QTS-09.4: Post-Quantum Cryptography (PQC) Validation Requirements
Mechanisms exist to configure Technology Assets, Applications and/or Services (TAAS) to use FIPS 140-3 validated cryptographic modules, where applicable.
Control Question: Does the organization configure Technology Assets, Applications and/or Services (TAAS) to use FIPS 140-3 validated cryptographic modules, where applicable?
Capability Maturity Model
Level 0 — Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 — Performed Informally
Quantum Security (QTS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
Level 2 — Planned & Tracked
Quantum Security (QTS) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with QTS domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are documented and maintained by process owners.
Level 3 — Well Defined
Quantum Security (QTS) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with QTS domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are well-documented and kept current by process owners. ▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain QTS domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with QTS domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to configure Technology Assets, Applications and/or Services (TAAS) to use FIPS 140-3 validated cryptographic modules, where applicable.
Level 4 — Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 — Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
Assessment Objectives
- QTS-09.4_A01 Technology Assets, Applications and/or Services (TAAS) are configured to use FIPS 140-3 validated cryptographic modules, where applicable.
Technology Recommendations
Micro/Small
- Use cloud provider services with FIPS 140-3 validated cryptographic modules
- Prefer managed services over self-hosted cryptography
Small
- Use FIPS 140-3 validated cryptographic libraries and services
- NIST CMVP validation list (https://csrc.nist.gov/projects/cryptographic-module-validation-program)
Medium
- FIPS 140-3 validated module requirements for cryptographic operations
- Track NIST CMVP PQC validation certificates
- Policy mandate for validated modules where applicable
Large
- Enterprise policy requiring FIPS 140-3 validated modules
- Validation tracking in cryptographic asset inventory
- HSM with FIPS 140-3 validation for key management
Enterprise
- Enterprise FIPS 140-3 validation requirement enforcement
- Automated validation status tracking in cryptographic inventory
- HSM infrastructure with FIPS 140-3 Level 3 validation
- Continuous compliance monitoring for cryptographic module validation