Key Deactivation
Specification
Define, implement and evaluate processes, procedures and technical measures to deactivate keys at the time of their expiration date, which include provisions for legal and regulatory requirements.
Threat coverage
Architectural relevance
Lifecycle
Data storage
Training
Not applicable
Orchestration, AI Services supply chain, AI applications
Operations, Maintenance, Continuous monitoring, Continuous improvement
Archiving, Data deletion, Model disposal
Ownership / SSRM
PI
Shared across the supply chain
Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.
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 defines, implements, and evaluates processes, procedures, and technical measures to deactivate cryptographic keys at the time of their expiration date, including provisions for legal and regulatory requirements (e.g., keys used in cloud infrastructure, managed storage encryption, KMS-based key provisioning). 2. Confirm that expiration metadata is defined for each cryptographic key managed by the CSP and tracked in centralized or service-specific key management systems. 3. Review whether automated expiration and deactivation mechanisms are implemented in the CSP’s key lifecycle tools (e.g., KMS, HSM, cloud-native encryption services). 4. Validate that keys approaching expiration are flagged and isolated from usage in active service pipelines or customer-facing operations. 5. Confirm that access to expired or deactivated keys is restricted through access control policies, logical isolation, or service-level enforcement mechanisms. 6. Review CSP audit trails and system logs to confirm that deactivation events are recorded with relevant metadata (e.g., key ID, expiration date, initiating system, affected services). 7. Verify that expired keys are transitioned to secure archival or destruction procedures, consistent with CSP’s data retention and cryptographic lifecycle policies. 8. Confirm that legal, regulatory, and contractual requirements (e.g., GDPR, financial recordkeeping, FIPS compliance) are incorporated into the CSP’s deactivation workflows and documentation. 9. Validate that CSP-managed keys supporting AI workloads (e.g., encrypted AI model storage, inference data, prompt logs) are subject to the same expiration and deactivation procedures. 10. Review whether the CSP coordinates deactivation timelines and notifications with upstream providers (e.g., hardware KMS vendors) and downstream entities (e.g., APs, AICs) to maintain continuity of encrypted services and avoid disruptions. From CCM: 1. Confirm the existence of processes and procedures to deactivate keys. 2. Review the access and permissions around the key deactivation process and confirm this is restricted to appropriate individuals. 3. Review key deactivation process and configurations. Confirm that they are in line with internal and external requirements. 4. Confirm the key deactivation process (e.g., manual, on expiration, at a defined future time.)
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 deactivate keys at their expiration date, including legal and regulatory provisions, addressing ISO 42001:2023’s lack of specific key deactivation requirements, enhancing ISO 27001 (A.8.24) and ISO 27002 (8.24).
No Mapping
Addendum
Cover the AICM control.
No Mapping
Addendum
No (explicit/implicit) reference is made in the NIST AI 600-1 standard as to the requirement of defining, implementing, or evaluating processes, procedures, and/or technical measures in the domain of key deactivation.
CRY-04
Addendum
N/A
AI-CAIQ questions (1)
Are processes, procedures, and technical measures to deactivate keys (at the time of their expiration date) defined, implemented, and evaluated including provisions for legal and regulatory requirements?