FIPS, ISO, and the Compliance Standards That Matter for Privacy Infrastructure
A practical guide to the security and compliance standards — FIPS 140-3, ISO 27001, SOC 2, NIST 800-53, PCI DSS, and more — that privacy-first platforms should align with, and how TEE-based architectures like Treza map to each.
If you're building infrastructure that handles sensitive data — financial transactions, identity verification, health records, cryptographic keys — compliance isn't optional. It's the baseline expectation from regulators, enterprise buyers, and end users.
But the compliance landscape is fragmented. FIPS, ISO, SOC, NIST, PCI, GDPR, HIPAA — each standard addresses a different facet of security, and knowing which ones matter for your architecture is half the battle.
This guide breaks down the standards most relevant to privacy infrastructure and confidential computing, explains what each one actually requires, and shows how TEE-based platforms like Treza align with them by design.
FIPS 140-3: Cryptographic Module Validation
What it is: The Federal Information Processing Standard 140-3 is the U.S. government standard for validating cryptographic modules. It replaced FIPS 140-2 in 2019 and is now the active standard for all new certifications. Any system that processes federal data or operates in regulated financial environments is expected to use FIPS-validated cryptography.
Why it matters: If your platform performs encryption, decryption, key generation, hashing, or digital signatures, the underlying cryptographic module should be FIPS 140-3 validated. This is non-negotiable for government contracts, many banking integrations, and healthcare data processing.
The four security levels:
- Level 1 — Basic requirements. Software-only cryptographic modules with at least one approved algorithm.
- Level 2 — Adds tamper-evidence requirements (physical coatings or seals) and role-based authentication.
- Level 3 — Requires tamper-resistance (active zeroization of keys upon physical intrusion) and identity-based authentication.
- Level 4 — Full envelope of physical security protections with environmental failure detection.
How TEEs align: AWS Nitro Enclaves — the foundation of Treza's confidential compute layer — use FIPS 140-2 Level 3 validated HSMs (AWS CloudHSM) for key management. The Nitro Security Module itself is designed with cryptographic isolation guarantees that map directly to FIPS requirements. By running workloads inside Nitro Enclaves with attestation-gated key access, Treza inherits FIPS-grade cryptographic protections without requiring application-level certification.
ISO/IEC 27001: Information Security Management
What it is: The international standard for information security management systems (ISMS). ISO 27001 provides a framework for establishing, implementing, maintaining, and continually improving an organization's approach to managing sensitive information.
Why it matters: ISO 27001 certification is the most widely recognized security credential globally. It's often a prerequisite for enterprise sales in Europe and Asia, and increasingly expected by U.S. financial institutions. The standard covers 93 controls across four themes: organizational, people, physical, and technological.
Key control areas relevant to privacy infrastructure:
- A.8.24 — Use of cryptography: Policies for cryptographic key management, algorithm selection, and key lifecycle.
- A.8.25 — Secure development lifecycle: Security requirements baked into the development process.
- A.8.31 — Separation of development, testing, and production environments.
- A.8.34 — Protection of information systems during audit testing.
- A.5.34 — Privacy and protection of personally identifiable information (PII).
How TEEs align: Treza's architecture enforces many ISO 27001 controls at the infrastructure level. Hardware-isolated enclaves provide separation guarantees that satisfy environmental segregation requirements. Cryptographic attestation produces verifiable evidence for audit controls. The SDK's privacy-preserving logging ensures that sensitive data never leaks into monitoring systems while still satisfying the standard's observability requirements.
ISO/IEC 27017 and 27018: Cloud-Specific Security and Privacy
What they are: ISO 27017 extends 27001 with cloud-specific security guidance — covering shared responsibility models, virtual machine isolation, and cloud service customer data segregation. ISO 27018 specifically addresses protection of personally identifiable information (PII) in public cloud environments.
Why they matter: If you're running sensitive workloads in cloud infrastructure (as most modern platforms do), these standards address the specific risks that traditional 27001 doesn't fully cover — multi-tenancy, data residency, and cloud provider access to customer data.
Key requirements:
- Cloud service providers must not process PII for marketing without explicit consent.
- Customer data must be deletable upon contract termination.
- Sub-processor (cloud provider) access to customer data must be documented and controlled.
- Virtual isolation must be equivalent to physical isolation for security purposes.
How TEEs align: This is where TEE-based architectures have a structural advantage. AWS Nitro Enclaves provide isolation that goes beyond virtual machine boundaries — not even the host operating system, root users, or AWS operators can access enclave memory. Treza workloads running inside enclaves satisfy the virtual-equals-physical isolation requirement by definition, and the attestation model provides cryptographic proof that no unauthorized party accessed the processing environment.
SOC 2: Trust Service Criteria
What it is: SOC 2 (System and Organization Controls 2) is an auditing framework developed by the AICPA. It evaluates an organization against five Trust Service Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy.
Why it matters: SOC 2 Type II reports are the standard due diligence requirement for SaaS and infrastructure vendors selling to enterprises in the U.S. Unlike ISO 27001 (which certifies a management system), SOC 2 audits examine actual operating effectiveness over a period of time.
The five Trust Service Criteria:
| Criterion | What It Covers |
|---|---|
| Security | Protection against unauthorized access (logical and physical) |
| Availability | System uptime and operational resilience |
| Processing Integrity | Accuracy, completeness, and timeliness of processing |
| Confidentiality | Protection of data designated as confidential |
| Privacy | Collection, use, retention, and disposal of personal information |
How TEEs align: The Confidentiality and Security criteria map directly to TEE guarantees. Hardware-enforced memory encryption satisfies confidentiality controls at a level that software-only solutions cannot match. Treza's cryptographic attestation provides auditable evidence of processing integrity — auditors can verify that the correct code ran in the correct environment without modification. This produces a stronger evidence trail than traditional log-based audit approaches.
NIST SP 800-53: Security and Privacy Controls
What it is: NIST Special Publication 800-53 is the most comprehensive catalog of security and privacy controls published by the U.S. federal government. It contains over 1,000 controls organized into 20 families and serves as the foundation for FedRAMP, FISMA, and many sector-specific frameworks.
Why it matters: NIST 800-53 is the control framework that underlies most U.S. federal and defense security requirements. If your platform will ever process government data, support a FedRAMP-authorized application, or serve defense/intelligence customers, alignment with 800-53 is essential.
Control families most relevant to privacy infrastructure:
- SC (System and Communications Protection) — Encryption, boundary protection, cryptographic key management.
- AC (Access Control) — Least privilege, separation of duties, remote access controls.
- AU (Audit and Accountability) — Audit logging, time stamps, non-repudiation.
- IA (Identification and Authentication) — Multi-factor authentication, cryptographic authentication.
- SA (System and Services Acquisition) — Supply chain risk management, developer security testing.
How TEEs align: Treza's enclave architecture maps to several high-impact controls. SC-28 (Protection of Information at Rest) and SC-8 (Transmission Confidentiality) are satisfied through end-to-end encryption with enclave-managed keys. AC-3 (Access Enforcement) is reinforced by the attestation model — only workloads with valid attestation documents can access cryptographic materials. AU-10 (Non-Repudiation) benefits from signed attestation records that prove exactly what code processed what data.
PCI DSS 4.0: Payment Card Industry Data Security Standard
What it is: PCI DSS version 4.0 (effective March 2025) governs the protection of cardholder data for any organization that stores, processes, or transmits payment card information. It contains 12 high-level requirements across six categories.
Why it matters: Any platform handling payment flows, tokenization, or financial transaction data needs PCI DSS compliance. Version 4.0 introduces a "customized approach" that allows organizations to meet requirements through alternative controls — which is particularly relevant for novel architectures like TEE-based processing.
Requirements most relevant to privacy infrastructure:
- Requirement 3 — Protect stored account data (encryption, key management, data retention).
- Requirement 4 — Protect cardholder data with strong cryptography during transmission.
- Requirement 6 — Develop and maintain secure systems and software.
- Requirement 7 — Restrict access to system components and cardholder data by business need-to-know.
- Requirement 10 — Log and monitor all access to system components and cardholder data.
How TEEs align: TEE-based payment processing can satisfy PCI DSS requirements at the hardware level. Cardholder data processed inside an enclave is never exposed to the host system, the operator, or any other tenant — satisfying Requirement 7 through architectural isolation rather than access control lists. Treza's approach to key management within enclaves (keys sealed to the enclave's attestation identity) aligns with Requirement 3's emphasis on strong cryptographic key management.
GDPR: General Data Protection Regulation
What it is: The EU's landmark privacy regulation governing how personal data of EU residents is collected, processed, and stored. GDPR imposes strict requirements around data minimization, purpose limitation, consent, and the right to erasure.
Why it matters: Any platform processing data from EU residents must comply, regardless of where the processing occurs. Penalties can reach 4% of global annual revenue or €20 million, whichever is higher.
Key principles relevant to privacy infrastructure:
- Data minimization — Collect and process only what's necessary.
- Purpose limitation — Data can only be used for the stated purpose.
- Privacy by design — Privacy must be baked into systems, not bolted on.
- Right to erasure — Individuals can request deletion of their personal data.
- Data protection impact assessments — Required for high-risk processing activities.
How TEEs align: Zero-knowledge proofs and TEE-based processing are arguably the strongest technical implementations of GDPR's data minimization principle. Treza's ZK-KYC system, for example, allows identity verification without transmitting or storing the underlying personal data. The verifier learns only the compliance result (pass/fail) — not the name, address, or document details. This is data minimization taken to its logical conclusion. For right-to-erasure requests, data that was never stored can't be retained.
Common Criteria (ISO/IEC 15408): Security Evaluation
What it is: Common Criteria is an international framework (ISO 15408) for evaluating the security properties of IT products. Products are evaluated against Protection Profiles and assigned an Evaluation Assurance Level (EAL) from 1 (minimal) to 7 (formally verified).
Why it matters: Common Criteria certification is required for IT products sold to many government agencies, particularly in defense and national security contexts. The evaluation provides independent verification that a product's security claims are implemented correctly.
How TEEs align: The underlying hardware that powers TEE-based architectures — AWS Nitro chips, Intel SGX processors, AMD SEV processors — typically holds Common Criteria certifications. AWS Nitro cards have been evaluated against relevant protection profiles, providing a certified foundation layer for Treza's enclave workloads.
How These Standards Intersect
These standards don't exist in isolation. In practice, compliance programs layer them:
| Use Case | Primary Standards |
|---|---|
| Financial services / payments | PCI DSS 4.0, SOC 2, FIPS 140-3 |
| Healthcare | HIPAA, SOC 2, NIST 800-53 |
| Government / defense | FedRAMP (NIST 800-53), FIPS 140-3, Common Criteria |
| EU data processing | GDPR, ISO 27001, ISO 27018 |
| Crypto / Web3 compliance | BSA/AML, SOC 2, ISO 27001, travel rule |
A TEE-based architecture doesn't automatically satisfy every control in every framework. But it provides a foundation that makes many of the hardest controls — data isolation, cryptographic key protection, processing integrity, non-repudiation — achievable at the infrastructure level rather than through operational procedures that are expensive to maintain and prone to human error.
What Treza Provides Today
Treza's current platform aligns with these standards through several architectural decisions:
- Hardware-rooted isolation via AWS Nitro Enclaves satisfies the most stringent data protection requirements across FIPS, PCI DSS, and NIST 800-53.
- Cryptographic attestation produces signed, verifiable evidence of processing integrity for SOC 2 and ISO 27001 audit trails.
- ZK-KYC verification implements GDPR data minimization and privacy-by-design principles at the protocol level.
- End-to-end encryption with enclave-managed keys covers transmission and at-rest protection requirements across all frameworks.
- Privacy-preserving logging balances the audit trail requirements of SOC 2 and NIST with the data minimization requirements of GDPR.
For teams building in regulated industries, these aren't just checkboxes — they're the difference between a product that can ship and one that can't clear procurement.
Getting Started
If you're building applications that need to meet any of these compliance standards, Treza's SDK and CLI provide a path to hardware-grade privacy guarantees without the infrastructure complexity:
- Documentation — Architecture guides and deployment tutorials.
- SDK on npm —
npm install @treza/sdkto get started. - GitHub — Open-source SDK, CLI, and infrastructure.
