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AWS KMS is now FIPS 140-2 Security Level 3. What does this mean for you?
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AWS Key Management Service (AWS KMS) recently announced that its hardware security modules (HSMs) were given Federal Information Processing Standards (FIPS) 140-2 Security Level 3 certification from the U… FIPS 140 validation is also required in certain fields such as manufacturing, healthcare,…
AWS Key Management Service (AWS KMS) recently announced that its hardware security modules (HSMs) were given Federal Information Processing Standards (FIPS) 140-2 Security Level 3 certification from the U.S. National Institute of Standards and Technology (NIST). For organizations that rely on AWS cryptographic services, this higher security level validation has several benefits, including simpler set up and operation. In this post, we will share more details about the recent change in FIPS validation status for AWS KMS and explain the benefits to customers using AWS cryptographic services as a result of this change.
Background on NIST FIPS 140
The FIPS 140 framework provides guidelines and requirements for cryptographic modules that protect sensitive information. FIPS 140 is the industry standard in the US and Canada and is recognized around the world as providing authoritative certification and validation for the way that cryptographic modules are designed, implemented, and tested against NIST cryptographic security guidelines.
Organizations follow FIPS 140 to help ensure that their cryptographic security is aligned with government standards. FIPS 140 validation is also required in certain fields such as manufacturing, healthcare, and finance and is included in several industry and regulatory compliance frameworks, such as the Payment Card Industry Data Security Standard (PCI DSS), the Federal Risk and Authorization Management Program (FedRAMP), and the Health Information Trust Alliance (HITRUST) framework. FIPS 140 validation is recognized in many jurisdictions around the world, so organizations that operate globally can use FIPS 140 certification internationally.
For more information on FIPS Security Levels and requirements, see FIPS Pub 140-2: Security Requirements for Cryptographic Modules.
What FIPS 140-2 Security Level 3 means for AWS KMS and you
Until recently, AWS KMS had been validated at Security Level 2 overall and at Security Level 3 in the following four sub-categories:
- Cryptographic module specification
- Roles, services, and authentication
- Physical security
- Design assurance
The latest certification from NIST means that AWS KMS is now validated at Security Level 3 overall in each sub-category. As a result, AWS assumes more of the shared responsibility model, which will benefit customers for certain use cases. Security Level 3 certification can assist organizations seeking compliance with several industry and regulatory standards. Even though FIPS 140 validation is not expressly required in a number of regulatory regimes, maintaining stronger, easier-to-use encryption can be a powerful tool for complying with FedRAMP, U.S. Department of Defense (DOD) Approved Product List (APL), HIPAA, PCI, the European Union’s General Data Protection Regulation (GDPR), and the ISO 27001 standard for security management best practices and comprehensive security controls.
Customers who previously needed to meet compliance requirements for FIPS 140-2 Level 3 on AWS were required to use AWS CloudHSM, a single-tenant HSM solution that provides dedicated HSMs instead of managed service HSMs. Now, customers who were using CloudHSM to help meet their compliance obligations for Level 3 validation can use AWS KMS by itself for key generation and usage. Compared to CloudHSM, AWS KMS is typically lower cost and easier to set up and operate as a managed service, and using AWS KMS shifts the responsibility for creating and controlling encryption keys and operating HSMs from the customer to AWS. This allows you to focus resources on your core business instead of on undifferentiated HSM infrastructure management tasks.
AWS KMS uses FIPS 140-2 Level 3 validated HSMs to help protect your keys when you request the service to create keys on your behalf or when you import them. The HSMs in AWS KMS are designed so that no one, not even AWS employees, can retrieve your plaintext keys. Your plaintext keys are never written to disk and are only used in volatile memory of the HSMs while performing your requested cryptographic operation.
The FIPS 140-2 Level 3 certified HSMs in AWS KMS are deployed in all AWS Regions, including the AWS GovCloud (US) Regions. The China (Beijing) and China (Ningxia) Regions do not support the FIPS 140-2 Cryptographic Module Validation Program. AWS KMS uses Office of the State Commercial Cryptography Administration (OSCCA) certified HSMs to protect KMS keys in China Regions. The certificate for the AWS KMS FIPS 140-2 Security Level 3 validation is available on the NIST Cryptographic Module Validation Program website.
As with many industry and regulatory frameworks, FIPS 140 is evolving. NIST approved and published a new updated version of the 140 standard, FIPS 140-3, which supersedes FIPS 140-2. The U.S. government has begun transitioning to the FIPS 140-3 cryptography standard, with NIST announcing that they will retire all FIPS 140-2 certificates on September 22, 2026. NIST recently validated AWS-LC under FIPS 140-3 and is currently in the process of evaluating AWS KMS and certain instance types of AWS CloudHSM under the FIPS 140-3 standard. To check the status of these evaluations, see the NIST Modules In Process List.
For more information on FIPS 140-3, see FIPS Pub 140-3: Security Requirements for Cryptographic Modules.
Legal Disclaimer This document is provided for the purposes of information only; it is not legal advice, and should not be relied on as legal advice. Customers are responsible for making their own independent assessment of the information in this document. This document: (a) is for informational purposes only, (b) represents current AWS product offerings and practices, which are subject to change without notice, and (c) does not create any commitments or assurances from AWS and its affiliates, suppliers or licensors. AWS products or services are provided “as is” without warranties, representations, or conditions of any kind, whether express or implied. The responsibilities and liabilities of AWS to its customers are controlled by AWS agreements, and this document is not part of, nor does it modify, any agreement between AWS and its customers. AWS encourages its customers to obtain appropriate advice on their implementation of privacy and data protection environments, and more generally, applicable laws and other obligations relevant to their business. AWS encourages its customers to obtain appropriate advice on their implementation of privacy and data protection environments, and more generally, applicable laws and other obligations relevant to their business. |
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Author: Rushir Patel