Hi Henrick,

On 7/11/26 19:43, Henrick Hellstrom wrote:
I agree, that discussion could be generalized and carried over to the TLS security considerations.

I'm glad we agree on that. The remaining question is what the text
should say.

I would suggest something along these lines:

  FIPS 203 requires that ML-KEM.KeyGen and ML-KEM.Encaps use fresh
  randomness generated by a NIST-approved randomness source.
  Implementations should not use raw primary RNG output directly as
  the ML-KEM `m` value because that value is recoverable by the
  decapsulating peer. Implementations should use a properly separated
  RBG/DRBG and/or a context-bound derivation for ML-KEM encapsulation
  randomness, and as the original design of Kyber did `m <- H(m)`,
  the `m` value should be hashed by a suitable secure cryptographic
  hash function. This is a defense-in-depth measure against
  hidden-structure RNG failures, including Dual_EC_DRBG-shaped
  kleptographic attacks.

I am not attached the text but the core message is very important.

In the case of ML-KEM specifically, you get it implicitly for TLS as
long as the implementation of ML-KEM is fully FIPS 203 conformant.
This is what the relevant paragraph on page 16 of FIPS 203 says:

"Randomness generation. Two algorithms in this standard require the generation of randomness as an internal step: ML-KEM.KeyGen and ML- KEM.Encaps. In pseudocode, this randomness generation is denoted by a statement of the form m <- B32. A fresh string of random bytes must be generated for every such invocation. These random bytes shall be generated using an approved RBG, as prescribed in SP 800-90A, SP 800-90B, and SP 800-90C [18, 19, 20]. Moreover, this RBG
shall have a security strength of at least 128 bits for ML- KEM-512,
at least 192 bits for ML-KEM-768, and at least 256 bits for ML-
KEM-1024."

I understand that argument and I am surprised when really intelligent
people fall for this extremely low budget argument. It doesn't even have
to be an Adversary trick, it's simply not an actually met requirement
most of the time in reality. The core problem is that TLS deployments do not automatically become fully validated FIPS 203 environments merely by using ML-KEM. The TLS draft also does not currently call out this specific FIPS 203 dependency in its Security Considerations but it has other details, oddly.

So I do not think TLS gets this protection "implicitly" in a way that is
clear enough for implementers. I have surveyed quite a number of
libraries and found that FIPS203 is followed for the removal of the hash
over `m` but rarely, if ever, for the NIST-approved entropy source as a
hard requirement. The draft _should_ say the assumption explicitly, and
it should say why it matters since it is absolutely critical for security.

Relying only on the phrase "approved RBG" is also not enough history for
this particular discussion. Dual_EC_DRBG was once standardized in the
same general family of standards. The lesson should not be "trust the
label"; it should be "do not expose structured RNG output when cheap
separation or whitening avoids it."

If an implementation is not FIPS-constrained, then restoring Kyber-style
`m <- H(m)` or using a context-bound derivation of `m` is the simpler
defense-in-depth answer. If side-channels are a concern then I observe
that having a remote oracle isn't likely to make those less effective.

Either way, the security goal is the same: do not give the decapsulating
peer a clean sample of raw, structured RNG output.

Kind regards,
Jacob

[0] https://groups.google.com/a/list.nist.gov/g/pqc-forum/c/WFRDl8DqYQ4/
m/o2XJ2YvfAwAJ

[1] https://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.203.pdf


On 2026-07-11 18:00, Jacob Appelbaum wrote:
Hi Henrick,

On 7/11/26 13:53, Henrick Hellström wrote:
Hi Jacob,

On 2026-07-09 18:11, Jacob Appelbaum wrote:
Obviously no one should use Dual_EC_DRBG. The problem is that users often do not know when their randomness source is sabotaged. Hashing does not solve all bad-RNG problems, but it
does destroy the
algebraic
structure used in this known attack class.

Yes, I understand this might once have been brought in as a quick-fix for Dual_EC-DRBG debacle, but at this time it ought to
be replaced by a more permanent fix.

I agree that a permanent fix is better than an ad hoc fix.

Where I disagree is the implication that the issue has already been permanently fixed in the TLS draft. If the permanent fix is "never hand raw primary RBG output to ML-KEM.Encaps() as decapsulator-recoverable `m`", then that should be stated clearly in the Security Considerations.

The Kyber hash was not merely nostalgia for Dual_EC_DRBG. It was a cheap defense-in-depth step against exposing raw system RNG output to the recipient. Prof. Dr. Peter Schwabe made that point explicitly during the NIST discussion [0]. FIPS 203 removed that step and instead relies on a requirement for approved randomness generation [1]. That dependency is exactly what the TLS draft should surface.

Because who exactly do you mean by "user" in this context, and what kind of conformance certification is required?

By "user" I mean the people who rely on TLS deployments: browser users, citizens using government systems, operators, administrators, device owners, library consumers, and people depending on remote services. They are usually not in a position to audit whether a hardware RNG, firmware RNG, HSM, cloud module, or library RNG is sabotaged.

That is why this belongs in protocol security guidance. A lab conformance story is not the same thing as user protection.

If you would want the implementation to be FIPS 140 conformant, the randomness source consumed by ML-KEM would have to be an approved DRBG, but it can be a secondary DRBG, like I described,
and it should be one of the symmetric, more easily analysed
DRBGs.

That may indeed be a good answer if it is mandatory, isolated, and specified carefully.

A secondary symmetric DRBG seeded from a primary RBG can plausibly destroy Dual_EC_DRBG-shaped (x-coordinate) structure, provided that raw primary output is not exposed elsewhere and the secondary DRBG is properly instantiated, reseeded, separated by use, and implemented. If that is the intended FIPS-friendly permanent fix, then the draft should say so.

What the draft should not do is silently inherit the assumption "approved RBG" as if that alone answered the historical failure mode. Dual_EC_DRBG was once standardized in the same general standards family. The lesson should not be "trust the label"; it should be "do not expose structured RBG output when cheap separation or whitening avoids it."

On the other hand, if you add a hash between the approved DRBG and the ML-KEM implementation, it would become an algorithm that
clearly differs from the specifications and requirements of NIST
SP 800-90, so I doubt it would be FIPS 140 certifiable.

This may be true for a strict FIPS validation boundary. If so, it is not a rebuttal; it is the problem stated plainly. Also, this isn't a draft about FIPS per se, though it is clearly very related
to IETF finding consensus on FIPS 203.

If restoring Kyber's `m <- H(m)` step would make an implementation
no longer FIPS 140 certifiable as ML-KEM, then the TLS draft
should say what FIPS-constrained implementations are expected to
do instead. For example: use an approved, separate, symmetric DRBG
or approved derivation construction for ML-KEM encapsulation
randomness, with domain separation, so that raw primary RBG output
is never used directly as `m`.

For non-FIPS-constrained implementations, Kyber-style hashing or context-bound derivation of `m` remains the simple defense-in- depth answer. For FIPS-constrained implementations, the answer may be a validated secondary DRBG construction. Either way, the security goal is the same: do not give the decapsulating peer a clean sample of raw, structured RNG output.

So I think we may be closer than it first appeared. If your position is:

"Do not use raw primary RBG output directly as ML-KEM `m`; use a properly separated approved secondary DRBG instead if FIPS validation is required"

then I would appreciate seeing that written into the draft's Security Considerations, along with the reason it matters to implementers.

Kind regards, Jacob

[0] https://groups.google.com/a/list.nist.gov/g/pqc-forum/c/ WFRDl8DqYQ4/ m/o2XJ2YvfAwAJ

[1] https://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.203.pdf

[2] https://csrc.nist.gov/pubs/fips/140-3/final

On 7/9/26 10:39, Henrick Hellstrom wrote:

On 2026-07-09 10:10, Tanja Lange wrote:

The question by Benjamin Kaduk was if there are cases where the
server hellow would not leak the state of the PRNG (adding P for clarity^*) and Botan implements that protection. There are other libraries that have seperate PRNGs for public and private values.

To further support Tanja's point: The sub-topic is not ordinary PRNG quality. It is avoiding leakage of bytes that can form a covert channel and carry algebraic structure from kleptographic RNGs such as Dual_EC_DRBG. That kind of leakage can happen through many protocol fields, including TLS fields,
and it is a specification-level defense- in-depth gap.

ML-KEM as finalized in FIPS 203 removed Kyber's hash over `m`,
even though at least one Kyber designer explicitly argued that
hashing `m` avoids sending system RNG output to the recipient
[0]. NIST later announced that the hash would be removed [1].
I have not seen an analysis from NIST showing that this
removal remains safe against their own historical example:
Dual_EC_DRBG, a DRBG NIST described as "provided by NSA,"
which NIST later said there were many reasons to reject or
modify, but "instead, we left it in" [2][3].

Any such analysis would have had to address the central point:
hashing destroys the Dual_EC_DRBG algebraic structure needed
for efficient state recovery.

Yes, but just hashing the output from a DRBG is not the approved way
to do it. Instead you are supposed to spawn a secondary DRBG with a seed generated from a primary DRBG.

That may be an approved construction for ordinary DRBG engineering, but it is not obviously a defense against a DRBG whose output is intentionally structured to leak its state. If
the primary DRBG is Dual_EC_DRBG-shaped, spawning another DRBG
from it may simply give the defender two things to audit.
Please point me to the specific approval text you mean where
the "do it" is defending against this class of Dual_EC_DRBG
kleptographic backdoor.

Dual_EC_DRBG output can look secure by many metrics and still act as a covert channel [4]. With the relevant trapdoor/ secret key(s), an Adversary who can sample enough output can recover DRBG state and predict future outputs. The general attack is well established [5][6] [7]. The RSA/Dual_EC_DRBG reporting and the BULLRUN reporting are the relevant historical context here [8][9].

Obviously no one should use Dual_EC_DRBG. The problem is that users often do not know when their randomness source is sabotaged. Hashing does not solve all bad-RNG problems, but it
does destroy the algebraic structure used in this known attack
class.

Just hashing wouldn't do much good, if you are really concerned that
the DRBG output might reveal anything about the internal state.

For this attack class, it does good.

Hashing `m` during `ML-KEM.Encaps()`, for example with the ML-
KEM public key and/or transcript context, binds `m` to context
before the ML-KEM ciphertext is sent. In the normal non-ECH
TLS 1.3 case, that closes the Dual_EC_DRBG-shaped oracle
against the server's RNG output. With ECH using ML-KEM or a
hybrid KEM, the same concern can arise in both directions.

A few objections have come up repeatedly:

0. Ad-hominem attacks

1. TLS already has random fields written to the wire, so we should not worry about ML-KEM

2. NIST already issued FIPS 203, so the IETF should not revisit the issue

3. Updating drafts, RFCs, or implementations would be work

4. The issue also affects hybrids, so the hybrid recommendation should be weakened

5. Hashing may not increase entropy

6. Hashing DRBG output merely creates a new DRBG, DRBG'

Briefly:

0. The IETF mission is to make the Internet work better for the people who use and manage it [10], and the IETF considers pervasive monitoring an attack [11]. Cryptographic sabotage is part of how pervasive monitoring becomes actionable intelligence. Attacking the person raising the issue is irrelevant to the technical question.

1. It is true that TLS has a broader problem with raw random bytes in protocol-visible fields. That is a reason to fix the broader issue, not a reason to preserve the same problem in ML- KEM. Tanja pointed out that Botan already has a TLS protection strategy. Other libraries use different ad-hoc strategies, or none. That is exactly why IETF guidance would help.

2. FIPS 203 being final is not the end of the story. NIST can publish errata, revisions, or clarifications. NIST withdrew Dual_EC_DRBG after public reporting on BULLRUN and related cryptographic sabotage. A NIST participant who described himself as a main author of FIPS 203 is on this list, and I have asked for clarification on both the hashing decision and the IPR implications.

3. Yes, updates take work. That is not a security argument. If
the Security Considerations of the draft omit an important assumption and a cheap mitigation, that should be fixed. This is a constructive suggestion and an easy win to build consensus.

4. The issue also applies to hybrid X25519MLKEM* constructions. The answer is not to weaken hybrids; it is to hash `m` in the ML-KEM component. Failure to hash `m` can contribute to compromising later values, including later X25519 keypairs, if the same long-running RNG state is used and no strong reseed or unknown additional input intervenes.

5. Hashing Dual_EC_DRBG output does not magically add entropy,
and may reduce it in some constructions. That is not the
point. The point is destroying hidden algebraic structure. We
should not shift the discussion from structure recovery to entropy accounting and then conclude that no mitigation is useful.

6. Yes, hashing DRBG output can be described as constructing DRBG'. That is fine. DRBG' should still be treated as suspect,
but it no longer preserves the Dual_EC_DRBG x- coordinate
structure needed by the published attacks. Unkeyed hashing
appears sufficient to block the known Dual_EC_DRBG recovery
attacks; a keyed hash may be useful for stronger designs, but
it is not needed to make this point.

My conclusion is simple: when history and user-centered harm reduction are the concern, the arguments favor hashing. We know this class of kleptographic attack is real. We know standards influence is part of the game. We should not leak raw pre-whitened system entropy to the network, and we should not hand raw RNG-derived `m` to a potentially adversarial decapsulator.

To restate the completely obvious: this isn't an accusation of
a backdoor in ML-KEM. It is a statement of fact that a defense- in-depth protection was knowingly removed by NIST. NIST did so over the objection of several people
participating in the NIST PQC process, and without analysis
that accounts for the extremely serious failures of NIST in
the very recent past with regard to Dual_EC_DRBG. The change
by NIST serves as an example where surprise: no one is
responsible for the user's security even though the difference
in exploitability for the Dual_EC_DRBG scenario is roughly a
single hash function call.

The IETF should give implementers clear guidance and it should
be in the draft's Security Consideration at the very least.
Hash `m`. Relatedly, do not write raw RNG output into protocol- visible fields when cheap whitening destroys known hidden structure.

Kind regards, Jacob Appelbaum

P.S.

Consider also the scale of the budgets for only a single agency [12]. It may also be worth your time looking at the cryptographic libraries worked on by former NSA people once they were officially out of government and firmly on the defending side of the fence. It is also informative for spotting the folks who have retained their first job while taking on another, another thing we learned about PROJECT BULLRUN. Remember: there is no need for accusations of a conspiracy as the business plan as the documented [12] attack budget appears to exceed the IETF's operating budget by a very
large margin. The larger issue isn't even really about the NSA
as the NSA's track record serves as a fairly clear example of
what to look for from many other large-scale adversaries.

[0] https://groups.google.com/a/list.nist.gov/g/pqc-forum/c/ WFRDl8DqYQ4/ m/o2XJ2YvfAwAJ

[1] https://groups.google.com/a/list.nist.gov/g/pqc-forum/c/ WFRDl8DqYQ4/ m/MRa5O0CvAAAJ

[2] https://rwc.iacr.org/2015/Slides/RWC-2015-Kelsey-final.pdf

[3] https://csrc.nist.gov/csrc/media/projects/crypto- standards- development-process/documents/ dualec_in_x982_and_sp800-90.pdf

[4] https://csrc.nist.gov/glossary/term/covert_channel

[5] https://rump2007.cr.yp.to/15-shumow.pdf

[6] https://eprint.iacr.org/2015/767

[7] https://www.usenix.org/system/files/conference/ usenixsecurity14/ sec14-paper-checkoway.pdf

[8] https://www.reuters.com/article/world/exclusive-secret- contract- tied-nsa-and-security-industry-pioneer- idUSBRE9BJ1C5/

[9] https://www.theguardian.com/world/2013/sep/05/nsa-gchq- encryption- codes-security

[10] https://datatracker.ietf.org/doc/html/rfc3935

[11] https://datatracker.ietf.org/doc/html/rfc7258

[12] https://archive.nytimes.com/www.nytimes.com/ interactive/2013/09/05/ us/documents-reveal-nsa-campaign- against- encryption.html




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