Demystifying FIPS 140-3 Rebranding

Posted on by

This post generated by AI; reviewed and corrected by human experts at KeyPair Consulting.

How the Process Works

With the September 2026 sunset of FIPS 140-2 on the horizon, organizations are exploring faster paths to compliance under FIPS 140-3. One efficient and cost-effective option is rebranding an existing validated module. But what does that actually mean—and how does the process work?

In this post, we break down the rebranding process and show how KeyPair Consulting makes it easy to align with NIST/CMVP requirements without starting from scratch.

🔐 What Is FIPS 140-3 Rebranding?

Rebranding is a formal process under the CMVP that allows an organization to obtain its own FIPS 140-3 certificate by leveraging an existing validated module—without modifying its cryptographic implementation.

Think of it as licensing a secure, validated foundation and applying your own name, brand, and vendor-specific certificate to it. The end result is a certificate you can reference in procurement, compliance, or federal deployments—under your company’s name.

🧩 Who Can Rebrand?

Any organization that:

  • Uses a FIPS 140-3 validated module in a compliant and unmodified form (no source or binary changes),
  • Has its own relationship with the lab and/or vendor facilitating the rebrand, and
  • Requires a certificate in its own company name (rather than relying on someone else’s certificate).

This is especially useful for:

  • OEMs and software vendors embedding FIPS modules,
  • MSPs, integrators, or product developers selling to federal agencies,
  • Companies facing FedRAMP, DoDIN APL, or other federal cryptographic compliance mandates.

🛠 How the Rebranding Process Works

Here’s what the typical rebranding lifecycle looks like:

1. Select a Rebrandable Module

Choose a validated FIPS 140-3 module that explicitly supports rebranding. The KeyPair FIPS Provider for OpenSSL 3 (Cert. #4724) is currently the most rebranded FIPS 140-3 certificate on the market, with:

  • ✅ 17 rebrand certificates issued,
  • 🛠 1 more in active progress (as of September 2025),
  • 💻 48 tested operational environments (OEs) and growing.

2. Create a Vendor-Specific Security Policy

A customized Security Policy is created under your company name, referencing your specific OEs and branding (logo, contact info, etc.). KeyPair generates the FIPS 140-3 Security Policy and certificate information for you.

3. Engage with the Lab

The original testing lab is re-engaged to perform a limited review—KeyPair will handle all the details and coordination with the lab. Typically, a rebrand submission to the CMVP takes 2–4 weeks depending on lab availability.

FIPS 140-3 algorithm and operational testing are required if you have specific operational environments to be included (that were not previously tested). This testing is performed while the CMVP processes the rebrand report submission to prepare for an operational environment update (OEUP) after the rebranded FIPS 140-3 certificate is issued. These details are also handled by KeyPair as part of our rebranding service.

4. Submit to CMVP

The lab submits the rebranded documentation to the CMVP (NIST + CCCS), which reviews and posts the rebranded module on the NIST certificate list.

You receive a new FIPS 140-3 certificate, under your company name, using the previously validated module.

📦 What You Get

By the end of the process, you’ll have:

  • A new FIPS 140-3 certificate number issued to your company,
  • Your own Security Policy, including your branding and OE list,
  • Legal use of the FIPS certificate for marketing, procurement, and deployment.

🚀 Why Choose KeyPair’s Rebrandable Module?

The KeyPair FIPS Provider for OpenSSL 3 (FIPS 140-3 Cert. #4724) has become the leading choice for rebranding because it offers:

  • 🥇 Fast turnaround times (our September 2025 estimate is 3-4 months for CMVP review time),
  • 🌐 Broad OS/platform support (Linux, Windows, embedded),
  • 🔧 Full access to the source code,
  • ✅ A proven process vetted by CMVP and multiple labs.

And now with the upcoming KeyPair FIPS Provider Plus for OpenSSL 3.5, customers have a roadmap aligned with the next generation of OpenSSL.

📞 Ready to Rebrand?

If you’re preparing to transition from FIPS 140-2 or need a trusted module to satisfy federal cryptographic requirements, rebranding a validated FIPS 140-3 module can save a year or more of time and thousands in cost.

KeyPair Consulting can guide you through every step—allowing you to focus on product development.

👉 Contact us to discuss your rebranding timeline and explore tested OEs for your platform.

KeyPair Consulting – FIPS 140-3 open-source rebrands & testing