I’ve been reviewing several recent RFPs for systems handling sensitive data, and a recurring requirement I'm seeing is for a FIPS 140-2 validated cryptographic module. While I understand the intent—to ensure a government-vetted standard for cryptographic security—I'm beginning to question whether this is always the appropriate or most effective requirement.
My concerns are primarily around two areas:
* **Scope Creep:** The requirement is often applied blanketly to entire applications or platforms, even when only a specific component (e.g., data-at-rest encryption, TLS termination) actually handles the cryptography. This can unnecessarily limit the vendor pool and increase cost, without a commensurate security benefit for the entire system.
* **Innovation Lag:** The validation process is lengthy. Insisting on FIPS 140-2 can sometimes mean locking out newer, potentially more secure cryptographic algorithms or implementations that are still working through the formal validation pipeline.
I believe the more critical question for an RFP should be: *What specific data flows or data-at-rest scenarios require FIPS-validated cryptography, and why?* The answer should dictate the scope of the requirement.
In our community's procurement experiences, I'm curious:
* In what deployment scenarios have you found a hard requirement for a FIPS 140-2 module to be non-negotiable and genuinely justified?
* Conversely, when have you seen it specified as a "checkbox" item where its practical value was minimal?
* For evaluations, do you score vendors on the *scope* of their validation (e.g., overall platform vs. specific module), or simply on a pass/fail basis?
I'm hoping we can develop a more nuanced rubric for this, moving beyond a binary checkmark to a more strategic evaluation of cryptographic controls.
—lucas
—lucas
Totally agree, especially on the innovation lag. We ran into this on a project that needed post-quantum cipher suites in the pipeline. Our compliance team's requirement for FIPS 140-2 across the board would've forced us to use an older TLS library, missing out on the newer, vetted algorithms that just hadn't completed the full validation paperwork yet. It created a real conflict between checking the compliance box and what our security architects actually recommended.
Your point about scoping the requirement is the key. It shouldn't be a binary, whole-platform flag. It's more like a linting rule for your infrastructure - you wouldn't enable `strict: all` for every file, you'd apply it to the specific modules handling sensitive logic. The RFP should define the cryptographic boundary, not just the product boundary.
Have you seen any RFPs that actually get this granular, or are they all still using the blanket clause?
editor is my home