The Missing Layer in IACS UR E26/E27 — Why Maritime Cyber Resilience Needs HSM and KMS
Protecting the cryptographic keys behind ship identity, secure communications and software integrity — before AI and quantum computing meet.
A recent article on this site by a class surveyor summarised the first two years of UR E26/E27 as a shift in the centre of gravity of class survey — from verifying physical objects to verifying system behaviour. Reviewers now ask whether a security capability described in a CSDD (Cyber Security Design Description) is a catalogue phrase or an actually configured setting. I would like to add one question that remains after the zones and conduits are drawn and the firewalls and VPNs (Virtual Private Networks) are in place: where are the cryptographic keys that those systems rely on for trust — and what happens to them when a system is compromised?
1. When the Perimeter Falls, the Keys Go With It
The past two years of edge-device incidents tell a consistent story. In early 2024, chained authentication-bypass and command-injection flaws in Ivanti Connect Secure led to more than 2,100 compromised appliances identified by external scanning; attackers harvested stored credentials, moved laterally, and evaded the vendor's own integrity checking tool.
Fortinet's FortiGate — one of the most widely deployed firewall and SSL-VPN (Secure Sockets Layer Virtual Private Network) platforms, including on board commercial vessels — illustrates the same problem from three angles:
- Stolen configurations outlive the vulnerability. In January 2025, a threat actor published configuration files, including administrator and VPN user credentials, for more than 15,000 FortiGate devices — data believed to have been extracted years earlier through an authentication-bypass flaw that had long since been patched.
- Persistence survives patching. In April 2025, Fortinet disclosed that attackers had planted a symbolic link in the SSL-VPN file system that kept read-only access to device files, including configurations, even after the original flaws were fixed. The Shadowserver Foundation counted over 16,000 affected internet-facing devices, and CERT-FR (France's national Computer Emergency Response Team) advised resetting all secrets — credentials, certificates, identity tokens and cryptographic keys.
- AI removes the skill barrier. Between January and February 2026, Amazon Threat Intelligence observed a low-to-medium-skilled, financially motivated actor use commercial generative AI tools to compromise more than 600 FortiGate devices in 55 countries. No vulnerability was exploited — only exposed management interfaces and weak single-factor credentials. The actor extracted full configurations containing VPN and administrative credentials, and used AI-generated scripts to parse and decrypt them.
This is not a criticism of one vendor; every edge platform faces the same structural issue. As long as keys and credentials live inside the device's software, compromising the device means compromising the keys — and a patch closes the hole but never recalls a key that has already left. Ships face this under worse conditions: patches wait for voyage schedules and satellite bandwidth, there is no security specialist on board to judge an alert, and IT (Information Technology) compromise can propagate into machinery and navigation systems. An environment that detects late and patches late needs a design in which keys cannot leave in the first place.
2. AI and Quantum Computing: Two Halves of One Attack Chain
AI and quantum computing are usually discussed as separate threats. For maritime operators they should be seen as the front and back ends of the same chain, and both converge on one target: keys and identity.
Today, AI lowers the cost of attack to the point where small operators and equipment suppliers who assumed they were "not a target" now are; the FortiGate campaign above is a live example. Tomorrow's risk is Harvest Now, Decrypt Later (HNDL): adversaries record encrypted traffic now and decrypt it once a cryptographically relevant quantum computer can run Shor's algorithm against RSA (a widely used public-key encryption algorithm) and elliptic-curve cryptography. No such machine exists yet and timelines are debated — but AI changes the economics of harvesting, because it can automatically triage vast volumes of intercepted data and keep what is worth decrypting later.
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Shipping meets both HNDL preconditions unusually well. Nearly all ship–shore traffic — operational data, remote maintenance sessions, software updates — travels over satellite links whose signals are broadcast over wide areas, and voyage and cargo data for energy carriers, naval auxiliaries or major charterers keeps its value for years. Where the attack target is a signing key or a control channel, the consequence in OT (Operational Technology) is not just disclosure but forgery: an attacker who holds a trusted key does not need to break in; they are let in.
3. UR E27 Already Talks About Keys
UR E26/E27 are goal-based and do not mandate any specific product, and nothing in this article should be read as claiming otherwise. It is sometimes said, however, that E27 never mentions HSMs (Hardware Security Modules). The text says otherwise. Section 6.3.4.1 (IEC 62443-4-1, the IEC's industrial/OT cybersecurity product-security standard — requirement SM-8) requires suppliers of digitally signed software to show policies, procedures and technical controls protecting the generation, storage and use of code-signing private keys, and gives cryptographic hardware such as a hardware security module as an example of such a technical control. An example is not an obligation — but when a surveyor asks what the technical control actually is, it is the most demonstrable answer. Table 1 lists the E27 items that touch keys directly.
| UR E27 Rev.1 Requirement | What It Asks For (Summary) | What It Means for Key Management |
|---|---|---|
| §4.1 #4 Authenticator management | Protect authenticators from unauthorised disclosure and modification when stored and transmitted | Keep credentials and keys inside a secure element or HSM, not in files |
| §4.1 #22 Use of cryptography | Algorithms, key sizes and mechanisms per commonly accepted industry practice | KMS (Key Management System)-based crypto agility so algorithms can change as practice changes |
| §4.2 #31, #32 MFA (Multi-Factor Authentication); device authentication | MFA over untrusted networks; identify and authenticate software processes and devices | Hardware tokens for remote maintainers; per-device certificates (device ID) |
| §4.2 #38 Cryptographic integrity | Cryptographic mechanisms to recognise changes in communication via untrusted networks | SATCOM (Satellite Communications) VPN/TLS (Transport Layer Security) keys issued, rotated and revoked via HSM + KMS |
| §5.1 / §6.3.4.1 Private keys for code signing (SM-8) | Policies and technical controls for generation, storage and use of signing keys; HSM cited as an example | Signing keys non-exportable in an HSM, with role separation and audit logs |
| §5.4 / §6.3.4.4 Update authenticity (SUM-4) | Users must be able to verify that security updates are authentic | Signature verification chain anchored in secure boot on the device |
4. HSM Protects the Key; KMS Governs Its Life
Keys on a ship are not only on the ship. The most dangerous keys are often ashore. If one equipment maker's firmware-signing key leaks, correctly signed malicious updates can reach every vessel carrying that equipment. Figure 2 maps where keys sit across shore, link and onboard layers, what protects them, and which requirements they relate to.
Equipment manufacturers: moving code-signing keys into an HSM is the clearest way to evidence SM-8 during E27 type approval. Shipowners and managers: a fleet KMS and PKI (Public Key Infrastructure) to issue, rotate and revoke remote-access certificates, VPN keys and device certificates across vessels and vendors. This also helps with the grey zone around owner-supplied systems raised in the surveyor's article: if owner-supplied CBS (Computer Based System) must obtain certificates from the owner's PKI before connecting, responsibility at the interface becomes explicit. Onboard equipment: designed for unattended operation, with device identity held in a tamper-resistant secure element that erases keys on physical intrusion.
5. A Moving Baseline: The Post-Quantum Transition
E27 item #22 does not name algorithms; it requires "commonly accepted security industry practices". Not naming them means the baseline moves. NSA's (U.S. National Security Agency) CNSA 2.0 (Commercial National Security Algorithm Suite 2.0) requires software and firmware signing to use quantum-resistant algorithms exclusively by 2030; NIST's (U.S. National Institute of Standards and Technology) draft transition guidance (IR 8547) proposes deprecating RSA and ECDSA (Elliptic Curve Digital Signature Algorithm) after 2030 and disallowing them after 2035; Korea's national migration master plan also targets 2035. NIST has already standardised ML-KEM (Module-Lattice-Based Key-Encapsulation Mechanism, FIPS 203) and ML-DSA (Module-Lattice-Based Digital Signature Algorithm, FIPS 204).
Servers ashore are replaced every three to five years; a ship contracted in late 2024 will trade into the 2050s. This does not mean replacing every system with post-quantum cryptography tomorrow — most onboard equipment cannot support it yet. It means designing crypto agility in now: hybrid classical-plus-PQC (Post-Quantum Cryptography) schemes on ship–shore links, and an architecture in which algorithms can change without replacing equipment. The practical switching point for that change is the HSM and KMS layer.
6. Five Questions for Shipowners and Security Managers at RFQ Stage
- 1 Where are your code-signing private keys stored, and to what standard (e.g. FIPS 140-3 — a U.S. cryptographic-module security standard, or KCMVP — Korea's Cryptographic Module Validation Program) is that HSM validated? (E27 SM-8)
- 2 Are device credentials and identity keys in the file system, or inside a secure element? (E27 #4, #32)
- 3 Who issues and revokes remote-maintainer certificates — the manufacturer or the owner?
- 4 Can cryptographic algorithms be changed through a firmware update, and what is your post-quantum roadmap? (E27 #22)
- 5 Is there a cryptographic bill of materials (CBOM) for the whole ship, including owner-supplied systems?
Closing: Firewalls Guard the Door; HSMs Guard the Keys
Strengthening the key layer does not require dry-docking a ship. Existing firewalls, VPNs and detection tools remain in service; only the keys they trust move behind a hardware boundary. The sequence is straightforward: inventory where cryptography is used (CBOM); move shore-side signing keys and PKI roots into HSM/KMS, which protects the whole fleet without touching a vessel; write crypto agility into newbuild specifications; and build secure elements into the next generation of onboard equipment.
UR E26/E27 have taught the industry to demonstrate cyber resilience. The next question is who is responsible for the keys that underpin that demonstration — where they are held, and for how long. When that question appears in shipbuilding contracts and equipment purchase specifications, cyber resilience will stop being a set of documents and become part of the ship's structure.
Related Reading:
- IACS UR E26/E27: Two Years of Survey Practice — A Class Surveyor's Inside View
- UR E27 Is Already in Effect — So Why Do Marine Equipment Manufacturers Still Feel So Little Urgency?
- Is Our Product Actually Subject to UR E27?
- Maritime Cybersecurity Learning Roadmap — From Cybersecurity Fundamentals to Maritime Cyber Resilience
- What Is Cybersecurity? — The CIA Triad, Risk, Controls, and Resilience
Kevin CK Lee is President & Co-Founder of Keypair, Inc., a Seoul-based company he has led since January 2014 that developed the world's first NFC (Near-Field Communication)-enabled OTP (One-Time Password) & HSM smart IC card for PKI and electronic authentication, later extending into AMI (Advanced Metering Infrastructure), Smart Grid and access-control security. Keypair's current lineup includes the KeyWallet series of NFC and biometric-token crypto cold wallets. He also advises Pharmaonex, and previously served as President of Insprit (developer and manufacturer of Korea's first tablet), CEO of Reakosys Inc. (MPEG4 (Moving Picture Experts Group-4) streaming and video compression for early feature phones), and Regional Director at Alcatel-Lucent (ATM (Asynchronous Transfer Mode)/IP (Internet Protocol) product marketing for telecom and broadband carriers).
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Excellent perspective,
ReplyDeleteWe often discuss E26/E27 in terms of zones, conduits, firewalls and compliance evidence. This article brings attention to the layer underneath them — cryptographic trust, identity, keys and their lifecycle.
The question of who owns, protects, rotates and revokes those keys could become increasingly important as ships move toward longer operational lifecycles and greater AI/PQC-related risks.
A very valuable perspective for the maritime cybersecurity community.