Organizations that already have a FIPS 140-2 validation may assume that their work is finished. After all, the product already went through a formal validation process, so why would another validation be necessary?

The answer is that FIPS 140-2 and FIPS 140-3 are different standards. FIPS 140-3 replaced FIPS 140-2 as the current standard for new validations and introduced updated requirements for evaluating cryptographic modules. With that and the looming FIPS 140-2 sunset date approaching, all vendors considering an approach for FIPS 140 will need to validate to the newest version of the publication.

This post is the fourth installment in our Deconstructing FIPS 140-3: 5 Myths and Realities series, where we examine common misconceptions surrounding FIPS validation and explain what organizations should understand before beginning the certification process.

Myth #4:

“Our product has a FIPS 140-2 validation, so we don’t need FIPS 140-3.”

At first glance, this assumption seems reasonable. If a product has already completed FIPS validation, it can be easy to think that the existing validation automatically carries over to the newer standard.

Reality:

A FIPS 140-2 validation does not automatically make a product FIPS 140-3 validated.

FIPS 140-2 was the standard used to validate cryptographic modules for many years. FIPS 140-3 is its successor and was developed to update the requirements and align the U.S. standard more closely with international standards.

While FIPS 140-3 builds on many of the concepts found in FIPS 140-2, it also includes updated requirements and changes to how cryptographic modules are evaluated. FIPS 140-2 and even FIPS 140-3 validations have a sunset date, traditionally 5 years. However, all remaining FIPS 140-2 validations will be automatically sunset on Sept. 21, 2026.

For vendors selling into the U.S. federal government, the CMVP states that all modules with a status designation of Historical “should not be included by Federal Agencies in new procurements.”

If an organization has already invested significant time and resources into obtaining a FIPS 140-2 validation, it is understandable to assume that the existing validation should be sufficient for the newer standard. However, a FIPS 140-2 certificate does not simply become a FIPS 140-3 certificate. The two standards have different requirements, and organizations need to understand what their existing validation means and what requirements apply to their specific product and use case.

Validation & Boundaries

If an organization has already invested significant time and resources into obtaining a FIPS 140-2 validation, it is understandable to assume that the existing validation should be sufficient for the newer standard. However, a FIPS 140-2 certificate does not simply become a FIPS 140-3 certificate. The two standards have different requirements, and organizations need to understand what their existing validation means and what requirements apply to their specific product and use case.

Another important consideration is that FIPS validation applies to a specific cryptographic module and its defined configuration. It is not a blanket certification that automatically covers every version or configuration of a product.

This means that when a product is updated or a new version is released, organizations need to understand whether those changes affect the scope of the existing validation. The fact that an earlier version was validated does not necessarily mean that a newer version has the same validation status.

Moving From One Standard to the Next

For organizations with an existing FIPS 140-2 validation, the transition to FIPS 140-3 does not necessarily mean starting from scratch. The existing validation can provide a useful foundation for understanding what may need to change.

Planning early can help organizations identify differences between their current FIPS 140-2 validation and the requirements of FIPS 140-3. This can help teams anticipate potential design, documentation, and testing impacts before beginning a new validation effort.

The Takeaway

Having a FIPS 140-2 validation is valuable, but it should not be confused with having a FIPS 140-3 validation. As organizations plan new products, product updates, or future validation efforts, understanding the differences between the two standards is an important first step.

FIPS validation is not simply a label that applies to every version of a product. The applicable standard, validated module, configuration, and current requirements all matter.

Understanding where your product stands today can help ensure that your next step is the right one.

By the time organizations begin planning for FIPS 140-3 validation, they usually understand that documentation is required. Security policies, design documentation, finite state models, and other artifacts are all necessary components of the validation package.

Because of the volume of required documentation, it’s easy to assume that FIPS validation is primarily an exercise in writing documents. In reality, documentation is only one part of a much broader process that evaluates how a cryptographic module is designed, implemented, tested, and maintained.

This post is the third installment in our Deconstructing FIPS 140-3: 5 Myths and Realities series, where we examine common misconceptions surrounding FIPS validation and explain what organizations should understand before beginning the certification process.

Myth #3:

“FIPS validation is just a documentation exercise.”

At first glance, this assumption seems reasonable. Organizations often see the extensive list of required documents and conclude that success depends primarily on producing enough paperwork.

While documentation is essential, it exists to support something much larger such as demonstrating that a cryptographic module satisfies the security requirements defined by FIPS 140-3.

Reality:

Documentation supports validation but it doesn’t replace engineering, testing, or compliance.

A successful FIPS validation requires far more than completed documents. Every document must accurately reflect the implementation of the cryptographic module and align with the evidence generated throughout the validation process.

Organizations should expect work across multiple areas, including:

• Cryptographic module architecture and boundary definition
• Approved algorithm implementation
• Security function design
• Role, service, and authentication analysis
• Self-tests and operational testing
• Documentation required by the Cryptographic Module Validation Program (CMVP)
• Independent testing performed by an accredited laboratory

Documentation ties these pieces together, but it cannot compensate for implementation gaps or design issues discovered during testing. If engineering decisions and documentation do not align, the validation process often slows as teams revisit product design, update documentation, or correct implementation issues. The overall process requires close collaboration between engineering, documentation, testing, and program management to keep the project moving swiftly.

Why This Myth Persists

Documentation is often the most visible part of the validation process. Teams spend significant time preparing security policies, reviewing technical descriptions, and responding to documentation feedback, making it appear that paperwork drives the project.

In reality, documentation reflects decisions that have already been made throughout product development. Every requirement documented must be supported by the module’s actual behavior and verified during laboratory testing.

Organizations that wait until the documentation phase to identify design issues, frequently discover that changes are more expensive and time-consuming than if they had been addressed earlier.

A Better Approach

The most successful FIPS projects treat documentation as one component of an integrated validation strategy—not the final task before submission.

Planning early allows organizations to:

• Define the cryptographic boundary correctly.
• Identify design issues before formal testing begins.
• Ensure documentation accurately reflects implementation.
• Reduce rework during laboratory review.
• Keep engineering, testing, and documentation aligned throughout the project.

Approaching validation this way helps minimize delays while improving confidence that the module will successfully complete evaluation.

Organizations that are unsure where to begin don’t have to navigate the process alone. Corsec’s FIPS 140-3 Assessments help teams evaluate their current readiness, identify potential gaps early, and develop a practical path toward validation before formal testing begins.

Looking Ahead

Documentation is an essential part of every FIPS 140-3 validation, but it is only valuable when supported by sound engineering, accurate implementation, and successful testing. Viewing validation as a documentation-only effort can lead organizations to underestimate the technical work required and introduce unnecessary delays later in the project.

In the next installment of this series, we’ll examine another common misconception:

Myth #4: Once a product is FIPS validated, it never needs to be updated or maintained.

In the first installment of this series, we explored why incorporating a FIPS-validated cryptographic module into a product does not automatically make the product FIPS 140-3 validated. While understanding validation boundaries is critical, another common misconception often shapes organizations’ decisions much earlier in the product lifecycle. 

Many development teams assume FIPS 140-3 only matters if they plan to sell directly to the U.S. federal government. If federal contracts are not part of the business strategy, validation is often viewed as unnecessary. 

At first glance, this assumption seems reasonable. After all, FIPS standards are developed by the National Institute of Standards and Technology (NIST) for use by federal agencies. However, today’s cybersecurity landscape has significantly expanded the role of FIPS validation well beyond traditional government procurement. 

Myth 2: “FIPS Is Only Required for Federal Agencies” 

Reality 

While FIPS 140-3 originated as a federal security standard, its influence now extends across numerous commercial industries, regulated sectors, and global technology markets. Organizations pursuing FIPS validation are often motivated by customer requirements, contractual obligations, regulatory expectations, and competitive positioning and not by direct federal sales. Many organizations discover that FIPS validation becomes important because their customers expect it, their partners require it, or their industry recognizes it as an established benchmark for cryptographic assurance. 

Why This Myth Exists 

FIPS publications are issued by NIST, and federal agencies are required to use validated cryptography for protecting sensitive government information. Because of this, many organizations assume the standard applies exclusively to government systems. 

However, cybersecurity expectations have evolved considerably. As cyber threats have become more sophisticated, many organizations have adopted established security frameworks originally developed for government use. FIPS validation has become one of the most widely recognized methods for demonstrating that cryptographic functionality has undergone independent testing and evaluation. 

Today, many procurement teams consider FIPS validation an indicator of security maturity rather than simply a government requirement. 

Where FIPS Validation Is Commonly Requested 

Organizations are often surprised by where FIPS validation appears during the sales process. Some examples include:

• Government contractors supporting federal programs,
• State and local government projects,
• Critical infrastructure providers,
• Defense and aerospace organizations,
• Healthcare technology vendors,
• Financial services institutions,
• Cloud service providers, and
• Enterprise software vendors serving highly regulated industries.

In many cases, customers include FIPS requirements in procurement documentation even when they are not federal agencies themselves. As a result, organizations that previously believed FIPS was irrelevant may suddenly discover validation has become a prerequisite for pursuing new business opportunities. 

Beyond Compliance: Building Customer Confidence 

Validation requires independent testing through the Cryptographic Module Validation Program (CMVP) and the result is it provides customers with greater confidence that the cryptographic implementation performs as intended and meets established security requirements. 

For many organizations, validation serves as an objective way to demonstrate their commitment to protecting sensitive information. This can help strengthen customer trust, reduce lengthy security questionnaire discussions, and support purchasing decisions where cryptographic assurance is an important evaluation criterion. 

Planning Early Matters 

One challenge organizations frequently encounter is waiting until late in product development before considering FIPS validation. 

If validation requirements are introduced after product architecture has already been finalized, engineering teams may need to revisit cryptographic implementations, operational environments, documentation, or module boundaries. 

Addressing these considerations early allows organizations to make informed architectural decisions, better estimate project timelines, and reduce the likelihood of costly rework later in the validation process.

For help with planning and guidance, Corsec offers FIPS 140-3 Assessments. These engagements help clarify requirements, outline paths to validation, and give business leaders the information they need to make decisions on validation.

Looking Ahead 

The next installment in this series examines another common misconception: 

Myth #3: FIPS Validation Is Just a Documentation Exercise 

While documentation is certainly an important part of the process, successful validation depends on much more than producing the required paperwork. We’ll explore why engineering decisions, implementation details, testing, and documentation all play equally important roles in achieving FIPS 140-3 validation. 

For organizations developing products that rely on cryptography to protect sensitive information, FIPS 140-3 validation has become the benchmark for security compliance. Whether serving federal agencies, government contractors, critical infrastructure providers, or highly regulated industries, organizations often encounter FIPS 140-3 requirements as part of procurement, compliance, and security assurance efforts.

Despite its widespread recognition, FIPS 140-3 is frequently misunderstood. Teams may assume that using a validated cryptographic component automatically makes their product compliant. Product managers may view validation as a documentation exercise. Engineering teams may underestimate the technical meticulousness involved, while executives may question why validation is necessary at all.

These misconceptions can lead to delayed projects, unexpected costs, architectural rework, and missed market opportunities. More importantly, they can create a false sense of readiness when customers or procurement requirements demand validation.

This blog series, Deconstructing FIPS 140-3: 5 Myths and Realities, examines five common misconceptions that continue to shape how organizations approach cryptographic validation. We will explore how these assumptions affect product planning, development, compliance strategies, and go-to-market decisions.

We begin with one of the most common misconceptions in the industry which is confusing the use of validated cryptography with validation of the product itself.

Myth 1: “FIPS Inside” Is the Same as Being FIPS 140-3 Validated

Reality: Incorporating a FIPS-validated cryptographic module into a product does not automatically make the product FIPS 140-3 validated.

Organizations frequently advertise that their solution contains or utilizes validated cryptography. While this may be technically accurate, FIPS validation applies to the specific cryptographic module that underwent testing and validation through the Cryptographic Module Validation Program (CMVP). Simply inserting that module does not transfer validation status to the broader product.

Depending on how the cryptographic module is integrated, configured, and exposed to users, additional evaluation activities may be required to demonstrate adherence with FIPS requirements. Organizations must carefully understand the validation boundary, operational environment, and implementation details to accurately represent their security posture.

Confusing “FIPS Inside” with FIPS validation can create challenges during procurement reviews, customer assessments, and certification planning efforts. Understanding this distinction early helps organizations avoid costly misunderstandings and better prepare for validation activities.

For more information on FIPS Inside, download an in depth overview on the topic.

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Upcoming Myths in This Series

In the remaining posts, we will examine four additional myths that continue to influence FIPS validation strategies:

Myth 2: FIPS Is Only Required for Federal Agencies

Myth 3: FIPS Validation Is Just a Documentation Exercise

Myth 4: Our Product Has a FIPS 140-2 Validation, We Don’t Need FIPS 140-3

Myth 5: The Cost and Timeline of FIPS Validation Aren’t Justified

Each of these assumptions fail to capture the full reality of today’s validation landscape. Left unchallenged, they can influence decisions that impact product architecture, project timelines, security adherence, product readiness, and market access. Throughout this series, we will break down each myth, explain the underlying realities, and highlight practical considerations organizations should evaluate when developing a FIPS 140-3 validation strategy.

Successfully navigating FIPS 140-3 requires more than simply understanding the standard. It often demands early coordination across engineering, product management, compliance, and certification stakeholders. Organizations that align validation requirements with product development activities from the start are typically better positioned to avoid rework, reduce risk, and achieve validation more efficiently.

Corsec supports organizations throughout the FIPS 140-3 lifecycle from architectural reviews and validation planning to documentation development, laboratory coordination, testing support, and CMVP submission activities. If FIPS 140-3 validation is part of your action plan or becoming a requirement for your customers and target markets—engaging early can help establish a clear path forward. Contact Corsec to learn how your organization can approach FIPS 140-3 validation with confidence and ease.

Throughout this series, we explored some of the most common misconceptions surrounding Common Criteria certification which included assumptions about cost, timelines, to misunderstandings about maintenance and global recognition. While each myth addressed a different aspect of the process, together they reveal a larger truth: organizations that approach certification strategically are often far more successful than those reacting to misconceptions or incomplete information.

For many organizations, Common Criteria can initially appear overwhelming. The certification process is often associated with long timelines, extensive documentation requirements, and complex technical expectations. In many cases, these perceptions are shaped by secondhand experiences, outdated assumptions, or a lack of visibility into how evaluations actually work. As a result, organizations may delay pursuing certification, underestimate the preparation involved, or assume the process only applies to a narrow segment of the market.

However, Common Criteria certification is not designed to be an obstacle. At its core, it is a structured framework for validating security functionality and assurance activities in a consistent, internationally recognized way. Organizations that take the time to understand the process, define realistic goals, and plan strategically are often able to navigate evaluations more efficiently than expected.

While each myth focused on a specific concern, the broader takeaway remained consistent: successful certification efforts are often shaped by preparation, collaboration, and long-term planning. As we conclude the series, it is worth revisiting the key lessons organizations should understand when approaching Common Criteria evaluations.

To help organizations navigate Common Criteria Myths, Corsec has developed a document which outlines these 5 myths and an addition 5 that Corsec has identified over the years. Learn More

Lessons from Myths 1 – 5

Across the series, we examined several common misconceptions., we examined several common misconceptions surrounding Common Criteria certification. From assumptions about who certification applies to, to misunderstandings about cost, maintenance, and global recognition, each myth highlighted an important reality that organizations should understand before beginning the evaluation process.

• Myth 1: Common Criteria is not limited to government vendors. Certification can also support commercial market differentiation, customer trust, and procurement opportunities across industries.
• Myth 2: While evaluations require time and resources, successful certification can present immediate ROI.
• Myth 3: There is more than one way to navigate Common Criteria.
• Myth 4: An active Common Criteria Certification is a requirement in government and highly regulated industries.
• Myth 5: Common Criteria and the EUCC are tied to one another, not independent certifications.

Common Criteria certification is frequently misunderstood because organizations often encounter it only when a procurement requirement, customer request, or market opportunity suddenly makes certification necessary. Without context or prior experience, the process can appear more intimidating or restrictive than it actually is.

Many of the perceived barriers surrounding Common Criteria are rooted more in misconceptions than reality. Certification is not limited to government vendors, it is not exclusively relevant to Europe, and it is not simply a one-time technical checkbox. Instead, Common Criteria provides a consistent and globally recognized approach for demonstrating security assurance.

Organizations that approach evaluations strategically — with realistic expectations, strong internal collaboration, and long-term planning — are often far better positioned for successful outcomes. Many organizations also benefit from working with experienced evaluation partners who understand the complexities of the Common Criteria process. Structured guidance and evaluation support can help teams streamline preparation efforts, improve readiness, and avoid common pitfalls throughout the certification journey.

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