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Jimmy Jung 703 851 6813 |
PS -
in the first paragraph of draft 63B-4, 2.2.2; does replay-resistant and authentication intent apply to all AAL2 or just authenticators procured by federal agencies?
63B#0090 |
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Federal agencies SHALL only procure authenticators which have been validated as meeting FIPS 140 Level 1 or higher. |
63B#0120 |
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Federal agencies SHALL only operate verifiers which have been validated as meeting FIPS 140 Level 1 or higher. |
63B#0120 is taken word for word from 800-63B and requires “verifiers to meet FIPS 140 Level 1 or higher.” It seems likely that this is a companion to 63B#0090 which requires authenticators that meet FIPS 140,
indicating that the authenticator and the verifier should BOTH operate at FIPS 140; however, “verifiers” generally refers to an organization, typically the CSP. FIPS 140 identifies Security Requirements for devices, specifically cryptography; applying it
as a criteria to an organization is awkward. In 63B#0090, the NIST language and our guidance ONLY applies this to authenticators
“procured” by federal agencies; allowing for “bring-your-own” authenticators that do not meet FIPS 140. Which is to say, the criteria specifically allows authenticators in 63B#0090 that do not meet the criteria of 63B#0120. The following
options are suggested for consideration:
It should be noted that this only applies to federal agencies (and we do have agencies with or applying for certification).
OPTION |
63B tag |
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KI_criterion |
Note - guidance will be added as KI-IAWG members develop it in response to usage & experience |
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1 |
63B#0120 |
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Withdrawn - addressed by 63B#0090 |
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2 |
63B#0120 |
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Federal agencies SHALL only operate verifiers which have been validated as meeting FIPS 140 Level 1 or higher. |
As described in 63B#0090, this is intended to exempt user-provided (“bring-your-own) authenticators from having to meet the FIPS 140 requirements, particularly on
the government-to-public use case. |
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3 |
63B#0120 |
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Federal agencies SHALL
verify FIPS 140 Level 1 (or higher) authenticators using equivalent cryptography. |
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4 |
63B#0120 |
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Cryptography used by verifiers operated by or on behalf of federal agencies at AAL2 SHALL be validated to meet the requirements of [FIPS140] Level 1. |
As described in 63B#0090, this is intended to exempt user-provided (“bring-your-own) authenticators from having to meet the FIPS 140 requirements, particularly on
the government-to-public use case. |
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KIAF-1440