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PCI_HSM_Security_Requirements_v4_Summary_of_Changes.pdf
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HSM_Security_Requirements_v5_Summary_of_Changes.pdf
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Content Changes
12 content changes. 13 administrative changes (dates, page numbers) hidden.
Added
p. 3
Table 2: Summary of Changes Document and Requirements Change Type Specified that multiple test requirements require the test laboratories to review source code to facilitate validation to the applicable Security Requirements, unless otherwise specified. This was an FAQ moved into the DTRs.
Additional Guidance Throughout the document, changed to the test laboratory, instead of the vendor, shall prepare the Asset Flow Analysis. Separated the process of Analysis from the output of a Diagram.
Requirement Change Throughout the document, specified that TDES keys of any size must not be used for device security purposes (such as firmware authenticity, device-level key storage, etc.), and that cryptography used for this purpose implements effective key strength of 128 bits or stronger.
Requirement Change General Added definition of “impractical” or “not practical” wherever used in testing requirements.
Additional Guidance General Throughout the document, changed references from ASC X9 TR-31 to ANSI X9.143.
Additional Guidance Stipulated that references to a controlled …
Additional Guidance Throughout the document, changed to the test laboratory, instead of the vendor, shall prepare the Asset Flow Analysis. Separated the process of Analysis from the output of a Diagram.
Requirement Change Throughout the document, specified that TDES keys of any size must not be used for device security purposes (such as firmware authenticity, device-level key storage, etc.), and that cryptography used for this purpose implements effective key strength of 128 bits or stronger.
Requirement Change General Added definition of “impractical” or “not practical” wherever used in testing requirements.
Additional Guidance General Throughout the document, changed references from ASC X9 TR-31 to ANSI X9.143.
Additional Guidance Stipulated that references to a controlled …
Added
p. 4
Requirement Change SR B1 Specified that the requirement must be met in both PCI and non-PCI mode.
Requirement Change SR B3.1 Clarified that the device must enforce application authentication and not just support the authentication.
Requirement Change SR B5 Added additional criteria for clearing internal buffers and eliminated Transaction Completed as a category.
Requirement Change SR B7 Moved SR B7 to Evaluation Module 2 as D1. Requirement Change SR B7 Specified that the requirement must be met in both PCI and non-PCI mode.
Requirement Change SR B10 Specified that the requirement must be met in both PCI and non-PCI mode.
Requirement Change SR B19 Added requirement for secure state. Requirement Change SR B20 Added requirement for secure connections. Requirement Change SRs D1
• D5 (v4) Deleted existing section on Key-Loading Devices. Requirement Change SR D1
• D6 (v5) Added Evaluation Module for Key-Transfer Functionality. Requirement Change SR D1 Modified to include both key entry and export. Requirement …
Requirement Change SR B3.1 Clarified that the device must enforce application authentication and not just support the authentication.
Requirement Change SR B5 Added additional criteria for clearing internal buffers and eliminated Transaction Completed as a category.
Requirement Change SR B7 Moved SR B7 to Evaluation Module 2 as D1. Requirement Change SR B7 Specified that the requirement must be met in both PCI and non-PCI mode.
Requirement Change SR B10 Specified that the requirement must be met in both PCI and non-PCI mode.
Requirement Change SR B19 Added requirement for secure state. Requirement Change SR B20 Added requirement for secure connections. Requirement Change SRs D1
• D5 (v4) Deleted existing section on Key-Loading Devices. Requirement Change SR D1
• D6 (v5) Added Evaluation Module for Key-Transfer Functionality. Requirement Change SR D1 Modified to include both key entry and export. Requirement …
Added
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Requirement Change SRs G1
• G4 (v4) Deleted existing section on Devices with Key-Generation Functionality.
Requirement Change SRs H1
• H2 (v4) Deleted existing section on Devices with Digital-Signature Functionality.
Requirement Change
• I3 (v4)
• moved to Key-Management Operations Draft Standard.
• moved to Key-Management Operations Draft Standard.
• K3, K6, K8
• K9 (v4) Deleted and moved to Key-Management Operations Draft Standard.
Requirement Change SR K10 (v4)/G11 (v5) Moved public-vulnerability-management requirement to Evaluation Module 5
• Life Cycle Security Requirements.
Requirement Change SRs I1, I4
• I5, J6, J8, K4
• K5 (v4) Consolidated into the new single Multi-tenant HSM Section F.
Requirement Change SRs F1
• F8 (v5) Added Evaluation Module for HSM Solution Security. Requirement Change SR F1 (v5) Added criteria for where restricted to deployment in a controlled or higher environment.
Requirement Change SR F4 (v5) Eliminated inclusion of registers, cache, and scratchpad memory.
Requirement Change SR F5 (v5) Added option that firmware downgrades can occur if the downgrade occurs as a sensitive …
• G4 (v4) Deleted existing section on Devices with Key-Generation Functionality.
Requirement Change SRs H1
• H2 (v4) Deleted existing section on Devices with Digital-Signature Functionality.
Requirement Change
• I3 (v4)
• moved to Key-Management Operations Draft Standard.
• moved to Key-Management Operations Draft Standard.
• K3, K6, K8
• K9 (v4) Deleted and moved to Key-Management Operations Draft Standard.
Requirement Change SR K10 (v4)/G11 (v5) Moved public-vulnerability-management requirement to Evaluation Module 5
• Life Cycle Security Requirements.
Requirement Change SRs I1, I4
• I5, J6, J8, K4
• K5 (v4) Consolidated into the new single Multi-tenant HSM Section F.
Requirement Change SRs F1
• F8 (v5) Added Evaluation Module for HSM Solution Security. Requirement Change SR F1 (v5) Added criteria for where restricted to deployment in a controlled or higher environment.
Requirement Change SR F4 (v5) Eliminated inclusion of registers, cache, and scratchpad memory.
Requirement Change SR F5 (v5) Added option that firmware downgrades can occur if the downgrade occurs as a sensitive …
Added
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Requirement Change SRs M1
• M8 Changed to Section H. Requirement Change SR Declaration Forms Deleted as unnecessary. Additional Guidance Merged Appendices A and B Retitled: Appendix A: Applicability of Requirements by Functionality Additional Guidance Appendix A Added Direct-Key Loading, HSM Cluster, Partitioned HSM, PIN Processing, Processes Operational Keys, and Remote Administration Platform (RAP). Deleted HSM, Key-Loading Devices, Remote-Managed, and Multi-tenant HSM.
Additional Guidance Appendix A Added HSM Solution as an Approval Class. Additional Guidance Added definitions for Account Data, External Memory, Fixed Key, Hardware Management Device, Hash-based Message Authentication Code, HSM-as-a-Service, HSM Cluster, HSM Processing Solution, HSM Tenant, Key Block, Key Check Value, Key Hierarchy, Local Master Key, Mode of Operation, Partitioned HSM, PCI Mode, Perfect Forward Secrecy, Post Quantum Cryptography, Random-Number Generator, Secure Channel, Storage Key, Tamper Key, and Unique-Key-Per-Transaction.
Additional Guidance Reporting Requirements for PTS Laboratories For DTRs, defined “impractical” or “not practical” as not feasible within the scope of …
• M8 Changed to Section H. Requirement Change SR Declaration Forms Deleted as unnecessary. Additional Guidance Merged Appendices A and B Retitled: Appendix A: Applicability of Requirements by Functionality Additional Guidance Appendix A Added Direct-Key Loading, HSM Cluster, Partitioned HSM, PIN Processing, Processes Operational Keys, and Remote Administration Platform (RAP). Deleted HSM, Key-Loading Devices, Remote-Managed, and Multi-tenant HSM.
Additional Guidance Appendix A Added HSM Solution as an Approval Class. Additional Guidance Added definitions for Account Data, External Memory, Fixed Key, Hardware Management Device, Hash-based Message Authentication Code, HSM-as-a-Service, HSM Cluster, HSM Processing Solution, HSM Tenant, Key Block, Key Check Value, Key Hierarchy, Local Master Key, Mode of Operation, Partitioned HSM, PCI Mode, Perfect Forward Secrecy, Post Quantum Cryptography, Random-Number Generator, Secure Channel, Storage Key, Tamper Key, and Unique-Key-Per-Transaction.
Additional Guidance Reporting Requirements for PTS Laboratories For DTRs, defined “impractical” or “not practical” as not feasible within the scope of …
Added
p. 7
Additional Guidance DTR A5 Clarified meaning of cryptographic keys indirectly attacked. Additional Guidance Specified that self-test functions that are implemented by the firmware of the device must use cryptography that implements an effective key strength of 128 bits or stronger.
Requirement Change DTR B1 Added clarification from the existing FAQ regarding error logs that do not contain any sensitive module information.
Requirement Change DTR B2 Specified that the tester shall identify in the report the publicly-available sources of vulnerability disclosure used.
Requirement Change DTR B2 Clarified interfaces that may be excluded from the requirement.
Requirement Change DTR B2 Specified inclusion of any services, in addition to physical or API interfaces.
Requirement Change Specified that firmware authentication must use cryptography that implements an effective key strength of 128 bits or stronger.
Requirement Change Specified that authentication methods with known weaknesses, such as a CBC MAC, are not used for firmware authentication.
Requirement Change Specified that application authentication must …
Requirement Change DTR B1 Added clarification from the existing FAQ regarding error logs that do not contain any sensitive module information.
Requirement Change DTR B2 Specified that the tester shall identify in the report the publicly-available sources of vulnerability disclosure used.
Requirement Change DTR B2 Clarified interfaces that may be excluded from the requirement.
Requirement Change DTR B2 Specified inclusion of any services, in addition to physical or API interfaces.
Requirement Change Specified that firmware authentication must use cryptography that implements an effective key strength of 128 bits or stronger.
Requirement Change Specified that authentication methods with known weaknesses, such as a CBC MAC, are not used for firmware authentication.
Requirement Change Specified that application authentication must …
Added
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Requirement Change DTR B8 Added additional guidance to support post-quantum cryptography.
Additional Guidance DTR B9 Specified acceptable storage and distribution of symmetric keys using both symmetric and asymmetric techniques.
Requirement Change DTR B9 Added clarification on the determination of equivalent key- block methods.
Additional Guidance Specified that applicability of minimum key sizes and parameters for algorithm(s) applies to acquirer-based keys used for key transport, exchange, or establishment.
Additional Guidance Specified that device-security keys
•such as firmware authentication, tamper/storage keys, etc.
•must use cryptography that implements an effective key strength of 128 bits or stronger.
Requirement Change Added new requirement that HSMs used in personalization must support the Elliptic Curve Schnorr Digital Signature Algorithm (EC-SDSA).
Requirement Change DTR B9 Added clarification for keys used for load balancing. Additional Guidance Added clarification that effective strength of at least 128 bits does not apply to the tamper/storage key if it is the same as the HSM’s MFK/LMK, and that the MFK/LMK …
Additional Guidance DTR B9 Specified acceptable storage and distribution of symmetric keys using both symmetric and asymmetric techniques.
Requirement Change DTR B9 Added clarification on the determination of equivalent key- block methods.
Additional Guidance Specified that applicability of minimum key sizes and parameters for algorithm(s) applies to acquirer-based keys used for key transport, exchange, or establishment.
Additional Guidance Specified that device-security keys
•such as firmware authentication, tamper/storage keys, etc.
•must use cryptography that implements an effective key strength of 128 bits or stronger.
Requirement Change Added new requirement that HSMs used in personalization must support the Elliptic Curve Schnorr Digital Signature Algorithm (EC-SDSA).
Requirement Change DTR B9 Added clarification for keys used for load balancing. Additional Guidance Added clarification that effective strength of at least 128 bits does not apply to the tamper/storage key if it is the same as the HSM’s MFK/LMK, and that the MFK/LMK …
Added
p. 9
Additional Guidance DTR B18 Additional guidance provided for operating in PCI mode, including as it applies to individual key hierarchies.
Additional Guidance Specified that the security policy defines and documents all hardware and firmware options•both security and non- security relevant. Specified that if wildcards are used, the specific configurations validated by the PCI-Recognized Laboratory must be explicitly noted.
Requirement Change Specified that where the HSM supports a remote- administration solution as defined in “Functions Provided,” the security policy must define and document the services provided by the remote-administration solution. This is an FAQ partly moved into the DTRs.
Requirement Change Specified that the security policy addresses how the device is designed to be delivered in a secure state to the end customer.
Requirement Change Specified that the security policy includes procedures for the ability to erase all sensitive data and configuration settings at its end-of-life or prior to transfer and re-deployment.
Requirement Change DTR D1 …
Additional Guidance Specified that the security policy defines and documents all hardware and firmware options•both security and non- security relevant. Specified that if wildcards are used, the specific configurations validated by the PCI-Recognized Laboratory must be explicitly noted.
Requirement Change Specified that where the HSM supports a remote- administration solution as defined in “Functions Provided,” the security policy must define and document the services provided by the remote-administration solution. This is an FAQ partly moved into the DTRs.
Requirement Change Specified that the security policy addresses how the device is designed to be delivered in a secure state to the end customer.
Requirement Change Specified that the security policy includes procedures for the ability to erase all sensitive data and configuration settings at its end-of-life or prior to transfer and re-deployment.
Requirement Change DTR D1 …
Added
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Requirement Change DTRs G1
• G11 Clarified where site inspections may be required. Additional Guidance DTR G3 Added criteria for usage of HSMs. Requirement Change DTR G6 Specified the inclusion of access-controlled area logs or electronic/signing logs.
Requirement Change DTRs H1
• H8 Clarified where site inspections may be required. Additional Guidance Appendix D Added that DSA is no longer allowed for use in signature generation. It is still allowed for legacy use in signature verification.
Requirement Change Appendix D Rewrote and added information on post quantum cryptography, key check values and random number- generators.
Requirement Change Appendix F Added numerous changes throughout. Additional Guidance
• G11 Clarified where site inspections may be required. Additional Guidance DTR G3 Added criteria for usage of HSMs. Requirement Change DTR G6 Specified the inclusion of access-controlled area logs or electronic/signing logs.
Requirement Change DTRs H1
• H8 Clarified where site inspections may be required. Additional Guidance Appendix D Added that DSA is no longer allowed for use in signature generation. It is still allowed for legacy use in signature verification.
Requirement Change Appendix D Rewrote and added information on post quantum cryptography, key check values and random number- generators.
Requirement Change Appendix F Added numerous changes throughout. Additional Guidance
Modified
p. 1
Payment Card Industry (PCI) PIN Transaction Security (PTS) Hardware Security Module (HSM) Summary of Requirements Changes from Version 3.0 to 4.0
Payment Card Industry (PCI) PIN Transaction Security (PTS) Hardware Security Module (HSM) Summary of Requirements Changes from Version 4.0 to 5.0
Modified
p. 2
Requirement Change To reflect the addition modification, deletion, or restructuring of requirements
Requirement Change To reflect the addition, modification, deletion, or restructuring of requirements.
Removed
p. 3
Table 2: Summary of Changes Document and Requirements Change Type General Eliminated PCI Vendor Questionnaire. PCI laboratories will solicit information using proprietary methods that provide more efficient support for the gathering of that information.
Additional Guidance General Migrated as applicable technical FAQs into the Derived Test Requirements or the Device Testing and Approval Program Guide.
Additional Guidance SR General Added new module - Cloud Based HSMs as a Service - Multi-tenant Usage Security Requirements with the following sections:
• Cloud Physical Security Requirements
• Cloud Logical Security Requirements
• Cloud Provisioning / Management Security Requirements Requirement SR General Renamed Device Management Security Requirements module to Life Cycle Security Requirement SR General Added references to ANSI X9.42, ANSI X9.102, ANSI X9.142, ASC X9 TR 34, FIPS PUB 140-3 and ISO 20038.
Additional Guidance SR General Added reference to ‘Secure Environments’ as defined in ISO 13491-2 Additional Guidance SR General Updated references to account data encryption Requirement (HSM …
Additional Guidance General Migrated as applicable technical FAQs into the Derived Test Requirements or the Device Testing and Approval Program Guide.
Additional Guidance SR General Added new module - Cloud Based HSMs as a Service - Multi-tenant Usage Security Requirements with the following sections:
• Cloud Physical Security Requirements
• Cloud Logical Security Requirements
• Cloud Provisioning / Management Security Requirements Requirement SR General Renamed Device Management Security Requirements module to Life Cycle Security Requirement SR General Added references to ANSI X9.42, ANSI X9.102, ANSI X9.142, ASC X9 TR 34, FIPS PUB 140-3 and ISO 20038.
Additional Guidance SR General Added reference to ‘Secure Environments’ as defined in ISO 13491-2 Additional Guidance SR General Updated references to account data encryption Requirement (HSM …
Removed
p. 4
Requirement SR J7 Specified model name and hardware version and shall be retrievable by a query or should be identifiable using secure, cryptographically protected methods.
Requirement SR Appendix B Modified Applicability of Requirements to reflect addition of new module: Cloud Based HSMs as a Service - Multi-tenant Usage Security Requirements Additional Guidance Glossary Added/modified terms for atomic, authentication code, check value, HSM processing element, HSM solution and HSM virtualization system Additonal Guidance DTRs Introduction Provided additional guidance for lab reporting criteria, including minimal contents of reports and minimal test activities.
Additional Guidance DTRs
• All Sections Enhanced robustness of test scripts throughout. Requirement DTR B1 Added additional criteria for both power-up and continuous/periodic tests Requirement DTR B4 Specified that the displayed firmware version number(s) must represent all firmware in the device.
Requirement DTR B9 Devices must support key blocks as specified by ISO 20038 and/or the ANSI TR-31 key-derivation method. Other methods can only …
Requirement SR Appendix B Modified Applicability of Requirements to reflect addition of new module: Cloud Based HSMs as a Service - Multi-tenant Usage Security Requirements Additional Guidance Glossary Added/modified terms for atomic, authentication code, check value, HSM processing element, HSM solution and HSM virtualization system Additonal Guidance DTRs Introduction Provided additional guidance for lab reporting criteria, including minimal contents of reports and minimal test activities.
Additional Guidance DTRs
• All Sections Enhanced robustness of test scripts throughout. Requirement DTR B1 Added additional criteria for both power-up and continuous/periodic tests Requirement DTR B4 Specified that the displayed firmware version number(s) must represent all firmware in the device.
Requirement DTR B9 Devices must support key blocks as specified by ISO 20038 and/or the ANSI TR-31 key-derivation method. Other methods can only …