Launch Without FIPS: Real-World Scenarios and Best Practices

Launch Without FIPS: A Practical Guide for DevelopersFederal Information Processing Standards (FIPS) are a set of U.S. government standards for cryptographic modules and algorithms. “Launching without FIPS” means deploying an application, service, or system using cryptographic libraries or configurations that are not validated against FIPS requirements. This guide explains when and why a team might choose to launch without FIPS, the risks involved, how to mitigate them, technical steps to follow, and operational/organizational considerations.

When teams consider launching without FIPS

• Speed to market: FIPS-validated modules and configurations can add development and QA overhead. Teams with urgent release timelines may opt to use widely adopted, non-FIPS libraries to ship quickly.
• Third-party dependencies: Some open-source libraries or SaaS platforms used by your product may not be FIPS-validated.
• Non-U.S. or non-government customers: If your product’s customers are not subject to FIPS requirements, validation may be unnecessary.
• Prototype or internal-only deployments: Early-stage prototypes or internal tools may prioritize iteration speed over formal cryptographic validation.

Key point: Launching without FIPS is often a pragmatic choice for speed and flexibility, but it shifts responsibility to the development team to manage security and compliance risks.

Major risks of launching without FIPS

• Regulatory/compliance risk: Government agencies, contractors, or regulated industries may require FIPS-validated cryptography. Noncompliance can block sales or trigger contractual breaches.
• Cryptographic vulnerabilities: Non-FIPS libraries are not guaranteed to follow the strict implementation practices FIPS enforces. This increases the chance of subtle implementation flaws, incorrect key handling, or weak randomness.
• Customer trust and procurement: Some enterprise buyers expect FIPS validation as a baseline. Lacking it can make procurement harder.
• Audit and liability: In the event of a breach, lack of FIPS adherence may be scrutinized by auditors or litigators as a failure to follow industry-standard controls.

Risk-mitigation strategies

• Threat modeling and risk acceptance: Document the reasons for launching without FIPS and get formal risk acceptance from stakeholders (product, security, legal).
• Use widely vetted libraries: Prefer mature, actively maintained cryptography libraries with large user bases and security track records (for example, libsodium, OpenSSL, BoringSSL, or platform-native cryptography). Note: maturity ≠ FIPS validation.
• Enforce secure defaults and hardening:
  • Disable known-weak algorithms and cipher suites (e.g., SSLv3, RC4, MD5).
  • Prefer AEAD constructions (AES-GCM, ChaCha20-Poly1305) for symmetric encryption.
  • Use elliptic-curve algorithms (e.g., X25519, P-256) with appropriate parameters for key exchange and signatures where supported.
• Key management best practices:
  • Use Hardware Security Modules (HSMs) or cloud Key Management Services (KMS) where possible.
  • Enforce least-privilege access to keys.
  • Rotate keys on a schedule and after personnel changes or suspicious events.
• Use deterministic, auditable randomness sources:
  • Where possible, rely on OS-provided CSPRNG (e.g., /dev/urandom, getrandom, Windows CryptGenRandom or BCryptGenRandom) and validate during testing.
• Independent code review and fuzzing:
  • Have cryptographic code reviewed by experts.
  • Use fuzzing and property-based tests for crypto code paths.
• Logging, monitoring, and incident response:
  • Log cryptographic errors and anomalous key usage.
  • Build a runbook for crypto-related incidents (key compromise, algorithm vulnerability).
• Document compensating controls:
  • If not FIPS-validated, document alternative controls (HSMs, secure key lifecycle, encryption-at-rest and in-transit, strict configuration) for auditors and customers.

Technical steps to safely deploy without FIPS

1. Inventory cryptographic usage:
   • Map where and how crypto is used: TLS endpoints, data-at-rest, tokens, signatures, password storage, etc.
2. Standardize libraries and versions:
   • Lock to specific versions of cryptographic libraries with known CVE history.
3. Configure strong TLS:
   • TLS 1.2+ with TLS 1.3 preferred.
   • Use strong cipher suites: TLS 1.3 defaults or TLS 1.2 AEAD suites (AES-GCM, CHACHA20-POLY1305).
   • Enable HSTS, OCSP stapling, secure renegotiation.
4. Password storage and authentication:
   • Use adaptive KDFs: Argon2id, scrypt, or bcrypt with appropriate parameters.
   • Never use raw hashes or unsalted hashes.
5. Secure key storage:
   • Use HSM/KMS for private keys when possible.
   • Protect keys at rest with envelope encryption.
6. API and token security:
   • Use short-lived tokens (JWT with short exp) and rotate refresh tokens.
   • Sign tokens with robust algorithms (RS256, ES256, or better), avoid deprecated ones (HS256 with weak secrets).
7. Client-side cryptography:
   • Be cautious: browsers and mobile platforms may have limited or inconsistent crypto APIs. Prefer server-side crypto for sensitive operations unless you vet the client libraries carefully.
8. CI/CD and build integrity:
   • Reproducible builds and signed artifacts reduce supply-chain risk.
   • Scan dependencies for vulnerabilities (SCA tools).
9. Testing and validation:
   • Unit tests for cryptographic flows.
   • Integration tests with known vectors.
   • Regular security assessments and penetration testing.

Operational and organizational considerations

• Contracts and procurement:
  • Update contracts to disclose the lack of FIPS validation where relevant.
  • Provide customers with compensating control descriptions.
• Sales and customer conversations:
  • Prepare a clear, factual explanation of why FIPS was not used and what compensating controls exist.
• Roadmap for FIPS compliance:
  • If customers may later require FIPS, add validation to the product roadmap and estimate time/cost to rework crypto layers.
• Training:
  • Train engineers on secure crypto usage patterns and common pitfalls.
• Incident response:
  • Ensure key compromise procedures are documented and tested.

Example migration path to FIPS later

• Phase 1: Inventory and modularize cryptography (abstraction layers for crypto).
• Phase 2: Replace non-FIPS modules with FIPS-validated equivalents behind abstractions.
• Phase 3: Re-run integration tests, performance tests, and obtain FIPS certification (if needed).
• Phase 4: Update documentation, contracts, and customer communications.

Practical checklist before launch (short)

• Risk acceptance documented and signed.
• Inventory completed.
• Strong TLS and cipher suites enforced.
• Keys stored in HSM/KMS or equivalent controls.
• Secure password storage (Argon2id/scrypt/bcrypt).
• Dependency scanning and pinned versions.
• Logging and incident runbook in place.
• Customer-facing documentation on compliance posture.

Launching without FIPS can be a reasonable, pragmatic choice when speed or compatibility outweighs immediate formal validation. The crucial part is to accept and manage the added risks through strong engineering, documentation, and organizational controls so that security and compliance needs can be met even without FIPS validation.