systems that have been evaluated by a NIST accredited evaluation authority and 

against a FIPS approved criteria shall be used.” 
FIPS 140-1&2 Differences 

17 

have been replaced by the FIPS 140-2 requirements: 

(Level 3) “All cryptographic software and firmware, cryptographic keys and CSPs, and control 

and status information shall be under the control of 

 

! an operating system that meets the functional requirements specified in the Protection 

Profiles listed in Annex B. The operating system shall be evaluated at the CC evaluation 

assurance level EAL3 and include the following additional requirements: Trusted_Path 

(FTP_TRP.1) and Informal TOE Security Policy Model (ADV_SPM.1), or 

! an equivalent evaluated trusted operating system.” 

The TCSEC terminology of a Trusted Computing Base (TCB) in FIPS 140-1 has been changed to 

the CC terminology of a Target of Evaluation Security Functions (TSF): 

(Levels 3 and 4) “All cryptographic keys and CSPs, authentication data, control inputs, and 

status outputs shall be communicated via a trusted mechanism (e.g., a dedicated I/O physical 

port or a trusted path). If a trusted path is used, the Target of Evaluation Security Functions 

(TSF) shall support the trusted path between the TSF and the operator when a positive TSFto-operator connection is required. Communications via this trusted path shall be activated 

exclusively by an operator or the TSF and shall be logically isolated from other paths.”

FIPS 140-2 specifies events that must be audited by the OS: 

(Levels 3 and 4) “In addition to the audit requirements of Security Level 2, the following 

events shall be recorded by the audit mechanism: 

! attempt to use the trusted path function, and 

! Identification of the initiator and target of a trusted path.” 

Security Level 4

In FIPS 140-2, the functional security requirements of the OS are those specified by the 

Recommended Protection Profiles evaluated at the CC EAL4. More precisely, the FIPS 140-1 

requirements: 

(Level 4) “All cryptographic software, cryptographic keys and other critical security 

parameters, control and status information shall be labeled and under the control of an 

operating system that provides structured protection (i.e., B2 protection in accordance with 

the Trusted Computer System Evaluation Criteria (TCSEC), or FIPS approved equivalent). 

Only operating systems that have been evaluated by a NIST accredited evaluation authority 

and against a FIPS approved criteria SHALL be used.” 

have been replaced by the FIPS 140-2 requirements: 

(Level 4) “All cryptographic software, cryptographic keys and CSPs, and control and status 

information shall be under the control of 

 

! an operating system that meets the functional requirements specified in the Protection 

Profiles listed in Annex B. The operating system shall be evaluated at the CC evaluation 

assurance level EAL4, or 

! an equivalent evaluated trusted operating system.” 
FIPS 140-1&2 Differences 

18 

3.3.7. Cryptographic Key Management 

The requirements for Key Archiving (Section 4.8.6 in FIPS 140-1) have been eliminated in FIPS 

140-2. 

The documentation requirements have been explicitly specified in FIPS 140-2: 

(Levels 1, 2, 3, and 4) “Documentation shall specify all cryptographic keys, cryptographic key 

components, and CSPs employed by a cryptographic module.” 

3.3.7.1. Random Number Generators (RNGs) 

FIPS 140-2 specifies security requirements for cryptographic modules that implement 

deterministic and/or nondeterministic random number generators (RNGs). 

 (Levels 1, 2, 3, and 4) “If a cryptographic module employs Approved or non-Approved RNGs 

in an Approved mode of operation, the data output from the RNG shall pass the continuous 

random number generator test as specified in Section 4.9.2. Depending on the security 

level, the data output from an Approved RNG shall pass all statistical tests for randomness as 

specified in Section 4.9.1. Approved deterministic RNGs shall be subject to the cryptographic 

algorithm test in Section 4.9.1. Approved RNGs are listed in Annex C to this standard.” 

(Levels 1, 2, 3, and 4) “Until such time as an Approved nondeterministic RNG standard 

exists, nondeterministic RNGs approved for use in classified applications may be used for 

key generation or to seed Approved deterministic RNGs used in key generation. 

Commercially available nondeterministic RNGs may be used for the purpose of generating 

seeds for Approved deterministic RNGs. Nondeterministic RNGs shall comply with all 

applicable RNG requirements of this standard.” 

 (Levels 1, 2, 3, and 4) “An Approved RNG shall be used for the generation of cryptographic 

keys used by an Approved security function. The output from a non-Approved RNG may be 

used 1) as input (e.g., seed, and seed key) to an Approved deterministic RNG or 2) to 

generate initialization vectors (IVs) for Approved security function(s). The seed and seed key 

shall not have the same value.” 

 (Levels 1, 2, 3, and 4) “Documentation shall specify each RNG (Approved and nonApproved) employed by a cryptographic module.” 

3.3.7.2. Key Generation 

FIPS 140-2 allows only Approved RNGs to be used in the key generation process. Specifically, 

the FIPS 140-1 requirement: 

(Levels 1, 2, 3, and 4) “When a random number is used in the key generation process, all 

values shall be generated randomly or pseudorandomly such that all combinations of bits and 

all possible values are equally likely to be generated.” 

has been replaced in FIPS 140-2 by: 

(Levels 1, 2, 3, and 4) “If an Approved key generation method requires input from a RNG, 

then an Approved RNG that meets the requirements specified in Section 4.7.1 shall be used.” 

FIPS 140-2 specifies security requirements regarding the general compromise of the key 

generation algorithm: 
FIPS 140-1&2 Differences 

19 

(Levels 1, 2, 3, and 4) “Compromising the security of the key generation method (e.g., 

guessing the seed value to initialize the deterministic RNG) shall require at least as many 

operations as determining the value of the generated key.”

FIPS 140-2 is explicit in the manner in which intermediate key generation values can be output by 

a cryptographic module. Specifically, the FIPS 140-1 requirement: 

(Levels 1, 2, 3, and 4) “If intermediate key generation states and values shall not be 

accessible outside of the module in plaintext or otherwise unprotected form.” 

has been replaced by the FIPS 140-2 requirement: 

(Levels 1, 2, 3, and 4) “If intermediate key generation values are output from the 

cryptographic module, the values shall be output either 1) in encrypted form or 2) under split 

knowledge procedures.” 

3.3.7.3. Key Establishment 

 

In FIPS 140-1, this subsection is entitled Key Distribution. 

FIPS 140-2 specifies security requirements for establishing cryptographic keys using radio 

communications: 

(Levels 1, 2, 3, and 4) “If, in lieu of an Approved key establishment method, a radio 

communications cryptographic module implements Over-The-Air-Rekeying (OTAR), it shall 

be implemented as specified in the TIA/EIA Telecommunications Systems Bulletin, APCO 

Project 25, Over-The-Air-Rekeying (OTAR) Protocol, New Technology Standards Project, 

Digital Radio Technical Standards, TSB102.AACA, January, 1996, Telecommunications 

Industry Association.” 

FIPS 140-2 specifies security requirements regarding the general compromise of the key 

establishment method: 

(Levels 1, 2, 3, and 4) “Compromising the security of the key establishment method (e.g., 

compromising the security of the algorithm used for key establishment) shall require at least 

as many operations as determining the value of the cryptographic key being transported or 

agreed upon.” 

3.3.7.4. Key Entry and Output 

FIPS 140-2 specifies the manner for entering and outputting cryptographic keys: 

(Levels 1, 2, 3, and 4) “If cryptographic keys are entered into or output from a cryptographic 

module, the entry or output of keys shall be performed using either manual (e.g., via a 

keyboard) or electronic methods (e.g., smart cards/tokens, PC cards, or other electronic key 

loading devices).” 

(Levels 1, 2, 3, and 4) “A seed key, if entered during key generation, shall be entered in the 

same manner as cryptographic keys.” 

If secret and private keys are themselves encrypted, FIPS 140-2 requires that an Approved 

algorithm be used: 
FIPS 140-1&2 Differences 

20 

(Levels 1, 2, 3, and 4) “All encrypted secret and private keys, entered into or output from a 

cryptographic module and used in an Approved mode of operation, shall be encrypted using 

an Approved algorithm.” 

When split knowledge procedures are used to enter or output secret and private keys, FIPS 140-

2 specifies requirements for the key components: 

(Levels 3 and 4) “If split knowledge procedures are used: 

! the cryptographic module shall separately authenticate the operator entering or outputting 

each key component, 

! plaintext cryptographic key components shall be directly entered into or output from the 

cryptographic module (e.g., via a trusted path or directly attached cable) without traveling 

through any enclosing or intervening systems where the key components may 

inadvertently be stored, combined, or otherwise processed (see Section 4.2), 

! at least two key components shall be required to reconstruct the original cryptographic 

key, 

! documentation shall prove that if knowledge of n key components is required to 

reconstruct the original key, then knowledge of any n-1 key components provides no 

information about the original key other than the length, and 

! documentation shall specify the procedures employed by a cryptographic module.” 

3.3.7.5. Key Storage 

FIPS 140-2 clarifies the storing of secret and private keys in a cryptographic module. In 

particular, the FIPS 140-1 requirement: 

(Levels 1, 2, 3, and 4) “When contained within a cryptographic module, secret and private 

keys may be stored in plaintext form.” 

has been replaced in FIPS 140-2 by the requirement: 

(Levels 1, 2, 3, and 4) “Cryptographic keys stored within a cryptographic module shall be 

stored either in plaintext form or encrypted form.” 

3.3.7.6. Key Zeroization 

This subsection was entitled Key Destruction in FIPS 140-1. 

3.3.8. Electromagnetic Interference/Electromagnetic Compatibility (EMI/EMC) 

Reference to the specific subparts of the 47 Code of Federal Regulations for EMI/EMC 

requirements have been updated in FIPS 140-2: 

(Levels 1 and 2) “A cryptographic module shall (at a minimum) conform to the EMI/EMC 

requirements specified by 47 Code of Federal Regulations, Part 15, Subpart B, Unintentional 

Radiators, Digital Devices, Class A (i.e., for business use).” 
FIPS 140-1&2 Differences 

21 

(Levels 3 and 4) “A cryptographic module shall (at a minimum) conform to the EMI/EMC 

requirements specified by 47 Code of Federal Regulations, Part 15, Subpart B, Unintentional 

Radiators, Digital Devices, Class B (i.e., for home use).” 

3.3.9. Self-Tests 

FIPS 140-2 is explicit in the documentation requirements: 

(Levels 1, 2, 3, and 4) “Documentation shall specify: 

• the self-tests performed by a cryptographic module, including power-up and conditional 

tests, 

• the error states that a cryptographic module can enter when a self-test fails, and 

• the conditions and actions necessary to exit the error states and resume normal 

operation of a cryptographic module (i.e., this may include maintenance of the module, or 

returning the module to the vendor for servicing.” 

3.3.9.1. Power-up Tests 

Cryptographic algorithm test 

The application of the cryptographic algorithms test has been clarified. More precisely, the FIPS 

140-1 requirement: 

(Levels 1, 2, 3, and 4) “A known answer test shall be run for each cryptographic function 

(e.g., encryption, decryption, authentication) that is implemented.” 

has been replaced in FIPS 140-2 by: 

(Levels 1, 2, 3, and 4) “A cryptographic algorithm test using a known answer shall be 

conducted for all modes (e.g., encryption, decryption, authentication, and deterministic 

random number generation) of each Approved cryptographic algorithm implemented by a 

cryptographic module.” 

(Levels 1, 2, 3, and 4) “Cryptographic algorithms whose outputs vary for a given set of inputs 

(e.g., the Digital Signature Algorithm) shall be tested using a known-answer test or shall be 

tested using a pair-wise consistency test.” 

Software/firmware integrity test 

In applying the software/firmware integrity test, a lower bound has been placed on the size of the 

error detection code: 

(Levels 1, 2, 3, and 4) “If an EDC is used, the EDC shall be at least 16 bits in length.” 

Statistical random number generator tests 

The four statistical random number tests, recommended in FIPS 140-1 with the possibility of 

substituting alternative equivalent or superior tests, are required without exception in FIPS 140-2. 

Specifically, the FIPS 140-2 requirement is: 
FIPS 140-1&2 Differences 

22 

(Levels 3 and 4) “A single bit stream of 20,000 consecutive bits of output from each RNG 

shall be subjected to the following four tests: monobit test, poker test, runs test, and long runs 

test.” 

The acceptance intervals for each of the statistical random number tests have been revised to 

decrease the probability of a false acceptance for a single bit stream of 20,000 consecutive bits of 

output: 

• Monobit Test: (9,725 < X < 10,275) for the number of 1’s. 

• Poker Test: (2.16 < X < 46.17) for the stated measure. 

• Runs Test: 

Length of 

Run 

Required 

Interval 

1 2,343 – 2,657 

2 1,135 – 1,365 

3 542 - 708 

4 251 - 373 

5 111 - 201 

6+ 111 - 201 

• Long Runs Test: a long run is defined to be of length 26 or more (of either zeros or ones). 

3.3.9.2. Conditional Tests 

Pairwise consistency test 

The following requirement involving key agreement is new in FIPS 140-2: 

(Levels 1, 2, 3, and 4) “If the keys are to be used to perform key agreement, then the 

cryptographic module shall create a second, compatible key pair. The cryptographic module 

shall then perform both sides of the key agreement algorithm and shall compare the resulting 

shared values. If the shared values are not equal the test shall fail.” 

Manual key entry test 

The following new requirement in FIPS 140-2 applies to keys or key components that are 

manually entered into a cryptographic module: 

(Levels 1, 2, 3, and 4) “If an EDC is used, the EDC shall be at least 16 bits in length.” 

Bypass test 

The following requirements have been in added in FIPS 140-2 for cryptographic modules that 

implement a bypass test: 

(Levels 1, 2, 3, and 4) “If a cryptographic module implements a bypass capability where the 

services may be provided without cryptographic processing (e.g., transferring plaintext 

through the module), then the following bypass tests shall be performed to ensure that a 

single point of failure of module components will not result in the unintentional output of 

plaintext: 

1. A cryptographic module shall test for the correct operation of the services providing 
FIPS 140-1&2 Differences 

23 

cryptographic processing when a switch takes place between an exclusive bypass 

service and an exclusive cryptographic service. 

2. If a cryptographic module can automatically alternate between a bypass service and a 

cryptographic service, providing some services with cryptographic processing and some 

services without cryptographic processing, then the module shall test for the correct 

operation of the services providing cryptographic processing when the mechanism 

governing the switching procedure is modified (e.g., an IP address source/destination 

table). “ 

(Levels 1, 2, 3, and 4) “Documentation shall specify the mechanism or logic governing the 

switching procedure.” 

3.3.10. Design Assurance 

This area has been renamed (from Software Security in FIPS 140-1 to Design Assurance in FIPS 

140-2) to more accurately reflect the content of the material. New security requirements are 

specified for the following subsections: 

• Configuration Management – provides assurance that the functional requirements and 

specifications are realized in the implementation of a cryptographic module. 

• Delivery and Operation – provides assurance that a cryptographic module is securely 

delivered to authorized operators, and is installed and initialized in a correct and secure 

manner. 

• Development – provides assurance that the implementation of a cryptographic module 

corresponds to the module’s security policy and functional specification. 

• Guidance Documents – concerned with the correct configuration, maintenance, 

administration and secure use of a cryptographic module.

3.3.10.1. Configuration Management 

The specific security requirements for this subsection are: 

(Levels 1, 2, 3, and 4) “A configuration management system shall be implemented for a 

cryptographic module and module components within the cryptographic boundary, and for 

associated module documentation. Each version of each configuration item (e.g., 

cryptographic module, module components, user guidance, security policy, and operating 

system) that comprises the module and associated documentation shall be assigned and 

labeled with a unique identification number.” 

3.3.10.2. Delivery and Operation 

The specific security requirements for this subsection are: 

(Security Levels 1, 2, 3, and 4) “Documentation shall specify the procedures for secure 

installation, initialization, and startup of a cryptographic module.” 

(Security Levels 2, 3, and 4) “In addition to the requirements of Security Level 1, 

documentation shall specify the procedures required for maintaining security while 

distributing and delivering versions of a cryptographic module to authorized operators.” 
FIPS 140-1&2 Differences 

24 

3.3.10.3. Development 

This subsection subsumes the security requirements for Software Security as specified in FIPS 

140-1. In FIPS 140-2, these requirements are extended to include the documentation of 

hardware design and to strengthen the requirements for documentation of software and firmware. 

The requirements for documentation of software have been broadened to include firmware and 

hardware. More specifically, the FIPS 140-1 requirements: 

(Levels 1, 2, 3, and 4) “Documentation shall include a detailed explanation of the 

correspondence between the design of the software and the cryptographic security policy 

(i.e., the rules of operation).” 

(Levels 1, 2, 3, and 4) “Documentation shall include a complete source code listing for all 

software contained within the module. For each software module, software function and 

software procedures, the source code listing shall be annotated with comments that clearly 

depict the relationship of these software entities to the design of the software.”

have been replaced in FIPS 140-2 by the requirements: 

(Levels 1, 2, 3, and 4) “Documentation shall specify the correspondence between the design 

of the hardware, software, and firmware components of a cryptographic module and the 

cryptographic module security policy (see Section 4.1).” 

(Levels 1, 2, 3, and 4) “If a cryptographic module contains software or firmware components, 

documentation shall specify the source code for the software and firmware components, 

annotated with comments that clearly depict the correspondence of the components to the 

design of the module.” 

(Levels 1, 2, 3, and 4) “If a cryptographic module contains hardware components, 

documentation shall specify the schematics and/or Hardware Description Language (HDL) 

listings for the hardware components.” 

At Security Level 2, FIPS 140-2 has new requirements for functional specification of the 

interfaces and ports and the behavior of the cryptographic module: 

(Levels 2, 3 and 4) “Documentation shall specify a functional specification that informally 

describes a cryptographic module, the external ports and the interfaces of the module, and 

the purpose of the interfaces.” 

At Security Level 3, the use of high-level languages in the design has been extended to include 

firmware and hardware. Specifically, the FIPS 140-1 requirement: 

(Levels 3 and 4) “All software within a cryptographic module shall be implemented using a 

high-level language, except that the limited use of low-level languages (e.g., assembly 

languages) is allowed when it is essential to the performance of the module or when a highlevel language is not available.” 

has been replaced by the FIPS 140-2 requirements:

(Levels 3 and 4) “All software and firmware components within a cryptographic module shall 

be implemented using a high-level language, except that the limited use of a low-level 

language (e.g., assembly language or microcode) is allowed if essential to the performance 
FIPS 140-1&2 Differences 

25 

of the module or when a high-level language is not available.” 

(Levels 3 and 4) “If HDL is used, all hardware components within a cryptographic module 

shall be implemented using a high-level specification language.” 

At Security Level 4, FIPS 140-2 adds the new requirement: 

(Level 4) “Documentation shall specify a rationale that demonstrates the consistency and 

completeness of the formal model with respect to the cryptographic module security policy.” 

and modifies other documentation requirements: 

“Documentation shall specify an informal proof of the correspondence between the formal 

model and the functional specification. 

Documentation shall specify an informal proof of the correspondence between the design of 

the cryptographic module (as reflected by the precondition and postcondition annotations) 

and the functional specification.” 

3.3.10.4. Guidance Documents 

The specific requirements for this subsection are: 

(Levels 1, 2, 3, and 4) “Crypto officer guidance shall specify: 

• the administrative functions, security events, security parameters (and parameter values, 

as appropriate), physical ports, and logical interfaces of the cryptographic module 

available to the crypto officer, 

• procedures on how to administer the cryptographic module in a secure manner, and 

• assumptions regarding user behavior that are relevant to the secure operation of the 

cryptographic module.” 

(Levels 1, 2, 3, and 4) “User guidance shall specify: 

• the Approved security functions, physical ports, and logical interfaces available to the 

users of a cryptographic module, and 

• all user responsibilities necessary for the secure operation of a cryptographic module.” 

3.3.11. Mitigation of Other Attacks 

Certain types of cryptographic modules may be susceptible to attacks for which testable security 

requirements were not available at the time FIPS 140-2 was issued (e.g., power analysis, timing 

analysis, and fault induction) or are outside of the scope of the standard (e.g., TEMPEST). FIPS 

140-2 requires the vendor to describe any such capabilities of the cryptographic modules: 

(Levels 1, 2, 3, and 4) “If a cryptographic module is designed to mitigate one or more specific 

attacks, then the module’s security policy shall specify the security mechanisms employed by 

the module to mitigate the attack(s). The existence and proper functioning of the security 

mechanisms will be validated when requirements and associated tests are developed.” 
FIPS 140-1&2 Differences 

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4. DIFFERENCES IN APPENDIXES 

This section details the differences in the Appendixes between FIPS 140-1 and 140-2. 

Appendix A: Summary of Documentation Requirements 

In FIPS 140-2, the information in Appendix A has been updated, commensurate with the changes 

to Section 4 of the standard. 

Appendix B: Recommended Software Development Practices 

In Appendix B of FIPS 140-2 the recommendations for modular design, programming, and 

documentation have been updated, consistent with modern practices. 

Appendix C: Cryptographic Security Policy 

In FIPS 140-2, Appendix C specifies detailed requirements for a Security Policy (not specified in 

FIPS 140-1) that must be provided by the vendor of the cryptographic module: 

“A cryptographic module security policy shall consist of a specification of the security rules, 

under which a module shall operate, including the security rules derived from the 

requirements of this standard and the additional security rules imposed by the vendor. 

The specification shall be sufficiently detailed to answer the following questions: 

• What access does operator X, performing service Y while in role Z, have to securityrelevant data item W for every role, service, and security-related data item in the 

cryptographic module? 

• What physical security mechanisms are implemented to protect a cryptographic module 

and what actions are required to ensure that physical security of a module is maintained? 

• What security mechanisms are implemented in a cryptographic module to mitigate 

against attacks for which testable requirements are not defined in the Standard? 

A cryptographic security policy shall be expressed in terms of roles, services, and 

cryptographic keys and CSPs. At a minimum, the following shall be specified: 

• an identification and authentication (I&A) policy, 

• an access control policy, 

• a physical security policy, and 

• a security policy for mitigation of other attacks.” 

Further details are provided (in Appendix C of FIPS 140-2) as to what constitutes an acceptable 

specification of these components. Check lists are provided that serve as guides in determining 

whether or not the security policy is complete and contains the appropriate details. 

Appendix D: Selected Bibliography 

In FIPS 140-2, the citation of documents related to or supporting the Standard has been updated. 

Outdated references have been eliminated. 
FIPS 140-1&2 Differences 

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5. ANNEXES TO THE STANDARD 

The lists of Approved security functions, protection profiles, random number generators, and key 

establishment techniques are expected to grow over time. In order to dynamically incorporate 

these changes in the requirements, these lists will be maintained in the following Annexes to 

FIPS 140-2: 

National Institute of Standards and Technology, FIPS 140-2 Annex A: Approved Security 

Functions, available at URL: csrc.nist.gov/cryptval. 

National Institute of Standards and Technology, FIPS 140-2 Annex B: Recommended Protection 

Profiles, available at URL: csrc.nist.gov/cryptval. 

National Institute of Standards and Technology, FIPS 140-2 Annex C: Approved Random 

Number Generators, available at URL: csrc.nist.gov/cryptval. 

National Institute of Standards and Technology, FIPS 140-2 Annex D: Approved Key 

Establishment Techniques, available at URL: csrc.nist.gov/cryptval.