Sovereign hardware risk
Pillar 1 of 5 · 7 min read · Grounded in hardware certification standards — Ciptor, NeoWave & Feitian Technlogies
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The assumption
All FIDO2 security tokens are functionally equal, regardless of their manufacturing supply chain or country of origin.
Once the decision to deploy hardware security keys has been made, procurement teams typically evaluate on price, compatibility, and form factor. FIDO2 certification from the FIDO Alliance is treated as the definitive quality mark — if a device is on the certified products list, it is assumed to meet the same security standard as every other device on that list. The country of manufacture is rarely part of the evaluation criteria.
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The reality
FIDO2 certification validates the protocol implementation. It does not validate the firmware integrity, the chip supply chain, or the data residency of the manufacturer. These are separate risks — and for regulated industries, they are material ones.
The FIDO Alliance certification programme tests whether a device correctly implements the FIDO2 standard. It is a protocol compliance test, not a hardware security assurance programme. Two devices can both pass FIDO2 certification while having fundamentally different security properties at the chip level, the firmware level, and the supply chain level.
EAL5+ |
The Common Criteria Evaluation Assurance Level required for the secure element chips in high-assurance hardware tokens — a significantly higher bar than FIDO2 certification alone, which imposes no chip-level security requirement.Source: Common Criteria Recognition Arrangement (CCRA); ANSSI Security Visa programme |
The supply chain risk is not theoretical. Firmware manipulation at the manufacturing stage — inserting a persistent backdoor or key exfiltration mechanism into hardware before it ships — is a documented class of nation-state attack. The US CISA, the UK NCSC, and the EU ENISA have all published guidance on hardware supply chain integrity as a critical infrastructure concern. For organisations in defence, critical infrastructure, financial services, and regulated healthcare, deploying hardware tokens manufactured in jurisdictions with adversarial intelligence relationships introduces a risk that no software control can remediate after the fact.
Third-Country data residency |
Hardware tokens that phone home to manufacturer infrastructure for telemetry, firmware updates, or device management may transmit authentication metadata to servers outside EU jurisdiction — a potential GDPR and NIS2 compliance exposure.Source: ENISA guidelines on supply chain security, 2024 |
"A hardware security key is only as trustworthy as the integrity of the chip inside it. FIDO2 tells you the key works correctly. It does not tell you the key works exclusively for you." — NeoWave technical advisory team
Pillar 1 — Adversary tactics
Vol. 1 The endpoint illusion
Vol. 2 The fallacy of network-delivered codes
Vol. 3 The helpdesk open door
Vol. 4 Sovereign hardware risk
Vol. 5 The hybrid infrastructure blindspot
The blueprint
Standardise on sovereign Western hardware built on Common Criteria EAL5+/EAL6+ certified chips carrying the ANSSI Security Visa — and verify the supply chain custody, not just the product specification sheet.
Hardware sovereignty is not a premium feature. For any organisation in a regulated sector or with government contracts, it is a baseline procurement requirement that should be evaluated before FIDO2 compatibility — because a compromised token that correctly implements FIDO2 is a worse outcome than an incompatible token that doesn't deploy at all.
What the certification hierarchy actually means
The certification landscape for hardware security keys has multiple layers, and they assess different things. Understanding what each certification does — and does not — cover is the foundation of an informed procurement decision.
The NeoWave and Feitian Technologieds distinction
NeoWave is a French manufacturer whose secure element chips are independently evaluated to Common Criteria EAL6+ and hold the ANSSI Security Visa — the most rigorous national security certification available in Europe for cryptographic hardware. All firmware development, chip manufacturing, and device assembly takes place under French jurisdiction, with no third-country manufacturing steps in the supply chain.
Feitian Technologies produces FIDO2-certified hardware tokens that are widely deployed globally. Their devices pass FIDO2 protocol certification. The distinction relevant to regulated European organisations is that manufacturing takes place in China, subject to Chinese law — including legislation that can compel cooperation with national intelligence services. For organisations in defence supply chains, critical infrastructure, or handling classified data, this is a disqualifying supply chain characteristic regardless of protocol compliance.
Procurement checklist for hardware sovereignty
- Chip certification: Require Common Criteria EAL5+ or higher for the secure element. Ask vendors to provide the specific evaluation report, not just the certificate number.
- Manufacturing jurisdiction: Specify that all manufacturing stages — chip fabrication, firmware loading, device assembly — must occur within EU/NATO-aligned jurisdictions.
- Firmware update infrastructure: Confirm that firmware update signing keys are held exclusively by the manufacturer, with no third-party key custody, and that update delivery does not route through third-country infrastructure.
- Data residency: Verify that no authentication metadata, device telemetry, or management data is transmitted to infrastructure outside EU jurisdiction.
ANSSI Security Visa or equivalent: For highest-assurance deployments, require explicit national authority certification in addition to Common Criteria evaluation.
The practical deployment position
For most enterprise deployments, a pragmatic approach combines both NeoWave and Feitian hardware — NeoWave for privileged users, executives, and anyone with access to classified or regulated data; Feitian for the broader workforce where the primary requirement is FIDO2 phishing resistance and supply chain sovereignty is a secondary consideration. This tiered approach balances security assurance with procurement cost across different user populations.
The critical point is that this should be an explicit decision, made with full awareness of the supply chain risk profile of each device, rather than an implicit one made by defaulting to the lowest-cost FIDO2-compatible option across the entire fleet.
Next in the series
Vol. 5 — The hybrid infrastructure blindspot
Your cloud SSO is secure. Your on-premises legacy systems are not. Attackers target the seam between them — and it is almost never monitored.
