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FIPS 140-3 Validation checklist

A pre-validation checklist for engineering and CMVP lab readiness, optimized to reduce rework.

Use this before you engage a CST laboratory or before you freeze your validation scope.

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Author

Sorena AI

Published

Mar 4, 2026

Updated

Mar 4, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Mar 4, 2026

Updated Mar 4, 2026

Overview

This checklist is designed to catch the usual FIPS 140-3 validation failures early: boundary ambiguity, inconsistent approved-mode claims, incomplete services mapping, weak SSP evidence, and documentation that does not match what is tested. Use it as an internal gate before lab submission, and record the exact CMVP guidance baseline you are using.

Section 1

1) Scope and boundary

If the cryptographic boundary is unclear, interfaces, roles, services, SSP handling, self-tests, and documentation all become unstable. Freeze the boundary early and treat scope changes as architecture changes.

Boundary diagram is complete, versioned, and explicit about what is inside and outside the module
All interfaces crossing the boundary are enumerated, including admin paths and debug paths
Operational environments, platforms, firmware, and toolchain assumptions are pinned
Embedded or bound modules are identified with exact certificate and version information
Any remaining FIPS 140-2 dependency or transition assumption is explicitly recorded

Section 2

2) Roles, services, and authentication

Your services list is a key input to the lab test plan. Every security-relevant service should be complete, stable, and linked to SSP access and approved-mode behavior.

Roles are clearly defined and least-privilege oriented
Authentication behavior is documented and testable, including reset and replacement flows
Every service includes inputs, outputs, SSP access, approved-mode behavior, and error behavior
There is a reviewed services-to-approved-security-functions map
Non-approved services are clearly identified and cannot be confused with approved services

Section 3

3) Approved mode of operation

Approved mode is a proof problem. The implementation, documentation, and tests all need to show the same approved-mode story.

Approved mode entry and exit conditions are explicit and testable
Service indicator behavior is defined and matches runtime behavior
Approved and non-approved algorithms are separated in code paths and docs
The Security Policy, service map, and tests describe the same approved-mode scope
The current CMVP Implementation Guidance revision is named in the evidence pack

Section 4

4) Algorithms and dependencies

Teams often fail here by assuming an algorithm is approved without proving validation coverage or dependency control. Keep one authoritative source of truth for algorithm use per build and environment.

Approved security functions are enumerated and tied to concrete implementations
Build flags and configuration controls for cryptographic functions are auditable
Crypto dependencies are pinned and their provenance is recorded
Embedded or bound crypto components are documented precisely where used
Supporting certificates or dependency evidence are retained where the submission relies on them

Section 5

5) Self-tests

Self-tests are operational requirements, not theory. They must run in the right state, fail safely, and generate evidence a lab can inspect.

Pre-operational self-tests are implemented and evidenced
Conditional self-tests and error states are documented and tested
Failure behavior blocks cryptographic operation where required
Logs or indicators for self-test status are defined
Self-tests are exercised for each validated build and environment

Section 6

6) SSP management and zeroization

Sensitive Security Parameter handling is usually evidence-heavy. Plan the evidence before lab work, not after.

SSP lifecycle is documented from generation or establishment through storage, use, and destruction
Zeroization methods are defined per storage type and are testable
Entropy and SSP-establishment assumptions are documented against the applicable SP 800-140 and IG rules
SSP access is mapped by service and role
Backup and recovery flows do not create shadow SSP stores outside the boundary

Section 7

7) Documentation pack

The CSTL works from your documentation. If those artifacts do not line up with implementation reality, the project slows down.

Security Policy matches boundary, services, approved mode, SSP handling, and self-tests
Supporting documents reflect the SP 800-140 documentation and policy expectations the lab is using
Module and interface descriptions match the current code and hardware reality
Configuration-management and release-governance evidence exists for validated builds
Test scripts, configs, logs, and expected outputs are packaged and repeatable

Section 8

8) Post-validation maintenance controls

Validation is not the end of the problem. Protect the validated state with strict but lightweight change control.

Validated versions and tested environments are pinned internally
There is a change gate for boundary, algorithm, SSP, and platform changes
Dependency updates are classified for validation impact
Evidence refresh has an owner and cadence
Customer-facing claims are reviewed so validated, compliant, and embedded-module language stays accurate

Recommended next step

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