Ensure that workloads with a regulatory or compliance requirement mandating the use of a dedicated hardware security module (HSM) use Azure Key Vault Managed HSM instead of the standard, multi-tenant Azure Key Vault. Azure Key Vault Managed HSM is a fully managed, highly available, single-tenant cloud service that safeguards cryptographic keys using FIPS 140-3 Level 3 validated HSMs (previously validated to FIPS 140-2 Level 3), giving your organization exclusive, customer-controlled ownership of the security domain, which acts as the root of trust for every HSM-protected key. Unlike Azure Key Vault Standard, which is FIPS 140-2 Level 1 validated and software-protected, or Azure Key Vault Premium, which is FIPS 140-3 Level 3 validated on current HSM Platform 2 (keys created on the older HSM Platform 1 remain FIPS 140-2 Level 2) but relies on Microsoft-owned, multi-tenant HSMs, Managed HSM stores only cryptographic keys (no secrets or certificates) in an isolated HSM pool that only your organization's designated administrators can access. This recommendation carries a manual assessment status because it applies only when an organization has a specific regulatory or contractual requirement for a dedicated HSM; a rule can verify whether a Managed HSM instance exists, but cannot by itself determine whether your organization is subject to such a requirement.
Managed HSM provides centralized key management, an isolated Managed HSM local role-based access control (RBAC) model, and support for private endpoints, and it integrates with services such as Azure SQL, Azure Storage, Azure Information Protection, and Customer Key for Microsoft 365. Because Microsoft cannot access, extract, or use the cryptographic keys stored in a Managed HSM instance, and because the security domain and root of trust remain entirely under your organization's control, using Managed HSM demonstrates the key sovereignty and single tenancy that many regulatory frameworks in banking, government, and other highly regulated industries require. Continuing to store HSM-backed keys in the standard, Microsoft-owned, multi-tenant Key Vault Premium tier when such a requirement applies leaves an organization unable to demonstrate that its cryptographic root of trust is isolated from other tenants, which can result in failed compliance audits and regulatory exposure.
Note: This is a manual CIS control. Use this rule's audit result, whether a Managed HSM instance exists, as one input to a compliance determination that only your organization can make. Do not treat the absence of a Managed HSM instance as non-compliant unless a documented regulatory or contractual requirement mandates dedicated HSM usage for the audited scope.
Managed HSM incurs a cost per month for each actively used HSM-protected key, which varies by key type and quantity, and each key version is billed separately. An hourly usage fee also applies per Managed HSM pool. Review the Key Vault pricing page to estimate costs before provisioning a Managed HSM instance.
Audit
To determine if an Azure Key Vault Managed HSM instance is provisioned within your Microsoft Azure account, perform the following operations:
Remediation / Resolution
To provision an Azure Key Vault Managed HSM instance for workloads that require a dedicated hardware security module, perform the following operations:
Provisioning a Managed HSM instance does not automatically migrate existing keys. After activation, you must import or create the HSM-protected keys that require dedicated HSM protection within the new Managed HSM instance, then update the applications and services that reference the original keys to use the new key URIs. Managed HSM instances remain billable throughout any soft-delete retention period, even after the resource group that contains them is deleted.References
- Azure Official Documentation
- Azure Key Vault Managed HSM Overview - Azure Key Vault Managed HSM | Microsoft Learn
- How to choose the right Azure key management solution - How to choose between Azure Key Vault, Azure Key Vault Managed HSM, Azure Cloud HSM, and Azure Payment HSM | Microsoft Learn
- Quickstart - Provision and activate an Azure Key Vault Managed HSM | Microsoft Learn
- Built-in policy definitions for Key Vault | Microsoft Learn
- Pricing - Key Vault | Microsoft Azure
- Azure Command Line Interface (CLI) Documentation
- az account | Microsoft Learn
- az account | Microsoft Learn
- az keyvault | Microsoft Learn
- az keyvault | Microsoft Learn
- az ad signed-in-user | Microsoft Learn
- az keyvault security-domain | Microsoft Learn
- CIS Security Documentation
- CIS Microsoft Azure Benchmarks