AGILICRYPT™ Briefing

The case for checking before the assessment, not during it

For: whoever signs off security spend or the affirmation  ·  Length: one page  ·  Decision needed by: before your next assessment or contract action

On 21 September 2026 every FIPS 140-2 certificate moves to historical status. This is a scheduled NIST transition, not an incident. It reaches defense contracts because FIPS-validated cryptography is a contractual requirement, and it is the kind of finding that is cheap to fix early and expensive to meet for the first time in an assessment.

Why it reaches us at all

DoD contract → involves CUI → carries DFARS 252.204-7012 → requires NIST SP 800-171 → control 3.13.11 requires FIPS-validated cryptography → and validation is what changes on 21 September.

Nothing stops working on the 22nd. Deployed systems keep running, and continued use is permitted on an assessment of where and how each module is used. What changes is standing — the evidence behind the control. It bites at an assessment or a contract action, not on the date.

The part that is easy to miss

21 September is the largest date on the calendar, not the last one. Another 53 certificates lose standing between then and the end of 2027 — Amazon Web Services' Key Management Service HSM on 17 November, for one, which is 57 days after the cliff, when the assessments are filed and nobody is looking again. An answer that was correct in September is quietly wrong by November, and nothing announces it.

That calendar is published in full, free, at agilicrypt.com/renewals. Every row links to NIST so it can be checked at the source rather than taken on trust.

Two outcomes from the same estate

Two organizations running identical systems get different assessment results. The difference is not the technology — it is whether the gap was found, classified and documented before anyone came to look.

 Found earlyFound in the assessment
What the assessor sees A documented gap with a plan, dates and vendor correspondence An unknown, discovered live
Vendor evidence Written answers already on file Requested under time pressure, if at all
Remediation Sequenced; purchases have lead time Whatever can be done before the report is issued
Cost Planned Unplanned, plus the cost of a re-assessment

What it costs to answer it properly

Doing this by hand means mapping every cryptographic component in the estate to a CMVP certificate, then checking whether that certificate names the exact version deployed. Take your own loaded rate for an engineer who can read a CMVP certificate and multiply it by two weeks. That is the comparison, and it is your number rather than ours.

It is also the optimistic version, because the traps are not obvious. Two Windows cryptographic modules have names where one contains the other word-for-word, and only one of them has a pending submission. Several hundred certificates name no version at all in the public table — the versions are in a PDF. Windows Server 2019's certificates cover two exact revisions and Server Core only. Each of those, got wrong, produces a confident answer that is false.

What is actually delivered

What this is not

It is not a compliance determination, and we are careful about that. We are not a testing laboratory, we do not certify cryptographic modules, and we are not a C3PAO. Your assessor decides whether you meet the control; you make the affirmation. We produce the measurement and the evidence, independently and early enough to act on. The full boundary is published, including the questions we refuse to answer.

The decision

Check one machine for $100, or the estate for $5,000

The $100 trial produces a real report on one system — enough to see the output and judge whether the answer is worth having for everything else. The full assessment covers the estate and includes the plan, the vendor letters and the re-run.

Nothing is installed and nothing is scanned. It reads an inventory export you already produce, and the tool contains no networking code at all — which is checkable, in about a minute, on your own machine.

Start with one machine — $100 Read a complete sample report

Questions worth asking us before you decide: what happens if the answer is that we cannot tell; what the report says when a vendor has published nothing; and what we do with your inventory afterwards. The answers are, in order: it says so and explains what would settle it; it asks rather than accuses; and nothing you send leaves your own machine unless you send it to us yourself.