Hi,

I am not happy with that formulation. SP 800-227 is not guidance, it defines 
requirements. My understanding is that Sections 3, 4, and C of SP 800-227 
contain requirements (“shall” and “must”) that apply to conforming 
implementations of ML-KEM in applications. Section 1.3 is just a nice summary.

The only reason not to state explicitly that the requirements in SP 800-227 
SHALL be followed would be if there are implementations intending to violate 
some of NIST’s requirements.

I am against the IETF publishing any standards that violate NIST’s requirements 
for ML-KEM. I am very tired of seeing implementations claiming to support 
AES-CBC, AES-GCM, RSA, or ML-KEM, while not actually conforming to any official 
standard. It makes security analysis of systems a real pain. If you use the 
name ML-KEM, you should follow NIST’s requirements.

If this draft intends to deviate from any NIST requirements, it must clearly 
specify which requirements are not being followed and why. For example:

“NIST requires that implementations of ML-KEM ..., but this document does not 
follow this requirement because ...”

Cheers,
John

From: Kampanakis, Panos <[email protected]>
Date: Wednesday, 8 October 2025 at 18:15
To: John Mattsson <[email protected]>, Tero Kivinen <[email protected]>, 
[email protected] <[email protected]>
Subject: RE: [IPsec] Re: WGLC of draft-ietf-ipsecme-ikev2-mlkem is done
Hi John,

Section 1.3 talks about testable and non-testable CMVP / NIST requirements. Not 
everyone needs to follow all of those. And not all of them are applicable to 
IKEv2.

I am planning to make the sentence more accurate by rephrasing it to

> Refer to Sections 3 and 4 of [SP800227] for guidelines to implement and use 
> KEMs securely in applications.

This sentence informs the reader that they can go read guidance on how to 
implement and use ML-KEM securely in the IKEv2 implementation. Otherwise, the 
draft already has normative language about ephemeral keys, proper ML-KEM input 
checks etc already which should suffice. Mandating “ML-KEM side-channel 
resistance” in IKEv2 does not help an implementer. If there is specific 
normative practical guidance for ML-KEM that we are missing, happy to add it.

I find that referencing a 56 page document and normatively saying “go comply 
with all of that” is impractical. If the rest of the WG thinks the doc should 
have that normative statement, I will add it.





From: John Mattsson <[email protected]>
Sent: Wednesday, October 8, 2025 1:45 AM
To: Tero Kivinen <[email protected]>; [email protected]
Subject: [EXTERNAL] [IPsec] Re: WGLC of draft-ietf-ipsecme-ikev2-mlkem is done


CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you can confirm the sender and know the 
content is safe.

> Section 4 of [SP800227] includes guidelines for using KEMs securely in 
> applications.

This is not a correct description of SP 800-227.

SP 800-227 makes _requirements_ for implementing and using KEMs. The important 
section is 1.3, which states that "Conforming implementations of approved KEMs 
are required to satisfy all of the requirements below."  FIPS 203 already 
references SP 800-227, stating: "For general definitions and properties of 
KEMs, including requirements for the secure use of KEMs in applications, see SP 
800-227". IKEv2 is one such application.
https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-227.pdf

The draft should state that the requirements in SP 800-227 shall be followed. I 
don't think anyone wants standards or implementations violating NIST 
requirements, and FIPS 203 and SP 800-227 should be viewed together.

Suggestion:

NEW: Section 1.3 of [SP800227] includes requirements for using KEMs securely in 
applications and SHALL be followed.

Cheers,
John

On 2025-10-05, 19:33, "Tero Kivinen" <[email protected]<mailto:[email protected]>> 
wrote:
The WGLC of the draft-ietf-ipsecme-ikev2-mlkem document has finished,
and there has been new document published that should resolve all WGLC
comments. If there are any comments that were not resolved please send
email to the list ASAP.
--
[email protected]<mailto:[email protected]>


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