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FIPS 140-3 — When 'Validated' Actually Means Something

FIPS 140-3 raised the bar on cryptographic module validation. If you sell into federal, healthcare, or banking, the deadline already passed.

Author

Hiroshi Tanaka

OT Security Lead

Published

January 7, 2026

Read

9 min

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Key Takeaways
  • 01FIPS 140-3 has been the target since September 2020. New 140-2 validations stopped April 2022; existing 140-2 validations move to historical five years post-cert. If you ship into federal, healthcare, or banking, the migration is overdue.
  • 02Validation tests module specification, interfaces, role-based authentication, self-tests, and lifecycle assurance — not just algorithm correctness.
  • 03Levels 1–4 increase from algorithm correctness to full physical tamper resistance. Most software targets Level 1; HSMs target 3–4. Targeting above your real assurance need wastes engineering time.
  • 04Standardize on a small set of validated modules (one OS-level, one HSM, one application-level), centralize the choice in a platform team, and let product teams consume rather than choose.

FIPS 140-3, the federal standard for cryptographic modules, has been the target standard since September 2020. New 140-2 validations stopped in April 2022, and existing 140-2 validations move to the historical list five years after their final certification date.

If your product, service, or pipeline relies on a cryptographic module that is not on the active 140-3 validated module list, you have a procurement problem and a contracts problem.

What validation actually tests

  • 01Module specification — boundary, modes, supported algorithms
  • 02Cryptographic module interfaces — control of inputs, outputs, error states
  • 03Roles, services, authentication — separation of crypto officer and user
  • 04Self-tests — power-up and conditional tests for algorithms and integrity
  • 05Lifecycle assurance — secure delivery, configuration, end-of-life

The four security levels

Levels 1 through 4 increase from basic algorithm correctness to full physical tamper resistance. Most software products target Level 1; HSMs and high-assurance hardware target Levels 3 and 4. Choosing a level above your real assurance need wastes money and engineering time.

Sourcing 140-3 modules without slowing engineering

Standardize on a small number of validated modules — typically one for OS-level (e.g., the platform's validated cryptographic library), one for HSM operations, one for application-level (e.g., a validated build of OpenSSL or BoringCrypto). Centralize the module choice in a shared platform team, and let product teams consume rather than choose.

#FIPS 140-3#Cryptography#Federal

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Hiroshi Tanaka

OT Security Lead · Alexa Cybersecurity