National Information Assurance Partnership
Common Criteria Evaluation and Validation Scheme
Validation Report
for the
NetApp Storage Encryption (NSE) Running ONTAP 9.16.1
Report Number: CCEVS-VR-VID11573-2026
Dated: February 26, 2026
Version: 1.0
National Institute of Standards and Technology Department of Defense
Information Technology Laboratory ATTN: NIAP, SUITE: 6982
100 Bureau Drive 9800 Savage Road
Gaithersburg, MD 20899 Fort Meade, MD 20755-6982
®
TM
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ACKNOWLEDGEMENTS
Validation Team
Jenn Dotson
Lisa Mitchell
Lori Sarem
The MITRE Corporation
Russ Fink
Johns Hopkins University Applied Physics Lab
Common Criteria Testing Laboratory
Nil Folquer
Kevin Steiner
Lightship Security USA, Inc.
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Table of Contents
1. Executive Summary.................................................................................................... 1
2. Identification............................................................................................................... 2
3. Architectural Information ........................................................................................... 4
3.1. TOE Evaluated Configuration ........................................................................ 4
3.2. Required Non-TOE Hardware, Software, and Firmware ............................... 4
3.3. Excluded Functionality................................................................................. 13
4. Security Policy.......................................................................................................... 15
4.1. Security Management ................................................................................... 15
4.2. Protection of the TSF.................................................................................... 15
4.3. Cryptographic Support.................................................................................. 15
5. Assumptions and Clarification of Scope................................................................... 16
5.1. Assumptions.................................................................................................. 16
5.2. Clarification of Scope ................................................................................... 16
6. Documentation.......................................................................................................... 17
7. IT Product Testing .................................................................................................... 18
7.1. Developer Testing......................................................................................... 18
7.2. Evaluation Team Independent Testing ......................................................... 18
7.3. TOE Test Environment Configuration.......................................................... 18
8. Results of the Evaluation .......................................................................................... 20
8.1. Evaluation of Security Target (ASE)............................................................ 20
8.2. Evaluation of Development Documentation (ADV) .................................... 20
8.3. Evaluation of Guidance Documents (AGD)................................................. 20
8.4. Evaluation of Life Cycle Support Activities (ALC)..................................... 21
8.5. Evaluation of Test Documentation and the Test Activity (ATE) ................. 21
8.6. Vulnerability Assessment Activity (VAN)................................................... 21
8.7. Summary of Evaluation Results.................................................................... 23
9. Validator Comments................................................................................................. 24
10. Annexes..................................................................................................................... 25
11. Security Target.......................................................................................................... 26
12. Glossary .................................................................................................................... 27
13. Acronym List ............................................................................................................ 28
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14. Bibliography ............................................................................................................. 29
List of Tables
Table 1: Evaluation Identifiers............................................................................................ 2
Table 2: Non-TOE Hardware (Broadwell) ......................................................................... 4
Table 3: Non-TOE Hardware (Skylake)............................................................................. 6
Table 4: Non-TOE Hardware (Cascade Lake).................................................................... 7
Table 5: Non-TOE Hardware (Ice Lake)............................................................................ 9
Table 6: Non-TOE Hardware (Sapphire Rapids).............................................................. 10
Table 7: Tools Used for Testing ....................................................................................... 19
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1. Executive Summary
This report documents the assessment of the National Information Assurance Partnership
(NIAP) Validation team of the evaluation of NetApp Storage Encryption (NSE) Running
ONTAP 9.16.1 provided by NetApp, Inc. It presents the evaluation results, their
justifications, and the conformance results. This Validation Report (VR) is not an
endorsement of the Target of Evaluation (TOE) by any agency of the U.S. government,
and no warranty is either expressed or implied.
The evaluation was performed by the Lightship Security USA Common Criteria
Laboratory (CCTL) in Baltimore, MD, United States of America, and was completed in
February 2026. The information in this report is largely derived from the Evaluation
Technical Report (ETR) and associated test reports, all written by Lightship Security (LS).
The evaluation determined that the product is both Common Criteria Part 2 Extended and
Part 3 Conformant and meets the assurance requirements of the collaborative Protection
Profile for Full Drive Encryption – Authorization Acquisition, Version 2.0 + Errata
20190201, February 1, 2019.
The TOE is NetApp Storage Encryption (NSE) Running ONTAP 9.16.1. The TOE
identified in this VR has been evaluated at a NIAP approved CCTL using the Common
Methodology for IT Security Evaluation (Version 3.1, Rev 5) for conformance to the
Common Criteria for IT Security Evaluation (Version 3.1, Rev 5). This VR applies only to
the specific version of the TOE as evaluated. The evaluation has been conducted in
accordance with the provisions of the NIAP Common Criteria Evaluation and Validation
Scheme (CCEVS) and the conclusions of the testing laboratory in the ETR are consistent
with the evidence provided.
The Validation team monitored the activities of the Evaluation team, provided guidance on
technical issues and evaluation processes, and reviewed the individual work units and
successive versions of the ETR. The Validation team found that the evaluation showed that
the product satisfies all of the functional requirements and assurance requirements stated
in the Security Target (ST). Therefore, the Validation team concludes that the testing
laboratory’s findings are accurate, the conclusions justified, and the conformance results
are correct. The conclusions of the testing laboratory in the ETR are consistent with the
evidence produced.
The technical information included in this report was obtained from the NetApp Storage
Encryption (NSE) Running ONTAP 9.16.1 Security Target, Version 1.8, February 25, 2026,
and analysis performed by the Validation team.
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2. Identification
The CCEVS is a joint National Security Agency (NSA) and National Institute of Standards
and Technology (NIST) effort to establish commercial facilities to perform trusted product
evaluations. Under this program, security evaluations are conducted by commercial testing
laboratories called Common Criteria Testing Laboratories (CCTLs) using the Common
Evaluation Methodology (CEM) in accordance with National Voluntary Laboratory
Assessment Program (NVLAP) accreditation.
The NIAP Validation Body assigns Validators to monitor the CCTLs to ensure quality and
consistency across evaluations. Developers of information technology products desiring a
security evaluation contract with a CCTL and pay a fee for their product’s evaluation.
Upon successful completion of the evaluation, the product is added to NIAP’s Validated
Products List.
Table 1 provides information needed to completely identify the product, including:
• The TOE: the fully qualified identifier of the product as evaluated.
• The ST, describing the security features, claims, and assurances of the product.
• The conformance result of the evaluation.
• The Protection Profile (PP) to which the product is conformant.
• The organizations and individuals participating in the evaluation.
Table 1: Evaluation Identifiers
Item Identifier
Evaluation Scheme
United States NIAP Common Criteria Evaluation and Validation
Scheme
Evaluated Product NetApp Storage Encryption (NSE) Running ONTAP 9.16.1
Sponsor and Developer
NetApp, Inc.
3060 Olsen Drive
San Jose, CA 95128
CCTL
Lightship Security USA, Inc.
3600 O’Donnell St., Suite 2
Baltimore, MD 21224
CC Version
Common Criteria for Information Technology Security
Evaluation, Version 3.1, Revision 5, April 2017.
CEM
Common Methodology for Information Technology Security
Evaluation: Evaluation Methodology, Version 3.1, Revision 5,
April 2017.
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Item Identifier
Protection Profile
collaborative Protection Profile for Full Drive Encryption –
Authorization Acquisition, Version 2.0 + Errata 20190201,
February 1, 2019
ST
NetApp Storage Encryption (NSE) Running ONTAP 9.16.1
Security Target, Version 1.8, February 25, 2026
Evaluation Technical
Report
NetApp Storage Encryption (NSE) Running ONTAP 9.16.1
Evaluation Technical Report, Version 1.4, February 2026
Conformance Result CC Part 2 extended, CC Part 3 conformant
Evaluation Personnel Nil Folquer and Kevin Steiner
CCEVS Validators Jenn Dotson, Lisa Mitchell, Lori Sarem, and Russ Fink
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3. Architectural Information
Note: The following architectural description is based on the description presented in the
Security Target.
The TOE is NetApp Storage Encryption (NSE) running ONTAP 9.16.1, an authorization
acquisition product that obtains and manages authorization data used to access encrypted
data stored on a full disk encryption product. The TOE provides the management and
protection of keys that are used to protect the data encryption keys used by third-party self-
encrypting drives (SEDs). The TOE supports FIPS validated third party SEDs that follow
either the Trusted Computing Group’s (TCG) Opal or Enterprise standards.
3.1. TOE Evaluated Configuration
The TOE is NetApp Storage Encryption (NSE) running ONTAP 9.16.1, an authorization
acquisition product that obtains and manages authorization data used to access encrypted
data stored on a FIPS validated full disk encryption product. The TOE provides
authorization data to FIPS validated third party self-encrypting drives (SEDs).
3.2. Required Non-TOE Hardware, Software, and Firmware
The TOE operates with the following components in the environment:
a) External clients sending NFS (UNIX) and/or SMB/CIFS (Windows) data that
interact with a protocol handler.
b) Physical drives
The non-TOE hardware required by and provisioned with the TOE are identified in the
tables below:
Table 2: Non-TOE Hardware (Broadwell)
Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
Intel Broadwell Xeon D Processor
AFF
A150A150
SSD NAS/SAN 72
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz
AFF A220 SSD NAS/SAN 144
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
AFF A300 SSD NAS/SAN 384 3U Intel Xeon D-1587
(Broadwell)
2 x 64-bit 16-core
1.70 GHz
AFF C190 SSD NAS/SAN 24
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 8-core
1.50 GHz
ASA A150 SSD SAN 72
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz
ASA AFF A220 SSD SAN 144
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz
FAS2720 HDD/SSD NAS/SAN 144/136
12 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz
FAS2750 HDD/SSD NAS/SAN 144/144
24 internal
drives
2U Intel Xeon D-1557
(Broadwell)
2 x 64-bit 12-core
1.50 GHz)
FAS8200 HDD/SSD NAS/SAN 480/480 3U Intel Xeon D-1587
(Broadwell)
2 x 64-bit 16-core
1.70 GHz
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Table 3: Non-TOE Hardware (Skylake)
Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form Factor
Storage Controller
Processor
Intel Skylake Xeon Scalable Processors
AFF A320 NVMe NAS/SAN 96 2U Intel Xeon Silver
4114 (Skylake-SP)
4 x 64-bit 10-core
2.20 GHz
AFF A8001
NVMe/SSD NAS/SAN 240/240
48 internal
drives
4U Intel Xeon
Platinum 8160
(Skylake-SP)
4 x 64-bit 24-core
2.10 GHz
ASA A8002
NVMe/SSD SAN 240/240
48 internal
drives
4U Intel Xeon
Platinum 8160
(Skylake-SP)
4 x 64-bit 24-core
2.10 GHz
Intel Skylake Xeon D Processor
AFF A250 NVMe/SSD NAS/SAN 48/24
24 internal
drives
2U Intel Xeon D-2164-
IT (Skylake-D)
2 x 64-bit 12 core,
2.10 GHz
AFF C250 NVMe NAS/SAN 48
24 internal
drives
2U Intel Xeon D-2164-
IT (Skylake-D)
2 x 64-bit 12 core,
2.10 GHz
1
AFF A800 models first shipped with the Intel Xeon Platinum 8160, later models shipped with
the Intel Xeon Gold 5220R after the Platinum 8160 was discontinued.
2
ASA A800 models first shipped with the Intel Xeon Platinum 8160, later models shipped with
the Intel Xeon Gold 5220R after the Platinum 8160 was discontinued.
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form Factor
Storage Controller
Processor
ASA A250 NVMe SAN 48
24 internal
drives
2U Intel Xeon D-2164-
IT (Skylake-D)
2 x 64-bit 12 core,
2.10 GHz
ASA C250 NVMe SAN 48
24 internal
drives
2U Intel Xeon D-2164-
IT (Skylake-D)
2 x 64-bit 12 core,
2.10 GHz
FAS500f NVMe NAS/SAN 48
24 internal
drives
2U Intel Xeon D-2164-
IT (Skylake-D)
2 x 64-bit 12 core,
2.10 GHz
Table 4: Non-TOE Hardware (Cascade Lake)
Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
Intel Cascade Lake 2nd
Gen Xeon Scalable Processors
AFF A400 NVMe/SSD NAS/SAN 96/480 4U Intel Xeon Silver
4210 (Cascade
Lake)
4 x 64-bit 10-core,
2.20 GHz
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
AFF A8003
NVMe/SSD NAS/SAN 240/240
48 internal
drives
4U Intel Xeon Gold
5220R (Cascade
Lake)
4 x 64-bit 24-core,
2.10 GHz
AFF C400 NVMe NAS/SAN 96 4U Intel Xeon Silver
4210 (Cascade
Lake)
4 x 64-bit 10-core,
2.20 GHz
AFF C800 NVMe NAS/SAN 240
48 internal
drives
4U Intel Xeon Gold
5220R (Cascade
Lake)
4 x 64-bit 24-core,
2.10 GHz
ASA A400 NVMe/SSD SAN 96/480 4U Intel Xeon Silver
4210 (Cascade
Lake)
4 x 64-bit 10-core,
2.20 GHz
ASA C400 NVMe SAN 96 4U Intel Xeon Silver
4210 (Cascade
Lake)
4 x 64-bit 10-core,
2.20 GHz
3
AFF A800 models first shipped with the Intel Xeon Platinum 8160, later models shipped with
the Intel Xeon Gold 5220R after the Platinum 8160 was discontinued.
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
ASA A8004 NVMe/SSD SAN 240/240
48 internal
drives
4U Intel Xeon Gold
5220R (Cascade
Lake)
4 x 64-bit 24-core,
2.10 GHz
ASA C800 NVMe SAN 240
48 internal
drives
4U Intel Xeon Gold
5220R (Cascade
Lake)
4 x 64-bit 24-core,
2.10 GHz
FAS8300 HDD/SSD NAS/SAN 720/480 4U Intel Xeon Silver
4210 (Cascade
Lake)
4 x 64-bit 10-core,
2.20 GHz
FAS8700 HDD/SSD NAS/SAN 1440/480 4U Intel Xeon Gold
5218 (Cascade
Lake)
4 x 64-bit 16-core,
2.30 GHz
Table 5: Non-TOE Hardware (Ice Lake)
Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
Intel Ice Lake 3rd
Gen Xeon Scalable Processors
4
ASA A800 models first shipped with the Intel Xeon Platinum 8160, later models shipped with
the Intel Xeon Gold 5220R after the Platinum 8160 was discontinued.
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage
Protocols
Max Drives Controller
Form Factor
Storage Controller
Processor
AFF A900 NVMe/SSD NAS/SAN 240/480 8U Intel Xeon Platinum
8352Y (Ice Lake)
4 x 64-bit 32-core
2.20 GHz
ASA A900 NVMe/SSD SAN 240/480 8U Intel Xeon Platinum
8352Y (Ice Lake)
4 x 64-bit 32-core
2.20 GHz
FAS9500 HDD/SSD NAS/SAN 1440/480 8U Intel Xeon Platinum
8352Y (Ice Lake)
4 x 64-bit 32-core,
2.20 GHz
Intel Ice Lake Xeon D Processor
FAS2820 HDD/SSD NAS/SAN 144/138
12 internal
drives
2U Intel Xeon D-
1735TR (Ice Lake-D)
2 x 64-bit 8-core
2.20 GHz
Table 6: Non-TOE Hardware (Sapphire Rapids)
Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form
Factor
Storage
Controller
Processor
Intel Sapphire Rapids 4th
Gen Xeon Scalable Processors
AFF A1K NVMe/SSD NAS/SAN 240/480 4U Intel Xeon
Platinum
8470N
2 x 64-bit 52-
core 1.7 GHz
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form
Factor
Storage
Controller
Processor
AFF A30 NVMe/SSD NAS/SAN 72/120
24 internal
drives
2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
AFF C30 NVMe NAS/SAN 72
24 internal
drives
2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
AFF A50 NVMe/SSD NAS/SAN 120/120
24 internal
drives
2U Intel Xeon
Gold 5411N
2 x 64-bit 24-
core 1.9 GHz
AFF C60 NVMe NAS/SAN 120
24 internal
drives
2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
AFF A70 NVMe/SSD NAS/SAN 240/240
48 internal
drives
4U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
AFF C80 NVMe NAS/SAN 240
48 internal
drives
4U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
AFF A90 NVMe/SSD NAS/SAN 240/240
48 internal
drives
4U Intel Xeon
Gold 6438N
2 x 64-bit 32-
core 2.0 GHz
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form
Factor
Storage
Controller
Processor
ASA A1K NVMe SAN 240 4U Intel Xeon
Platinum
8470N
2 x 64-bit 52-
core 1.7 GHz
ASA A30 NVMe SAN 72
24 internal
drives
2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
ASA C30 NVMe SAN 72
24 internal
drives
2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
ASA A50 NVMe SAN 120
24 internal
drives
2U Intel Xeon
Gold 5411N
2 x 64-bit 24-
core 1.9 GHz
ASA A70 NVMe SAN 240
48 internal
drives
4U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
ASA A90 NVMe SAN 240
48 internal
drives
4U Intel Xeon
Gold 6438N
2 x 64-bit 32-
core 2.0 GHz
FAS50 HDD/SSD NAS/SAN 480/120 2U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
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Values identified, including the CPU count, are for a single HA pair specification.
All disk drives are third party devices.
Storage
Controller
Disk Type Storage Protocols Max Drives Controller
Form
Factor
Storage
Controller
Processor
FAS70 HDD/SSD NAS/SAN 1440/240 4U Intel Xeon
Gold 5416S
2 x 64-bit 16-
core 2.0 GHz
FAS90 HDD/SSD NAS/SAN 1440/480 4U Intel Xeon
Gold 6438N
2 x 64-bit 32-
core 2.0 GHz
Intel Sapphire Rapids 5th
Gen Xeon Scalable Processors
AFF A20 NVMe/SSD NAS/SAN 48/120
24 internal
drives
2U Intel Xeon
Bronze
3508U
2 x 64-bit 8-
core 2.0 GHz
ASA A20 NVMe SAN 48
24 internal
drives
2U Intel Xeon
Bronze
3508U
2 x 64-bit 8-
core 2.0 GHz
3.3. Excluded Functionality
The list below identifies features or protocols that are not evaluated or must be disabled,
and the rationale why. Note that this does not mean the features cannot be used in the
evaluated configuration (unless explicitly stated so). It means that the features were not
evaluated and/or validated by an independent third party and the functional correctness of
the implementation is vendor assertion. Evaluated functionality is scoped exclusively to
the security functional requirements specified in the ST. The features below are out of
scope.
Feature Description
Networking protocols Security functional requirements associated with networking
protocols (NFS, SMB, etc.) are not evaluated and/or validated in the
evaluated configuration.
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Feature Description
High Availability Security functional requirements associated with High Availability
features provided by the TOE are not evaluated and/or validated in
the evaluated configuration.
KMIP KMIP client configurations provided by the TOE are not evaluated
and/or validated in the evaluated configuration.
SnapLock NetApp SnapLock is the WORM (write once, read many)
compliance replication solution from NetApp. It provides integrated
data protection for workloads that need to adhere to regulatory
guidelines such as HIPAA, SEC 17a-4(f) rule, FINRA, and CFTC
as well as national requirements for German-speaking countries
(DACH).
SnapLock was not included in the evaluation and was not tested in
the evaluated configuration.
Trusted Platform Module (TPM) The encryption keys for the onboard key manager (OKM) are not
sealed by a physical TPM when running in Common Criteria mode.
MetroCluster NetApp MetroCluster (MC) software is a solution that combines
array-based clustering with synchronous replication to deliver
continuous availability and zero data loss at the lowest cost.
MetroCluster was not included in the evaluation and was not tested
in the evaluated configuration.
System Manager GUI The System Manager GUI is considered out of scope and all
management is performed via the command line interface.
Note: CLI management access excludes SSH access and is limited
to serial console access only.
VMware Virtualization VMware Virtualization was not included in the evaluation and was
not tested in the evaluated configuration.
Cloud environments ONTAP instances running within a cloud environment were not
included in the evaluation and were not tested in the evaluated
configuration.
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4. Security Policy
This section summarizes the security functionality of the TOE:
4.1. Security Management
The TOE supports management functions for forwarding requests to change the DEK to
the EE, forwarding requests to cryptographically erase the DEK to the EE, allowing
authorized users to change authorization factors or set of authorization factors used, and
initiating TOE software updates using a command line interface.
4.2. Protection of the TSF
The TOE provides trusted firmware updates, protects Key and Key Material; and supports
power saving states. The TOE runs a suite of self-tests during initial start-up (on power
on).
4.3. Cryptographic Support
The TOE includes NIST CAVP-validated cryptographic algorithms supporting
cryptographic functions. The TOE provides Key Wrapping, Key Derivation, and BEV
Validation.
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5. Assumptions and Clarification of Scope
5.1. Assumptions
The Security Problem Definition, including the assumptions, can be found in the following
document:
• collaborative Protection Profile for Full Drive Encryption – Authorization
Acquisition, Version 2.0 + Errata 20190201, February 1, 2019
That information has not been reproduced here and CPP_FDE_AA_V2.0E should be
consulted if there is interest in that material.
5.2. Clarification of Scope
The scope of this evaluation was limited to the functionality and assurances covered in
CPP_FDE_AA_V2.0E as described for this TOE in the ST. Other functionality provided
by the devices was not assessed as part of this evaluation. All other functionality needs to
be assessed separately, and no further conclusions can be drawn about their effectiveness.
All evaluations (and all products) have limitations, as well as potential misconceptions that
need clarification. This text covers some of the more important limitations and
clarifications of this evaluation. Note that:
• As with any evaluation, this evaluation only shows that the evaluated configuration
meets the security claims made in accordance with the assurance activities specified
in the CPP_FDE_EE_V2.0E and performed by the Evaluation team.
• This evaluation covers only the specific software version identified in this
document, and not any earlier or later versions released or in process.
• Apart from the Admin Guides identified in Section 6, additional customer
documentation for the specific models was not included in the scope of the
evaluation and therefore should not be relied upon when configuring or operating
the device as evaluated.
• This evaluation did not specifically search for, nor attempt to exploit, vulnerabilities
that were not “obvious” or vulnerabilities to objectives not claimed in the ST. The
CEM defines an “obvious” vulnerability as one that is easily exploited with a
minimum of understanding of the TOE, technical sophistication, and resources.
• The functionality evaluated is scoped exclusively to the security functional
requirements specified in the CPP_FDE_AA_V2.0E and applicable Technical
Decisions. Any additional security related functional capabilities of the TOE were
not covered by this evaluation. In particular, functionality defined in Section 3.3 is
not covered by this evaluation.
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6. Documentation
The following guidance documents are provided with the TOE upon delivery in accordance
with the PP:
• NetApp Storage Encryption: Common Criteria Configuration Guide, Version 1.6,
February 25, 2026
• Set up, upgrade and revert ONTAP- ONTAP 9, March 21, 2025
• ONTAP 9.16.1 commands, January 31, 2025
These documents are the only documentation that should be trusted to set-up, administer,
or use the product in the evaluated configuration. Additional documentation was not
included in the scope of the evaluation and should not be relied upon when configuring or
operating the device as evaluated.
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7. IT Product Testing
This section describes the testing efforts of the Evaluation team. It is derived from
information contained in the NetApp Storage Encryption (NSE) running ONTAP 9.16.1
FDE Authorization Acquisition Test Plan, Version 1.2, February 2026, which is not
publicly available. The NetApp Storage Encryption (NSE) Running ONTAP 9.16.1
Assurance Activity Report, Version 1.4, February 2026, provides an overview of testing
and the prescribed evaluation activities.
7.1. Developer Testing
No evidence of developer testing is required in the SARs or Evaluation Activities.
7.2. Evaluation Team Independent Testing
Testing was performed by Nil Folquer from June 2025 through November 2025.
Testing of the models AFF A250 and FAS2820 was performed remotely in the Lightship
Baltimore facility that has been accredited by NVLAP. Remote testing was approved by
NIAP according to NIAP Policy #31. The remote equipment (TOEs and TOE setup) was
in NetApp’s isolated lab in a dedicated rack connected to an isolated subnet only accessible
to the evaluator and 3 authorized NetApp personnel.
The Evaluation team configured the TOE according to vendor installation instructions and
as identified in the Security Target.
The Evaluation team confirmed the technical accuracy of the setup and installation guide
during installation of the TOE. The Evaluation team confirmed that the TOE version
delivered for testing was identical to the version identified in the ST.
The Evaluation team used the Protection Profile test procedures as a basis for creating each
of the independent tests as required by the Evaluation Activities.
Each Evaluation Activity was tested as required by the conformant Protection Profile and
the Evaluation team verified that each test passed.
7.3. TOE Test Environment Configuration
The TOE testing environment components are identified in Figure 1 and Table 7 below.
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Figure 1: Testing Environment Overview
Table 7: Tools Used for Testing
Tool Name Version Description
NetApp ONTAP
9.16.1 (debug version)
9.16.1 <1d> Instrumented TOE build to allow the
evaluator to capture key values and dump
the core of the TOE to verify key
destruction. This tool was used for
FCS_CKM.4(d) testing only.
bm-search 1.0 Proprietary tool used to search for patterns
in memory dumps such as keys and
random bytes.
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8. Results of the Evaluation
The results of the assurance requirements are generally described in this section and are
presented in detail in the proprietary documents: the Detailed Test Report (DTR) and the
Evaluation Technical Report (ETR). The reader of this document can assume that all
activities and work units received a passing verdict.
A verdict for an assurance component is determined by the resulting verdicts assigned to
the corresponding evaluator action elements. The evaluation was conducted based upon
CC Version 3.1 Revision 5 and CEM Version 3.1 Revision 5. The evaluation determined
NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 to be Part 2 extended, and
meets the SARs contained in the PP. Additionally, the evaluator performed the Evaluation
Activities specified in CPP_FDE_AA_V2.0E and its supporting document.
8.1. Evaluation of Security Target (ASE)
The Evaluation team applied each ASE CEM work unit. The ST evaluation ensured the ST
contains a description of the environment in terms of policies and assumptions, a statement
of security requirements claimed to be met by the NetApp Storage Encryption (NSE)
Running ONTAP 9.16.1 that are consistent with the Common Criteria, and product security
function descriptions that support the requirements.
The Validation team reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
8.2. Evaluation of Development Documentation (ADV)
The Evaluation team applied each ADV CEM work unit. The Evaluation team assessed the
design documentation and found it adequate to aid in understanding how the TSF provides
the security functions. The design documentation consists of a functional specification
contained in the ST and Guidance documents. Additionally, the evaluator performed the
assurance activities specified in the CPP_FDE_AA_V2.0E related to the examination of
the information contained in the TOE Summary Specification (TSS).
The Validation reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
8.3. Evaluation of Guidance Documents (AGD)
The Evaluation team applied each AGD CEM work unit. The Evaluation team ensured the
adequacy of the user guidance in describing how to use the operational TOE. Additionally,
the Evaluation team ensured the adequacy of the administrator guidance in describing how
to securely administer the TOE. All of the guides were assessed during the design and
testing phases of the evaluation to ensure they were complete.
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The Validation team reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
8.4. Evaluation of Life Cycle Support Activities (ALC)
The Evaluation team applied each ALC CEM work unit. The Evaluation team found that
the TOE was appropriately labeled with a unique identifier consistent with the TOE
identification in the evaluation evidence and that the TOE references used are consistent.
The Validation team reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
8.5. Evaluation of Test Documentation and the Test Activity (ATE)
The Evaluation team applied each ATE CEM work unit. The Evaluation team ran the set
of tests specified by the assurance activities in the CPP_FDE_AA_V2.0E and recorded
the results in the DTR, summarized in the AAR.
The Validation team reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
8.6. Vulnerability Assessment Activity (VAN)
The Evaluation team applied each AVA CEM work unit. The vulnerability analysis is in
the NetApp NSE ONTAP v9.16 Vulnerability Assessment, report prepared by the Evaluation
team. The vulnerability analysis includes a public search for vulnerabilities. The public
search for vulnerabilities, last conducted on February 23, 2026, did not uncover any
residual vulnerability.
The Evaluation team searched:
• NIST National Vulnerabilities Database: https://web.nvd.nist.gov/view/vuln/search
• MITRE CVE List: https://cve.mitre.org/cve/search_cve_list.html
• CVE Details: https://www.cvedetails.com/vulnerability-search.php
• CISA - Known Exploited Vulnerabilities Catalog: https://www.cisa.gov/known-
exploited-vulnerabilities-catalog
• NetApp Security Advisories: https://security.netapp.com/advisory
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The Evaluation team performed a search using the following keywords:
NetApp ONTAP 9 NetApp Storage Encryption
AFF A150 AFF A1K AFF A20 AFF A50 AFF A30
AFF A70 AFF C250 AFF A90 AFF C60 AFF C400
AFF C800 AFF C30 AFF C80 ASA A20 ASA A90
ASA A400 ASA A70 ASA A900 ASA A800 ASA A30
ASA C30 ASA A250 ASA A50 ASA A150 ASA A1K
ASA C400 ASA C250 ASA AFF A220 ASA C800 FAS50
FAS70 FAS90 AFF A800 AFF A220 AFF C190
AFF A250 AFF A300 AFF A400 AFF A900 AFF A320
FAS2720 FAS2820 FAS9500 FAS2750 FAS8700
FAS8200 FAS500f FAS8300
Intel Xeon D-2164IT Intel Xeon Bronze 3508U Intel Xeon D-1557
Intel Xeon Silver 4114 Intel Xeon Platinum 8160 Intel Xeon Silver 4210
Intel Xeon Gold 5218 Intel Xeon Gold 5220R Intel Xeon D-1735TR
Intel Xeon Gold 5416S Intel Xeon Platinum 8352Y Intel Xeon Gold 5411N
Intel Xeon Gold 6438N Intel Xeon Platinum 8470N Intel Xeon D-1587
NetApp CryptoMod NetApp Cryptographic Security Module
Intel Intelligent Storage Acceleration Library OpenSSL 3.0.8
Drive Encryption Disk Encryption Key destruction
Key sanitization Opal management software
SED management software Password caching Key caching
The Validation team reviewed the work of the Evaluation team and found that sufficient
evidence and justification was provided by the Evaluation team to confirm that the
evaluation was conducted in accordance with the requirements of the CEM, and that the
conclusion reached by the Evaluation team was justified.
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8.7. Summary of Evaluation Results
The Evaluation team's assessment of the evaluation evidence demonstrates that the claims
in the ST are met. Additionally, the Evaluation team's test activities also demonstrated the
accuracy of the claims in the ST.
The Validation team's assessment of the evidence provided by the Evaluation team is that
it demonstrates that the Evaluation team followed the procedures defined in the CEM and
performed the Assurance Activities in CPP_FDE_AA_V2.0E and its supporting document
and correctly verified that the product meets the claims in the ST.
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9. Validator Comments
The Validation team notes that the evaluated configuration is dependent upon the TOE
being configured per the configuration instructions in the Guidance documents defined in
Section 6. No other versions of the TOE software, either earlier or later, were evaluated.
The Validation team suggests that the consumer pay particular attention to the evaluated
configuration of the TOE. As stated in the Clarification of Scope, the evaluated
functionality is scoped exclusively to the security functional requirements specified in the
ST and only that functionality was evaluated. All other functionality provided by the TOE
needs to be assessed separately and no further conclusions can be drawn about its
effectiveness.
The Validation team strongly recommends that all TOE hardware in the operational
environment is kept up to date with patches as they are released. In addition, Per
NIAP/CCEVS Publication #6, user installation of vendor-delivered bug fixes and security
patches is encouraged between completion of the evaluation and the Assurance
Maintenance Date; with such updates properly installed, the product is still considered by
NIAP to be in its evaluated configuration.
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10. Annexes
Not applicable.
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11. Security Target
NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 Security Target, Version 1.8,
February 25, 2026
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12. GLOSSARY
• Common Criteria Testing Laboratory (CCTL): An IT security evaluation
facility accredited by the National Voluntary Laboratory Accreditation Program
(NVLAP) and approved by the CCEVS Validation Body to conduct Common
Criteria-based evaluations.
• Conformance: The ability to demonstrate in an unambiguous way that a given
implementation is correct with respect to the formal model.
• Evaluation: The assessment of an IT product against the Common Criteria using
the Common Criteria Evaluation Methodology to determine whether or not the
claims made are justified; or the assessment of a protection profile against the
Common Criteria using the Common Evaluation Methodology to determine if the
Profile is complete, consistent, technically sound and hence suitable for use as a
statement of requirements for one or more TOEs that may be evaluated.
• Evaluation Evidence: Any tangible resource (information) required from the
sponsor or developer by the evaluator to perform one or more evaluation activities.
• Feature: Part of a product that is either included with the product or can be ordered
separately.
• Target of Evaluation (TOE): A group of IT products configured as an IT system,
or an IT product, and associated documentation that is the subject of a security
evaluation under the CC.
• Threat: Means through which the ability or intent of a threat agent to adversely
affect the primary functionality of the TOE, facility that contains the TOE, or
malicious operation directed towards the TOE. A potential violation of security.
• Validation: The process carried out by the CCEVS Validation Body leading to the
issue of a Common Criteria certificate.
• Validation Body: A governmental organization responsible for carrying out
validation and for overseeing the day-to-day operation of the NIAP Common
Criteria Evaluation and Validation Scheme.
• Vulnerabilities: A vulnerability is a hardware, firmware, or software flaw that
leaves an Automated Information System (AIS) open for potential exploitation. A
weakness in automated system security procedures, administrative controls,
physical layout, internal controls, and so forth, which could be exploited by a threat
to gain unauthorized access to information or disrupt critical processing.
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13. Acronym List
CAVP Cryptographic Algorithm Validation Program (CAVP)
CCEVS Common Criteria Evaluation and Validation Scheme
CCIMB Common Criteria Interpretations Management Board
CCTL Common Criteria Testing Laboratories
CEM Common Evaluation Methodology for IT Security Evaluation
LS Lightship Security USA CCTL
ETR Evaluation Technical Report
IT Information Technology
NIAP National Information Assurance Partnership
NIST National Institute of Standards and Technology
NSA National Security Agency
NVLAP National Voluntary Laboratory Assessment Program
OSP Organizational Security Policies
PCL Products Compliant List
ST Security Target
TOE Target of Evaluation
VR Validation Report
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14. Bibliography
1. Common Criteria for Information Technology Security Evaluation, Part 1:
Introduction and General Model, CCMB-2017-04-001, Version 3.1 Revision 5,
April 2017
2. Common Criteria for Information Technology Security Evaluation, Part 2:
Security functional requirements, CCMB-2017-04-002, Version 3.1 Revision 5,
April 2017
3. Common Criteria for Information Technology Security Evaluation, Part 3:
Security assurance requirements, CCMB-2017-04-003, Version 3.1 Revision 5,
April 2017
4. Common Methodology for Information Technology Security Evaluation,
Evaluation Methodology, CCMB-2017-04-004, Version 3.1, Revision 5, April
2017
5. collaborative Protection Profile for Full Drive Encryption – Authorization
Acquisition, Version 2.0 + Errata 20190201, February 2019
6. Supporting Document - Mandatory Technical Document Full Drive Encryption:
Authorization Acquisition, Version 2.0 + Errata 20190201, February 2019
7. NetApp Storage Encryption: Common Criteria Configuration Guide, Version
1.6, February 25, 2025
8. Set up, upgrade and revert ONTAP- ONTAP 9, March 21, 2025
9. ONTAP 9.16.1 commands, January 31, 2025
10. NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 Security Target,
Version 1.8, February 25, 2026
11. NetApp ONTAP 9.16.1 with NetApp Storage Encryption and Onboard Key
Manager Common Criteria Full Drive Encryption – Authorization Acquisition
Key Management Description, Version 1.1, June 2, 2025
12. NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 Assurance Activity
Report, Version 1.4, February 2026
13. NetApp NSE ONTAP 9.16 Vulnerability Assessment, Version 1.4, February
2026
14. NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 Evaluation
Technical Report, Version 1.4, February 2026
15. NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 cPP FDE AA 2.0E
Test Plan, Version 1.2, February 2026
16. NetApp Storage Encryption (NSE) Running ONTAP 9.16.1 cPP FDE AA 2.0E
Test Evidence, Version 1.1, February 2026