Key Activation
Specification
Define, implement and evaluate processes, procedures and technical measures to create keys in a pre-activated state when they have been generated but not authorized for use, which include provisions for legal and regulatory requirements.
Threat coverage
Architectural relevance
Lifecycle
Data storage
Not applicable
Not applicable
Not applicable
Maintenance
Archiving, Model disposal
Ownership / SSRM
PI
Owned by the Cloud Service Provider (CSP)
The Cloud Service Provider (CSP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with cloud computing (processing, storage, and networking) technologies in the context of the services or products they develop and offer. The CSP is responsible and accountable for implementing the control within its own infrastructure/environment. The CSP is responsible for enabling the customer and/or upstream partner to implement/configure the control within their risk management approach. The CSP is accountable for ensuring that its providers upstream implement the control related to the service/product developed and offered by the CSP.
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 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.
Application
Owned by the Application Provider (AP)
The Application Provider (AP) is responsible 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. The AP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the AP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The AP is accountable for carrying out the due diligence on its upstream providers (e.g MPs, Orchestrated Services) to verify that they implement the control as it relates to the service/product develop and offered by the AP. These providers build and offer end-user applications that leverage generative AI models for specific tasks such as content creation, chatbots, code generation, and enterprise automation. These applications are often delivered as software-as-a-service (SaaS) solutions. These providers focus on user interfaces, application logic, domain-specific functionality, and overall user experience rather than underlying model development. Example: OpenAI (GPTs,Assistants), Zapier, CustomGPT, Microsoft Copilot (integrated into Office products), Jasper (AI-driven content generation), Notion AI (AI-enhanced productivity tools), Adobe Firefly (AI-generated media), and AI-powered customer service solutions like Amazon Rufus, as well as any organization that develops its AI-based application internally.
Implementation guidelines
Auditing guidelines
1. Verify that the CSP defines processes, procedures, and technical measures to generate cryptographic keys in a pre-activated state, where keys are not authorized for use until explicitly approved. 2. Confirm that pre-activated keys are securely stored and logically separated from active key inventories until explicitly activated (e.g., across cloud services, infrastructure encryption platforms, or tenant-specific KMS configurations). 3. Review the CSP’s key activation approval workflow to validate that formal authorization is required before any pre-activated key is transitioned to active use. 4. Validate that key activation privileges are restricted to authorized personnel or services and that multi-party approvals or policy enforcement gates are in place where required. 5. Confirm that key activation controls are consistently enforced across all cloud infrastructure components, including KMS, HSMs, and encryption-as-a-service offerings. 6. Review logs of key activation events and ensure they capture the key ID, activation time, initiating identity, approval references, and affected systems or services. 7. Verify that legal and regulatory requirements (e.g., data protection laws, export controls, financial encryption rules) are considered and enforced in CSP key activation policies. 8. Confirm that pre-activated keys are subject to expiration, timeout, or revalidation policies if not activated within a defined period. 9. Validate that cryptographic keys supporting AI workloads (e.g., model storage encryption, inference protection, prompt handling) follow the same pre-activation controls and approval workflows as general-purpose keys. 10. Confirm that the CSP’s key activation procedures support coordination with upstream providers (e.g., hardware security module vendors) and downstream consumers (e.g., APs, AICs), especially where activation status impacts shared services or encryption chains. From CCM: 1. Confirm the existence of processes and procedures to generate keys. 2. Confirm that the access and permissions around the key creation process is restricted to appropriate individuals. 3. Identify the key management server and the key storage database. 4. Review the key attributes and confirm that these are appropriate for the key (e.g., activation data, instance, deletion ability, rollover) 5. Confirm the key activation process (e.g., manual, on creation, at a future time). 6. Review the pre-activated keys.
Standards mappings
No Mapping for ISO 42001 ISO 27001: A.8.24 ISO 27002: 8.24
Addendum
Add a control requiring AI systems to define, implement, and evaluate processes, procedures, and technical measures to create keys in a pre-activated state when generated but not authorized, including legal and regulatory provisions, addressing ISO 42001:2023’s lack of pre-activation key management, enhancing ISO 27001 (A.8.24) and ISO 27002 (8.24).
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 activation.
CRY-04
Addendum
N/A
AI-CAIQ questions (1)
Are processes, procedures, and technical measures to create keys in a pre-activated state (i.e., when they have been generated but not authorized for use) defined, implemented, and evaluated, including provisions for legal and regulatory requirements?