+Cryptographic Key Management and Lifecycle

1. Overview

Cryptographic Key Management and Lifecycle

Establish protocols for the proper use, protection, and lifecycle management of cryptographic keys. Define criteria for selecting cryptographic techniques and practices, incorporating best practices and industry standards. Employ mitigation and monitoring measures if adherence to these practices and standards is not possible. Outline requirements for managing and controlling cryptographic keys throughout their lifecycle, including generation, storage, backup, archiving, retrieval, transmission, retirement, revocation, and destruction. Establish methods to recover cryptographic keys in case of loss, compromise, or damage. Monitor crypto-analysis developments and, when necessary, update or change cryptographic technology. Implement mitigation and monitoring measures if changing or updating the cryptographic technology is not feasible. Maintain a register for all certificates and certificate storing devices.

1.1 References

1.2 Identified Requirements

1.2 Related Regulation

2. Identified Requirements

Requirements

3. Related Regulations

Regulations
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 6 , 1
1. As part of their ICT security policies, procedures, protocols, and tools referred to in Article 9(2) of Regulation (EU) 2022/2554, financial entities shall develop, document, and implement a policy on encryption and cryptographic controls.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 6 , 2

2. Financial entities shall design the policy on encryption and cryptographic controls referred to in paragraph 1 on the basis of the results of an approved data classification and ICT risk assessment. That policy shall contain rules for all of the following:

  • (a) the encryption of data at rest and in transit;
  • (b) the encryption of data in use, where necessary;
    • For the purposes of point (b), where encryption of data in use is not possible, financial entities shall process data in use in a separated and protected environment, or take equivalent measures to ensure the confidentiality, integrity, authenticity, and availability of data
  • (c) the encryption of internal network connections and traffic with external parties;
  • (d) the cryptographic key management referred to in Article 7, laying down rules on the correct use, protection, and lifecycle of cryptographic keys.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 6 ,3 ,

3. Financial entities shall include in the policy on encryption and cryptographic controls referred to in paragraph 1 criteria for the selection of cryptographic techniques and use practices, taking into account leading practices, and standards as defined in Article 2, point (1), of Regulation (EU) No 1025/2012, and the classification of relevant ICT assets established in accordance with Article 8(1) of Regulation (EU) 2022/2554. Financial entities that are not able to adhere to the leading practices or standards, or to use the most reliable techniques, shall adopt mitigation and monitoring measures that ensure resilience against cyber threats.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 6 , 4
4. Financial entities shall include in the policy on encryption and cryptographic controls referred to in paragraph 1provisions for updating or changing, where necessary, the cryptographic technology on the basis of developments incryptanalysis. Those updates or changes shall ensure that the cryptographic technology remains resilient against cyberthreats, as required by Article 10(2), point (a). Financial entities that are not able to update or change the cryptographictechnology shall adopt mitigation and monitoring measures that ensure resilience against cyber threats.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 6 , 5
5. Financial entities shall include in the policy on encryption and cryptographic controls referred to in paragraph 1 a requirement to record the adoption of mitigation and monitoring measures adopted in accordance with paragraphs 3 and 4 and to provide a reasoned explanation for doing so.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 7 , 1
1. Financial entities shall include in the cryptographic key management policy referred to in Article 6(2), point (d), requirements for managing cryptographic keys through their whole lifecycle, including generating, renewing, storing, backing up, archiving, retrieving, transmitting, retiring, revoking, and destroying those cryptographic keys.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 7 , 2
2. Financial entities shall identify and implement controls to protect cryptographic keys through their whole lifecycle against loss, unauthorised access, disclosure, and modification. Financial entities shall design those controls on the basis of the results of the approved data classification and the ICT risk assessment.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 7 , 3
3. Financial entities shall develop and implement methods to replace the cryptographic keys in the case of loss, or where those keys are compromised or damaged.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 7 , 4
4. Financial entities shall create and maintain a register for all certificates and certificate-storing devices for at least ICT assets supporting critical or important functions. Financial entities shall keep that register up to date.
DORA RTS ICT Risk Management T. II Ch. I Sec. 4 Art. 7 , 5
5. Financial entities shall ensure the prompt renewal of certificates in advance of their expiration.
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