If your organization handles sensitive data, you are almost certainly subject to multiple regulatory frameworks, and each has something to say about cryptographic compliance. FIPS 140-3, PCI DSS, HIPAA, GDPR, and DORA were written for very different purposes, yet they converge on the same expectations: use strong cryptography, manage it properly, and be able to prove that you are doing so.
Tackling cryptographic compliance one framework at a time is slow, costly, and easy to get wrong. The good news is that the overlap between them is substantial, so a single, well-maintained view of your cryptography can satisfy much of what each one asks. This blog walks through what FIPS 140-3, PCI DSS, HIPAA, GDPR, and DORA each require, where they line up, and how CBOM Secure helps you meet them all.
The Common Thread Across Every Framework
FIPS, PCI DSS, HIPAA, GDPR, and DORA come from different worlds: federal security, payments, healthcare, privacy, and financial resilience. But they increasingly converge on the same expectations: use strong, approved cryptography; manage keys and certificates properly; know where cryptography is used; and be able to demonstrate it. The hard part is rarely the rule itself; it is proving compliance across a sprawling, constantly changing environment.
FIPS 140-3
What it is: A U.S. federal standard defining security requirements for cryptographic modules, widely referenced beyond government as a benchmark of cryptographic assurance.
Cryptographic focus:
- Use of approved algorithms and validated cryptographic modules.
- Proper key management and secure handling of cryptographic material.
- Avoidance of weak or non-approved algorithms.
How CBOM Secure helps: Identifies the algorithms in use across your environment, flags non-approved or weak choices, and gives you the inventory needed to demonstrate that approved cryptography is in place.
PCI DSS
What it is: The Payment Card Industry Data Security Standard, which protects cardholder data for any organization that stores, processes, or transmits it.
Cryptographic focus:
- Strong cryptography to protect stored account data.
- Strong cryptography and secure protocols to protect data transmitted over open or public networks.
- Documented key and certificate management throughout the lifecycle.
- A documented, regularly reviewed inventory of cryptographic cipher suites and protocols in use.
How CBOM Secure helps: Maintains the cipher-suite and protocol inventory PCI DSS expects, surfaces weak protocols and algorithms, and provides continuous evidence that strong cryptography is in use.
HIPAA
What it is: The U.S. healthcare framework whose Security Rule governs the protection of electronic protected health information (ePHI).
Cryptographic focus:
- Encryption of ePHI at rest and in transit as a safeguard against unauthorized access.
- Encryption to recognized standards, which can reduce breach-notification exposure.
How CBOM Secure helps: Verifies that systems handling sensitive data use strong, current encryption, and highlights gaps or weak cryptography that could undermine those safeguards.
GDPR
What it is: The European Union’s General Data Protection Regulation, governing the protection of personal data.
Cryptographic focus:
- Encryption is named explicitly as an appropriate measure to protect personal data (Article 32).
- Strong encryption can reduce the obligation to notify individuals after a breach.
How CBOM Secure helps: Provides evidence that personal data is protected by strong cryptography and identifies weak or missing protection across your estate.
DORA
What it is: The European Union’s Digital Operational Resilience Act, which strengthens the ICT risk posture of financial entities and their technology providers.
Cryptographic focus:
- Encryption of data at rest and in transit as part of ICT risk management.
- A defined policy for cryptographic controls and key management.
- Attention to evolving threats, including the move toward post-quantum cryptography.
How CBOM Secure helps: Backs your cryptographic controls policy with real inventory, identifies gaps, and supports resilience and post-quantum planning with continuous visibility.
What These Cryptographic Compliance Requirements Have in Common
Strip away the sector-specific language, the differing legal bases, and the regional scope, and the five frameworks converge on the same handful of expectations. Whether the driver is federal assurance, payment security, patient privacy, data protection, or operational resilience, each one ultimately asks you to do the same four things with your cryptography:
Know where cryptography is used across your environment: You cannot protect, validate, or report on what you cannot see. This means building and maintaining a complete inventory of the algorithms, protocols, keys, and certificates in use across applications, servers, databases, network traffic, source code and cloud services, not just the systems you happen to remember to check.
Ensure it is strong, approved, and free of deprecated algorithms: Every framework expects modern, well-vetted cryptography and the retirement of anything weak or broken, such as MD5, SHA-1, DES, or undersized RSA keys. As standards evolve and computing power grows, the definition of strong keeps moving, so this is a continuous exercise rather than a one-time clean-up.
Manage keys and certificates throughout their lifecycle: Strong algorithms are only as trustworthy as the keys behind them. Generation, distribution, storage, rotation, and revocation of all need defined controls, and expired or poorly protected keys and certificates are a common cause of both outages and breaches.
Be able to demonstrate all the above, on demand: Auditors, regulators, and customers increasingly want evidence rather than assurances. That calls for current, accurate documentation of your cryptographic posture that you can produce quickly during an audit, a vendor assessment, or a breach of investigation, instead of reconstructing it under pressure.
Each framework dresses up to these expectations in its own terminology, but an organization that handles all four well is most of the way to satisfying every standard at once. That is precisely the problem CBOM Secure is built to solve.
Side-by-Side Framework Comparison
Before going deeper, here is how the five frameworks compare side by side. The table below summarises each one’s primary cryptographic focus and the role CBOM Secure plays in meeting it, so the common ground is easy to see immediately.
| Framework | Primary Cryptographic Focus | How CBOM Secure Helps |
|---|---|---|
| FIPS 140-3 | Approved algorithms and validated modules | Flags non-approved/weak algorithms; inventories usage |
| PCI DSS | Strong crypto and a cipher/protocol inventory | Maintains the inventory; finds weak protocols |
| HIPAA | Encryption of ePHI at rest and in transit | Verifies strong encryption; surfaces gaps |
| GDPR | Encryption of personal data | Proves protection; finds weak or missing crypto |
| DORA | Crypto-controls policy and resilience | Backs policy with real data; supports PQC planning |
Meeting Every Framework with Encryption Consulting
Knowing what the frameworks demand is one thing; satisfying all of them, continuously, across an ever-changing environment is another. It takes both the right platform and the right expertise. CBOM Secure delivers visibility and evidence, and Encryption Consulting delivers the guidance that turns that visibility into sustained compliance.
Together, the platform and our advisory services give you:
- A single, continuously updated inventory of all cryptography across on-premises, cloud, and application environments.
- Automatic detection of weak, deprecated, and non-compliant algorithms and protocols, such as MD5, SHA-1, DES, and legacy TLS.
- Risk prioritized and mapped to FIPS 140-3, PCI DSS, HIPAA, GDPR, and DORA, so you address what matters most first.
- Continuous, audit-ready evidence you can produce on demand, rather than point-in-time snapshots.
- Expert remediation and advisory across PKI, key management, HSMs, and post-quantum readiness.
- Ongoing, multi-framework compliance backed by managed services.
Encryption Consulting helps you turn overlapping requirements into a single, manageable program, backed by the visibility CBOM Secure provides.
Conclusion
FIPS 140-3, PCI DSS, HIPAA, GDPR, and DORA were written for very different purposes, but they all point in the same direction: strong, well-managed, and demonstrable cryptography. The organizations that cope best are not the ones chasing each framework in isolation, but the ones that build a single, accurate view of their cryptography and keep it current. That view is what turns five overlapping obligations into one manageable program.
CBOM Secure gives you that view: continuous visibility into every algorithm, protocol, key, and certificate, the audit-ready evidence each framework expects, and a foundation for the move to post-quantum cryptography. Encryption Consulting brings the expertise to interpret findings, close gaps, and keep you compliant as both your environment and regulations evolve.
Facing one framework or five? Talk to Encryption Consulting about meeting your cryptographic requirements with CBOM Secure.
