Key Rotation
Specification
Rotate cryptographic keys in accordance with the calculated cryptoperiod, which includes provisions for considering the risk of information disclosure and legal and regulatory requirements.
Threat coverage
Architectural relevance
Lifecycle
Data storage
Not applicable
Not applicable
Orchestration, AI Services supply chain, AI applications
Operations, Maintenance, Continuous monitoring
Archiving, Data deletion, Model disposal
Ownership / SSRM
PI
Shared Cloud Service Provider-Model Provider (Shared CSP-MP)
The CSP and MP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.
Model
Owned by the Model Provider (MP)
The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.
Orchestrated
Shared Model Provider-Orchestrated Service Provider (Shared MP-OSP)
The MP and OSP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.
Application
Shared Orchestrated Service Provider-Application Provider (Shared OSP-AP)
The OSP and AP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.
Implementation guidelines
Auditing guidelines
1. Verify that the CSP rotates cryptographic keys in accordance with defined cryptoperiods, considering the risk of information disclosure and legal or regulatory requirements across cloud infrastructure, storage, and key management services. 2. Confirm that cryptoperiods are formally defined for each key type based on key usage, data classification, risk exposure, and applicable compliance requirements. 3. Verify that automated key rotation is implemented in supported services (e.g., KMS, HSM, database encryption), and manual key rotation follows documented procedures. 4. Review configuration baselines and key management system settings to ensure rotation schedules are enforced consistently and override attempts are monitored and approved. 5. Confirm that access to initiate or configure key rotation is limited to authorized cloud operations or security teams, following role-based access control and approval workflows. 6. Validate that cryptographic keys used in CSP services supporting AI workloads (e.g., encrypted model storage, prompt logging, inference caching) follow rotation schedules aligned with defined cryptoperiods. 7. Review audit logs to confirm that key rotation events are logged with relevant metadata (e.g., key ID, time, rotation trigger, system ID, user ID) and retained for auditability. 8. Confirm that rotated keys are distributed securely across CSP infrastructure and dependent services, ensuring continuity and preventing exposure of key material. 9. Verify that superseded or expired keys are securely archived or destroyed based on CSP data classification and compliance retention policies. 10. Confirm that the CSP coordinates key rotation schedules with downstream entities (e.g., APs, AICs) and evaluates upstream cryptographic dependencies to ensure uninterrupted encryption and trust continuity. From CCM: Consider the symmetric vs. asymmetric key rotation capabilities of CSPs and that an appropriate rotation process is adopted. 1. Confirm that policy and procedures include a requirement for regular key rotation. 2. Identify keys used within the organization. Confirm that these keys are part of the rotation process. 3. Review the key rotation process to confirm logging and monitoring of key rotation, tracking of date, time, encryption algorithm used, and authorization process used.
Standards mappings
No Mapping for ISO 42001 ISO 27001: No Mapping ISO 27002: Control 8.24
Addendum
Add a control requiring AI systems to rotate cryptographic keys in accordance with their calculated cryptoperiod, incorporating provisions for assessing the risk of information disclosure and adhering to legal and regulatory requirements, addressing the gap in ISO 42001:2023’s lack of specific key rotation mandates. Include guidance on cryptoperiod calculation and risk-based rotation, enhancing ISO 27001 (A.8.24) and ISO 27002 (8.24) for AI-specific key lifecycle management.
No Mapping
Addendum
Cover the AICM control.
No Mapping
Addendum
No (implicit/explicit) reference to cryptography, encryption, or key management is made in the NIST AI 600-1 standard, let alone to the specific requirement of key rotation.
CRY-04
Addendum
N/A
AI-CAIQ questions (1)
Are cryptographic keys rotated based on a cryptoperiod calculated while considering information disclosure risks, and legal and regulatory requirements?