FIPS 140-3 Validation checklist

FIPS 140-3 applies to cryptographic modules used by federal agencies or operated for them under contract, and its adoption is also available to private and commercial organizations. CMVP validation is not a broad product certification; it validates the cryptographic module and gives procuring agencies a security metric for equipment containing validated modules.

Start the checklist only after the team can name the implementation under test, the module type, the cryptographic boundary, and the intended security level claim. If the answer is still the whole product, a cloud service, or a library name without a boundary diagram, the validation package is not ready.

The boundary evidence should let a reviewer separate the validated module from surrounding product code, excluded components, embedded validated modules, and the operational environment. For binding or embedding cases, the implementation guidance expects clear identification of the implementation under test and any external validated module the submission relies on.

Security level claims should be traceable to the FIPS 140-3 requirement areas, including module specification, interfaces, roles and authentication, software or firmware security, operating environment, physical security, non-invasive security, sensitive security parameter management, self-tests, life-cycle assurance, and mitigation of other attacks.

FIPS 140-3 conforming modules must employ approved security functions, including approved algorithms, key-management techniques, and authentication techniques. The checklist should therefore tie every service table entry to approved-mode behavior, non-approved functions with no security claimed, CAVP or component validation evidence, and the security policy wording that users will follow.

Entropy and self-test evidence should be checked early because they often affect the certificate, the security policy, the test report, and the allowed approved mode. The CMVP implementation guidance covers entropy caveats, deterministic random bit generator (DRBG) evidence, cryptographic algorithm self-tests, periodic self-testing, error logging, and software or firmware loading distinctions.

For SSP generation in approved mode, IG 9.3.A sets a concrete gate: if the known amount of entropy used to generate the SSP is less than 112 bits, the module cannot be validated. When the source is outside the Tested Operational Environment's Physical Perimeter or the module only passively receives entropy, the applicable assurance caveat, minimum-input control, and operator guidance must also be captured; the exact branch depends on how the module obtains the entropy.

The security policy is the public-facing control description that must stay aligned with the tested module. Before submission, compare the security policy, test report inputs, user guidance, crypto officer guidance, service tables, algorithm tables, entropy claims, and operational-environment listings for internal consistency.

FIPS 140-3 validation testing is performed by accredited CST laboratories, and a test report for modules demonstrating compliance is submitted to CMVP for review and validation. The schedule is coordination-dependent, so the checklist should focus on completeness and traceability rather than promising a fixed review duration.

Record the FIPS 140-3, SP 800-140-series, Implementation Guidance, Management Manual, Security Policy template, and algorithm-transition editions used for the package. CMVP guidance and submission resources change; recheck the official CMVP pages before laboratory testing, submission, revalidation, and any material claim update.

A validation checklist is incomplete if it stops at the first certificate. Module changes, excluded component changes, algorithm transitions, operational-environment changes, firmware or software loading changes, and embedded-module status changes can affect whether the validation evidence still matches the module being shipped.

Keep a maintenance record that separates changes requiring laboratory or CMVP review from ordinary engineering records. Unsupported statements such as "FIPS validated product" should be removed unless the shipped configuration matches the module certificate, boundary, version, caveats, and operating environment.

Use the checklist result as a validation-readiness record. Each row should state the verifiable condition, responsible owner, expected evidence, source or assertion reference, result, exception or open question, and whether the issue blocks CST laboratory testing, CMVP submission, procurement reliance, or customer-facing claims.