eIDAS Compliant HSMs: Root CA Options

TL;DR

Yes, several Hardware Security Modules (HSMs) support eIDAS compliance for Root Certificate Authorities (CAs). This guide outlines key considerations and popular options. Achieving full compliance requires careful planning and configuration beyond just the HSM itself.

Understanding eIDAS & HSMs

eIDAS (electronic IDentification, Authentication and trust Services) is a European Union regulation that sets standards for electronic signatures, timestamps, and other trust services. For Root CAs, it demands high levels of security, including the use of Qualified Signature Creation Devices (QSCDs), which are often HSMs.

An HSM provides a tamper-resistant environment to protect cryptographic keys used for issuing certificates. Not all HSMs are created equal when it comes to eIDAS; you need one specifically certified or capable of being configured to meet the requirements.

Steps to Choose & Implement an eIDAS Compliant Root CA HSM

1. Identify Your Requirements:

• Certification Level: Determine if you need a QSCD (required for Qualified Trust Services) or if a simpler HSM configuration is sufficient.
• Throughput & Scalability: How many certificates will you issue per day/hour? This impacts the required HSM performance.
• High Availability: Do you need redundancy to ensure continuous operation?
• Integration: Does the HSM need to integrate with existing PKI (Public Key Infrastructure) software?

Choose an eIDAS Compliant HSM Vendor: Here are some popular options:

• Thales Luna HSM: A widely used, highly secure option. Often pre-certified for eIDAS.
• Entrust nShield HSM: Another leading vendor with strong eIDAS support and a range of models.
• Utimaco CryptoServer HSM: Offers good performance and compliance features.
• Sequitur Systems (now part of Thales): Specialises in smaller form-factor HSMs, some suitable for specific use cases.

HSM Configuration & Key Generation: This is the most critical step.

• Secure Boot: Ensure the HSM has a secure boot process to prevent tampering.
• Key Ceremony: Perform a formal key generation ceremony following best practices (e.g., NIST SP 800-90A). Document everything meticulously!
• Partitioning: Create separate partitions within the HSM for different functions (Root CA, issuing CAs, etc.). This limits the impact of a compromise.
• Access Control: Implement strict role-based access control to limit who can manage keys and perform sensitive operations.

PKI Software Integration:

• Compatibility: Verify that your chosen PKI software (e.g., OpenSSL, Microsoft Certificate Services) supports the HSM’s API (e.g., PKCS#11).
• Configuration: Configure the PKI software to use the HSM for key storage and cryptographic operations. This often involves installing a specific driver or library provided by the HSM vendor.

eIDAS Audit & Compliance Documentation:

• Regular Audits: Conduct regular security audits to ensure ongoing compliance with eIDAS requirements.
• Documentation: Maintain detailed documentation of all HSM configuration, key generation procedures, access control policies, and audit results. This is essential for demonstrating compliance to auditors.

Example Configuration Snippet (OpenSSL with Luna HSM)

This is a simplified example; consult the Thales documentation for complete instructions.

openssl engine -text -providers 'dynamic' | grep luna

This command lists available Luna HSM engines in OpenSSL. You’ll then need to configure an OpenSSL configuration file to use the engine and specify connection details (IP address, partition name, etc.).

Important Considerations

• Common Criteria Certification: Look for HSMs with Common Criteria certification at a high assurance level (e.g., EAL 4+).
• FIPS 140-2/3 Validation: FIPS validation is often required, especially in US government contexts.
• Vendor Support: Choose a vendor with strong support and expertise in eIDAS compliance.