When considering products or services for handling an agency’s information, it is common to see two variations of FIPS accreditation: FIPS validated and FIPS compliant. Although they seem similar, there are different implications with these two labels.

• FIPS Validation means a product has undergone and passed detailed conformance testing at an accredited national laboratory.

• FIPS Compliance means that different components of a product have received FIPS validation, but the product in its entirety has not passed testing or has not been tested at all.

Why is being FIPS 140-2 compliant important?

One of the many reasons to become FIPS compliant is due to the government’s requirement that any organization working with them must be FIPS 140-2 compliant. This requirement ensures government data handled by third-party organizations is stored and encrypted securely and with the proper levels of confidentiality, integrity, and authenticity.

Using services or software without these tested methods in place could lead to a massive breach in security, causing problems for every person in the nation.

Who needs to be FIPS compliant?

The main organizations that are required to be FIPS 140-2 compliant are federal government organizations that either collect, store, share, transfer, or disseminate sensitive data, such as Personally Identifiable Information. All federal agencies, their contractors, and service providers must all be compliant with FIPS as well. Additionally, any systems deployed in a federal environment must also be FIPS 140-2 compliant.  Many organizations follow FIPS to ensure their own security is up to par with the government’s security. Many other organizations become FIPS 140-2 compliant to distribute their products and services in not only the United States, but also internationally. As FIPS is recognized around the world, any organization that possesses FIPS compliance will be seen as a trusted provider of services, products, and software. Some fields, such as manufacturing, healthcare, and financial sectors, along with local governments require FIPS 140-2 compliance as well.

Windows Operating System FIPS 140-2 Validation.

Achieving this FIPS 140-2 approved mode of operation of Windows requires administrators to complete all four steps listed in the following article. Federal Information Processing Standard (FIPS) 140 Validation – Windows security | Microsoft Docs

• Step 1: Ensure FIPS 140-2 validated cryptographic modules are installed
• Step 2: Ensure all security policies for all cryptographic modules are followed
• Step 3: Enable the FIPS security policy
• Step 4: Ensure that only FIPS validated cryptographic algorithms are used

While you may be running the right algorithms, without the Microsoft Validated process in place, you will not be in a validated compliance mode, which could potentially affect your certification process.

Specially for Bitlocker, you can configure the Federal Information Processing Standard (FIPS) setting for FIPS-Mode. As an effect of FIPS compliance, users can’t create or save a BitLocker password for recovery or as a key protector. The use of a recovery key is permitted. However, the policy must be enabled before any encryption key is generated for BitLocker. When this policy is enabled, BitLocker prevents creating or using recovery passwords, so recovery keys should be used instead.

To enable FIPS-Mode, Windows provides the security policy setting, System cryptography: Use FIPS-compliant algorithms for encryption, hashing, and signing. This setting is used by some Microsoft products to determine whether to run in FIPS mode. When this policy is turned on, the validated cryptographic modules in Windows will also operate in FIPS mode. This policy may be set using Local Security Policy, as part of Group Policy, or through a Modern Device Management (MDM) solution.

• For details, best practices, location, values, policy management and security considerations for this policy setting see the following information: System cryptography Use FIPS compliant algorithms for encryption, hashing, and signing (Windows 10) – Windows security | Microsoft Docs
• For modern MDM policy and configuration, review the following information: Policy CSP – Cryptography – Windows Client Management | Microsoft Docs
• Intune: FIPS-Mode can also be enabled directly via Intune under the Configuration Profile (as shown in the image below)

As far as Microsoft validations processes for cryptographic algorithms, the cadence for starting module validation aligns with the feature updates of Windows 10 and Windows Server. As the software industry evolves, operating systems release more frequently. Microsoft completes validation work on major releases but, in between releases, seeks to minimize the changes to the cryptographic modules.

ON another note, FIPS 140-2 modules can remain active for five years after validation or until 21 September 2026, when the FIPS 140-2 validations will be moved to the historical list. I am not aware of that validation process for FIPS 140-3 has started or not. However, I don’t expect to see much information available publicly since the current validation process is still active until 2026

For more information about FIPS 140-3, visit the following information.

FIPS 140-3 Transition Effort | CSRC (nist.gov)