By NIST’s schedule, every FIPS 140-2 certificate is now on the Historical List. The Cryptographic Module Validation Program (CMVP) said FIPS 140-2 validations could be used “until September 21, 2026, when the FIPS 140-2 validations will be moved to the historical list,” and its transition schedule places all FIPS 140-2 certificates there on September 22, 2026. It has accepted no FIPS 140-2 submissions for new certificates since April 1, 2022.
What historical means
Historical is not revoked. In the CMVP’s words, if a validation certificate is marked as historical, “Federal Agencies should not include these in new systems but can be procured for legacy systems,” and this “does not mean that the overall FIPS-140 certificates for these modules have been revoked.” Agencies “may make a risk determination on whether to continue using the modules on the Historical list,” and the CMVP says that “even on the historical list, CMVP supports the purchase and use of these modules for existing systems.”
A system already running a FIPS 140-2 module can keep it if its agency accepts the risk. A new system should be built on FIPS 140-3 modules.
What FedRAMP’s 2026 rules ask
FedRAMP’s Consolidated Rules for 2026 call for cryptographic modules “with active validations under the NIST Cryptographic Module Validation Program,” and a historical certificate is no longer active. How firmly they ask depends on the class: Class B providers may use modules with active validations, Class C providers should, and Class D providers must. Providers must also document the cryptographic modules each service uses, and whether each is validated or an update stream of a validated module.
FedRAMP’s help center answers the case many providers are in, where the FIPS 140-3 version of a module is still waiting for NIST. It gives three options:
- Move to an approved FIPS 140-3 module, through the significant change process.
- Stay on the historical module until the FIPS 140-3 version is available, tracked as an open vulnerability.
- Move early to the FIPS 140-3 version before it completes certification, also tracked as an open vulnerability.
FedRAMP leaves the choice with the provider: “It is your job as the CSP to manage those risks.”
What to do now
The same steps apply to defense contractors: requirement 3.13.11 of NIST SP 800-171 asks for FIPS-validated cryptography when it protects the confidentiality of CUI.
- List every cryptographic module in your boundary, with its certificate number and its status in the CMVP’s validated modules search. Operating systems, libraries, appliances and cloud services all count.
- For each FIPS 140-2 module, check whether its vendor has a FIPS 140-3 certificate, or a module on the CMVP’s Modules In Process list.
- Plan each move through change management, and for a FedRAMP service through significant change.
- Record each module that cannot move yet as an open risk, with the reason and the date its replacement is expected, so your authorizing official decides on it with the facts.
- Build new systems on FIPS 140-3 modules.
How we can help
Our cryptographic inventory finds where your systems establish keys and sign, and the libraries underneath them, and our AFIPS model maps each one to the validated module doing the work. The same inventory is the first step of a post-quantum migration. For the background, read our introduction to FIPS 140.
Sources
- NIST CMVP, FIPS 140-3 Transition Effort (opens in a new tab): the September 21 and 22, 2026 dates, the end of FIPS 140-2 submissions on April 1, 2022, and the use of historical modules in existing systems.
- NIST CMVP, Validated Modules (opens in a new tab): what a historical certificate means.
- FedRAMP, Consolidated Rules for 2026, Cryptographic Module Use for Class B (opens in a new tab), Class C (opens in a new tab) and Class D (opens in a new tab): rules CMU-CSO-UVM and CMU-CSO-CMD.
- FedRAMP help center, Will FedRAMP provide guidance on the sunsetting of FIPS 140-2? (opens in a new tab): the three options.