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Common Criteria (ISO/IEC 15408): evaluating products against the claims they choose

Where FIPS 140-3 tests every module against one fixed list, Common Criteria lets the vendor (or a protection profile) state the security claims, then grades how rigorously a lab checked them. Here's how to read 'EAL4+', and why it says less than it seems to.

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1TCSECUS 'Orange Book'2ITSECEurope3CTCPECCanada4ISO/IEC 15408Merged, adopted1999
Evaluate once instead of three timesOpen the slides →

One framework for evaluating whatever a product claims

Common Criteria grew out of three national evaluation schemes: the US 'Orange Book' (TCSEC), Europe's ITSEC, and Canada's CTCPEC. Their sponsors merged them in the 1990s so a vendor could be evaluated once rather than three times, and the result was adopted internationally as ISO/IEC 15408 in 1999. The evaluation methodology that labs follow is its companion, ISO/IEC 18045 (the CEM).

The defining difference from FIPS 140-3 is that Common Criteria has no single list of requirements every product must meet. It is a catalog of security functional requirements and assurance requirements, plus rules for combining them. Each evaluation picks its own set, writes it down, and the lab checks the product against that set. A firewall, a smart card chip, an HSM, and an operating system can all be 'Common Criteria certified', against completely different claims.

The vocabulary: TOE, ST, PP, SFRs, and SARs

Five terms carry almost all of the meaning in a Common Criteria certificate.

How the pieces of an evaluation fit together

TOE (Target of Evaluation)

Exactly what was evaluated: a product version, often in a specific configuration, and often only part of the product. Anything outside the TOE boundary wasn't evaluated.

ST (Security Target)

The vendor's document for this evaluation: the TOE boundary, the threats and assumptions, and the SFRs and SARs it claims. It's public, and it's the most important document to read.

PP (Protection Profile)

A reusable, implementation-independent set of requirements for a product type (smart card chips, HSMs for trust services, network devices), written by a user community or government. An ST can claim conformance to one.

SFRs (Security Functional Requirements)

What the product does: for example, generating keys of a stated size, authenticating administrators, or zeroizing keys on tamper detection.

SARs (Security Assurance Requirements)

How hard the lab looked: design documentation, testing depth, development-site security, and vulnerability analysis. Evaluation Assurance Levels are predefined bundles of SARs.

EALs measure how deeply the claims were checked, not how secure the product is

The seven Evaluation Assurance Levels are packages of assurance requirements that get progressively more demanding about design evidence, testing, and analysis. An EAL says nothing about which security functions the product has. A product evaluated at EAL4 against a Security Target with weak claims has had weak claims checked thoroughly.

The '+' in 'EAL4+' means the package was augmented with individual assurance components from a higher level. The one that matters most for cryptographic hardware is AVA_VAN, vulnerability analysis: AVA_VAN.5 means the lab's penetration testing assumed an attacker with 'high' attack potential, the level that includes serious side-channel and fault-injection work. That's why smart card chips and HSMs are so often certified at 'EAL4+ (AVA_VAN.5)' or 'EAL5+' rather than a plain EAL.

The seven Evaluation Assurance Levels

EAL1

Functionally tested.

EAL2

Structurally tested. The highest level the CCRA recognizes across all member countries for evaluations that don't use a collaborative protection profile.

EAL3

Methodically tested and checked.

EAL4

Methodically designed, tested, and reviewed. Usually described as the highest level that's economically feasible for an existing commercial product line; the base for most HSM certifications.

EAL5

Semiformally designed and tested. Common for secure microcontrollers in smart cards and secure elements.

EAL6

Semiformally verified design and tested.

EAL7

Formally verified design and tested. Rare, and only practical for small, purpose-built products.

Practice

Product A is certified EAL4+ (AVA_VAN.5) and product B is certified EAL6+. Both are cryptographic hardware. Can you conclude that B is more secure than A from those labels alone?

Protection profiles: making certificates comparable again

If every vendor writes its own Security Target, two certificates for the same kind of product can be hard to compare. Protection profiles fix that by letting a community agree on one requirement set for a product type, so every conforming product makes the same baseline claims.

Different schemes lean on this to different degrees. In the US, NIAP evaluates only against NIAP-approved protection profiles and doesn't assign EALs at all; products on its list are what US national security systems are required to buy. Since 2014 the international arrangement has promoted collaborative protection profiles (cPPs), written jointly by vendors, labs, and several governments, with exact conformance so there's no room to dilute them. In Europe, EN 419221-5 is the protection profile for HSMs used by trust service providers under eIDAS (for certificate issuance, signing, and sealing), and certified HSMs typically claim it at EAL4 augmented with AVA_VAN.5. Paired with a Signature Activation Module certified against EN 419241-2, such an HSM is what makes up a remote qualified signature creation device; the ETSI & eIDAS page covers what that means legally and how the ETSI policy standards around it fit together.

Where EN 419221-5 sits under eIDAS

EN 419221-5 (HSM)

Holds and uses the signing keys, for a provider's own CA and sealing keys or for signatories' keys in remote signing.

EN 419241-2 (Signature Activation Module)

Checks the signatory's authentication before the HSM may use their key, so the pair can be certified as a remote QSCD.

ETSI & eIDAS: qualified signatures and trust services →

What makes a signature qualified, how providers get qualified status, and the ETSI EN 319 standards they're audited against.

Who recognizes whose certificate

Certificates are issued by national certification bodies (BSI in Germany, ANSSI in France, NIAP in the US, and others) based on evaluations by accredited labs. Recognition across borders comes from separate agreements, and each one recognizes a different range of assurance.

The recognition arrangements that matter

CCRA (Common Criteria Recognition Arrangement)

About thirty countries. Since 2014, mutual recognition covers evaluations up to EAL2 plus flaw remediation (ALC_FLR), and evaluations against collaborative protection profiles. Higher-EAL certificates are still valid, just not automatically recognized by every member.

SOG-IS MRA

The European agreement that recognized certificates up to EAL4, and up to EAL7 in two technical domains (smart cards and similar devices, and hardware devices with security boxes). Being replaced by EUCC.

EUCC

The EU's Common Criteria-based scheme under the Cybersecurity Act, set out in Implementing Regulation (EU) 2024/482 and applicable since 27 February 2025. It issues certificates at assurance level 'substantial' (AVA_VAN.1–2) or 'high' (AVA_VAN.3–5) and takes over from the national SOG-IS schemes.

FIPS 140-3 and Common Criteria side by side

A serious HSM vendor usually holds both, because they answer different questions for different buyers. Payment HSMs add a third, PCI PTS HSM, run by the PCI Security Standards Council (see the EMVCo & PCI SSC page).

FIPS 140-3 (CMVP)

  • •One fixed set of requirements for every cryptographic module
  • •Four security levels, scored per area, with the lowest as the overall level
  • •Conformance testing: each requirement passes or fails
  • •Requires CAVP-validated algorithms
  • •Run by NIST and Canada's Cyber Centre; required by US and Canadian federal buyers

Common Criteria (ISO/IEC 15408)

  • •Requirements chosen per evaluation, in a Security Target or protection profile
  • •Seven EALs describing assurance depth, often augmented
  • •Includes vulnerability analysis and penetration testing (AVA_VAN)
  • •No algorithm validation of its own; the ST or PP states which algorithms are claimed
  • •Many national schemes, linked by the CCRA, SOG-IS, and now EUCC; NIAP for US national security systems

Practice

A European trust service provider is choosing HSMs for issuing qualified certificates under eIDAS. One candidate has a FIPS 140-3 Level 3 certificate; another has a Common Criteria certificate against EN 419221-5. Which one was evaluated against requirements written specifically for trust-service HSMs?

Go deeperCC:2022, the transition from v3.1, and keeping a certificate current⌄

For most of the last fifteen years, evaluations used CC version 3.1 (its final revision, R5, dates from 2017). CC:2022 restructured the standard into five parts (adding a framework for evaluation methods and a set of predefined packages) alongside a matching CEM:2022. Under the transition policy of the arrangement's management committee, new evaluations against v3.1 R5 had to start by 30 June 2024, and CC:2022 Security Targets that build on protection profiles certified under v3.1 are accepted until 31 December 2027, which is why certificates naming both versions will keep appearing for a while.

Like a FIPS certificate, a Common Criteria certificate covers one version in one evaluated configuration, usually described in a guidance document that tells operators how to set it up. Assurance continuity lets a vendor carry a certificate forward: minor changes can be handled as maintenance, based on an impact analysis report reviewed by the certification body, while changes that affect the security claims need a re-evaluation. When you check a certificate, check that the version you're running is one the certificate or a maintenance report actually covers.

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Further reading

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Up next

ETSI and eIDAS: qualified signatures, trust services, and the EU Digital Identity Wallet →

FIPS 140-3 and Common Criteria certify products. eIDAS is EU law: it decides when an electronic signature counts as much as a handwritten one, who may issue the certificates behind it, and where the key has to live. ETSI's EN 319 series supplies the technical detail. Here's how the pieces fit, from QES and QSCDs to AdES formats and the new EUDI Wallet.

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