Artifact GuideGLOBALFIPS 140-3

FIPS 140-3 Approved and Non-Approved Mode Workflow

A workflow for classifying module services, indicators, and Security Policy evidence before relying on an approved-mode claim.

Use it to separate approved security services, allowed no-security-claimed behavior, and services that cannot run in the approved mode.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

This workflow is for product security, validation, and procurement teams reviewing a FIPS 140-3 cryptographic module. It focuses on a narrow question: for each externally invoked service, can an operator unambiguously tell whether the service uses an approved cryptographic algorithm, security function, or process in an approved manner, and does the Security Policy document the same classification?

Section 1

Start with a service-by-service inventory

Do not start from a product feature list or a broad statement that the module is in FIPS mode. CMVP Implementation Guidance 2.4.C treats a service as an externally operator-invoked operation or function, and it explains that a service may map to one API call, a group of API calls, or different behavior based on input parameters.

The first workflow step is to list every callable service that can affect cryptographic behavior, including encryption, decryption, signature generation, verification, key establishment, random bit generation, authentication, on-demand self-tests, zeroisation paths, status output, and any service that exposes both approved and non-approved behavior.

  • Name the service as the operator sees it, not only the internal function name.
  • Record the algorithm, security function, process, key or CSP use, and input parameters that determine whether the service is approved.
  • Separate services that perform approved security functions from services that only show version, status, or other non-security information.
  • Keep the service names aligned with the module Security Policy so reviewers can compare the page, evidence pack, and certificate materials.
Section 2

Classify each service before writing the indicator rule

For each service, decide which CMVP bucket it belongs in. Approved security services use approved or allowed security functions in an approved manner. Some services may run in the approved mode even though they do not use a security function, or because a non-approved algorithm is present only with no security claimed. Services that use non-approved and not-allowed security functions are not available for use in the approved mode.

This classification is not the same as saying the entire product is approved. FIPS 140-3 requires modules conforming to the standard to employ approved security functions, while the CMVP guidance requires the Security Policy to show approved and non-approved services and the indicators that apply.

  • Classify the service as approved security service, non-security service, allowed no-security-claimed service, non-approved service, or mixed/non-security action.
  • For allowed no-security-claimed use, document why the non-approved algorithm is not being used to meet FIPS 140-3 security requirements.
  • Treat a non-approved security function as disallowed in the approved mode unless the CMVP guidance supports the specific no-security-claimed treatment.
  • Do not use an approved algorithm name by itself as proof that the service is approved; the service context, CAVP evidence, self-tests, and Security Policy limits matter.
Section 3

Design the approved security service indicator

The indicator must let the operator determine whether an approved security service is in use. CMVP guidance allows different indicator designs, including return codes, log messages, status bits, status interfaces, query functions, LEDs, or a global indicator when the module only supports approved services in an approved manner.

A Security Policy description can explain how to interpret an indicator, but the description alone does not satisfy the indicator requirement. If approved and non-approved security services can run concurrently, or if different inputs can change whether a service is approved, a broad global indicator is not enough unless it still unambiguously identifies the approved security service.

  • For each approved security service, record the indicator value, interface, timing, and operator action needed to retrieve or recognize it.
  • Use per-service indicators when the same module can perform approved and non-approved security services at the same time.
  • Avoid identical indicator values for approved and non-approved cryptographic services because that prevents unambiguous differentiation.
  • Write the Security Policy interpretation next to the implemented indicator, not as a substitute for the implemented indicator.
Section 4

Workflow table for approved and non-approved services

Use one row per service so procurement, lab, engineering, and audit reviewers can see the decision without reading the entire Security Policy.

Row fields: service name; operator-facing entry point; algorithm or process used; approved, allowed, no-security-claimed, or non-approved classification; CAVP certificate or evidence reference where applicable; key or CSP sharing result; indicator value and interface; Security Policy location; reviewer decision.

Decision outcomes: approved security service with indicator; allowed in approved mode with no security claimed; non-security service with no indicator needed; not available in approved mode; unresolved pending lab or CMVP review.

  • Put services that use the same algorithm but different parameters in separate rows when approval depends on parameter choice.
  • Mark non-approved algorithms that obfuscate CSPs as plaintext-treatment evidence unless an approved protection method covers the CSP.
  • Record any key or CSP sharing between approved and non-approved algorithms as a blocking issue unless the CMVP guidance expressly supports the path.
  • Keep unresolved rows out of public FIPS claims until the indicator, Security Policy, and validation evidence line up.
Section 5

Evidence checks before relying on the approved-mode result

Before a team relies on the workflow result, compare the service row against the Security Policy, algorithm certificate evidence, self-test coverage, operational environment, and any module configuration that prevents non-approved use. A service can be implemented with an approved algorithm and still fail the approved-service indicator logic if required testing, self-tests, or documented limits are missing.

The operator also has a role: CMVP guidance says the operator may need to retrieve, recognize, and act on the service indicator. For customer-facing or procurement evidence, show how a human operator, calling application, client process, or another module can obtain the indicator in the deployed configuration.

  • Verify the Security Policy contains the approved and non-approved service lists and describes each applicable indicator.
  • Check that CAVP certificate evidence and required self-tests support the approved implementation claimed for the service.
  • Confirm module configuration prevents non-approved service use where a global approved-service indicator depends on that configuration.
  • Document how the deployed operator retrieves the indicator, especially for APIs, status interfaces, logs, and concurrent service execution.
Section 6

Mistakes that break approved and non-approved mode evidence

Most failures come from collapsing service-level evidence into a single product-level statement. The safer pattern is to say exactly which service is approved, which indicator proves it, which Security Policy row explains it, and which non-approved behavior is blocked, allowed with no security claimed, or outside the approved mode.

Be especially careful with services that can change approval status based on parameters, service combinations, concurrent execution, or operator-controlled use outside the module. Those cases need clearer indicators and Security Policy interpretation than modules that only expose approved services.

  • Do not call a module service approved merely because one underlying algorithm appears on a validation certificate.
  • Do not rely on a FIPS 140-2-style global mode light when the module can run approved and non-approved security services concurrently.
  • Do not list a non-approved algorithm as allowed in approved mode unless its purpose is not security relevant and its key or CSP use satisfies the CMVP guidance.
  • Do not use the Security Policy to explain away an ambiguous indicator; the implemented indicator must let the operator distinguish the approved security service.
Primary sources

References and citations

csrc.nist.gov
Referenced sections
  • Grounds the main failure modes for this workflow: ambiguous indicators, unsupported no-security-claimed use, missing CAVP or self-test support, and overbroad global indicators.
"description in the security policy alone"
csrc.nist.gov
Referenced sections
  • Supports the workflow fields for non-approved algorithm purpose, no-security-claimed treatment, plaintext CSP handling, and key or CSP sharing limits.
"shall not share the same keys"
csrc.nist.gov
Referenced sections
  • Grounds evidence checks for Security Policy indicator descriptions, CAVP support, self-tests, and operator responsibility for using the indicator.
"operator of the module to retrieve"
csrc.nist.gov
Referenced sections
  • Use public certificate lookup as one evidence input, not as proof that every service or deployment mode is approved.
"validation-search"
doi.org
Referenced sections
  • Supports keeping claims tied to cryptographic modules and approved security functions rather than broad product statements.
"cryptographic modules that conform"
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