Launch Without FIPS: Mitigations to Keep Your Release SecureReleasing a product or service without FIPS (Federal Information Processing Standards) compliance can be the right choice for speed, flexibility, or cost reasons — but it also changes your security posture and regulatory obligations. This article explains what “launch without FIPS” means, why teams choose it, the main risks, and practical mitigations to keep your release secure while you iterate toward full compliance if needed.
What “Launch Without FIPS” Means
FIPS refers to a set of U.S. government standards for cryptographic modules and algorithms (notably FIPS 140-2 and FIPS 140-3). Launching without FIPS typically means your product will not use FIPS-validated cryptographic libraries or run in a FIPS-validated mode at release time. That can affect encryption, random number generation, key management, and other cryptographic operations that many regulated customers expect to be FIPS-validated.
Teams may launch without FIPS for reasons such as time-to-market pressure, dependency complexity, unsupported platforms, or waiting for vendor FIPS validations to complete.
Why Teams Choose to Launch Without FIPS
- Speed: FIPS validation can add months to development timelines due to library selection, architectural changes, policies, and testing.
- Platform constraints: Some platforms or third-party components lack FIPS-validated options.
- Cost and resource limitations: Achieving and maintaining validation requires dedicated engineering, documentation, and often third-party audit expense.
- Iterative development: Startups and product teams may prioritize core functionality and user feedback before full regulatory compliance.
While reasonable, launching without FIPS requires compensating controls to protect users, customers, and the business.
Key Risks of Launching Without FIPS
- Customer trust and procurement: Regulated customers (government, defense, certain enterprises) may require FIPS; lack of it can block sales.
- Cryptographic assurance: Non-FIPS modules might implement cryptography correctly, but they lack third-party validation; misconfigurations or subtle bugs are more likely.
- Legal/regulatory exposure: Contracts or regulations may mandate FIPS for certain data types or workflows.
- Operational complexity: Later migration to FIPS can require rework of key stores, protocols, and deployment pipelines.
Mitigations to Keep Your Release Secure
Below are practical mitigations organized by engineering, operational, and policy controls. Many are complementary — use as many as feasible given your product, timeline, and customer requirements.
1) Choose Well-Maintained, Widely Used Crypto Libraries
- Select reputable cryptographic libraries with active maintainers and a strong security track record (e.g., OpenSSL, BoringSSL forks, libsodium, Windows CNG, Java’s JCE).
- Prefer libraries that offer a FIPS mode or are on a clear path to FIPS validation; this reduces future migration work.
- Keep dependencies up to date and monitor CVEs for the chosen libraries.
2) Use Modern, Safe Algorithms and Configurations
- Default to strong, standardized algorithms: AES-GCM or ChaCha20-Poly1305 for symmetric encryption; ECDSA or Ed25519 for signatures; ECDH or X25519 for key agreement.
- Avoid deprecated algorithms and modes (e.g., MD5, SHA-1, RSA PKCS#1v1.5 for signatures without proper padding protections).
- Enforce secure parameter sizes (e.g., 256-bit ECC curves, 128+ bit symmetric keys).
3) Secure Key Management
- Protect keys with hardware-backed storage where available (TPM, Secure Enclave, HSM, cloud KMS).
- Implement key lifecycle policies: rotation, expiration, revocation, and minimal privileges.
- Restrict access to key material via role-based access control (RBAC) and audit logging.
4) Defense-in-Depth for Cryptographic Operations
- Combine transport-layer security (TLS) with end-to-end or application-layer encryption for sensitive data.
- Use short-lived session keys and perfect forward secrecy (PFS) ciphersuites for TLS.
- Utilize authenticated encryption to prevent tampering and misuse.
5) Harden TLS/PKI Configurations
- Use TLS 1.2+ with modern ciphersuites and prefer TLS 1.3 where possible.
- Disable insecure features (SSLv3, TLS 1.0/1.1, weak ciphers, renegotiation if risky).
- Implement certificate pinning or strict certificate validation for sensitive clients, where practical.
6) Strong Randomness and Entropy Management
- Ensure cryptographic random number generators use OS-provided CSPRNGs (e.g., /dev/urandom, BCryptGenRandom, SecureRandom).
- For embedded or virtualized environments with limited entropy, use hardware RNGs, entropy daemons, or cloud provider entropy services to seed generators reliably.
7) Secure Defaults and Fail-Closed Behavior
- Ship conservative, secure defaults for encryption, authentication, logging, and telemetry: enable encryption by default; minimize exposed interfaces.
- On cryptographic library or hardware failures, fail closed (deny access) rather than silently falling back to weaker algorithms.
8) Transparency and Documentation
- Document your cryptographic choices, threat model, known limitations, and roadmap to FIPS (if applicable). Customers and auditors value transparency.
- Provide clear guidance for customers about supported configurations for higher assurance deployments.
9) Compensating Controls for Compliance Gaps
- If FIPS is legally or contractually required for specific customers, offer alternatives: deployable versions with validated modules, or private instances/managed services that use FIPS-validated components.
- Consider contractual controls such as limited warranties, data segregation, or attestation to reasonable security practices.
10) Rigorous Testing and Continuous Monitoring
- Perform regular cryptographic code reviews and threat modeling focused on crypto misuse.
- Run fuzzing and unit tests around parsing, key handling, and protocol boundaries.
- Use runtime monitoring to detect crypto failures, suspicious authentication patterns, or abnormal certificate changes.
11) Secure Build and Deployment Pipelines
- Protect build artifacts, sign releases, and verify integrity at install time.
- Ensure CI/CD systems use secret management and do not leak keys or credentials.
- Maintain reproducible builds or build provenance records to aid audits.
12) Plan and Roadmap to FIPS (if needed)
- If customers require it, create a prioritized migration plan: select validated modules, schedule integration and testing, and budget for validation/audit.
- Prototype a FIPS-mode path early to find architectural mismatches (e.g., RNG assumptions, library APIs).
- Consider vendor-managed FIPS options (cloud KMS with FIPS, HSM-backed services) to reduce validation burden.
Example Migration Checklist (Short)
- Inventory all cryptographic usage and libraries.
- Identify platform-specific gaps (OS RNG, hardware support).
- Replace or abstract crypto calls to allow FIPS-mode swap.
- Integrate with FIPS-capable key stores (HSM/KMS/TPM).
- Run conformance tests and engage a validation lab if pursuing full FIPS certification.
Communication and Sales Considerations
- Be proactive with customers: explain why you launched without FIPS, list mitigations in place, and provide a timeline or options for FIPS-capable deployments.
- Offer technical documentation, readouts of security practices, and contracts that address customer risk concerns (e.g., SOC reports, penetration test results).
When Launching Without FIPS Is Acceptable
- Non-regulated markets where customers don’t require FIPS.
- Early-stage products prioritizing feature validation and rapid feedback.
- When immediate use of FIPS-validated libraries would introduce unacceptable platform limitations or delays, and compensating controls reduce risk.
When It’s Not Acceptable
- You must meet regulatory, contractual, or legal requirements mandating FIPS for specific data types or customers.
- Products that process classified or regulated government data where FIPS-certified cryptography is explicitly required.
Final Notes
Launching without FIPS can be a pragmatic choice if you apply layered mitigations, remain transparent with customers, and maintain a clear roadmap to higher assurance where required. Focus on strong algorithms, key management, secure defaults, and operational controls to reduce risk while preserving speed and flexibility.
If you want, I can:
- produce a one-page executive summary for customers explaining your mitigations;
- map your current architecture to a prioritized FIPS migration plan; or
- draft a technical FAQ to include with releases.
Leave a Reply