Extend usage timelines for FIPS 140-2 tokens for Digital Signature

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The Issue

As a tax professional and Business users , the imminent requirement to upgrade our digital security token hardware is causing unnecessary stress and potential financial burden. By September 21, 2026, the government mandates the usage of FIPS 140-3 Tokens, artificially shortening the lifespan of our FIPS 140-2 Tokens. This is particularly frustrating as there is no significant threat or vulnerability associated with continuing to use the current generation of tokens until the 2029 deadline set by the U.S. National Institute of Standards and Technology (NIST).

The current measures outlined in the CCA guidelines seem to favor token original equipment manufacturers (OEMs) and distributors, without any evident advantages for users. The guidelines do not include a buyback policy, leaving professionals in a lurch and resulting in additional costs for already compliant hardware.

Moreover, there has been an absence of communication from Certificate Authorities and Token OEMs about plans for the migration to FIPS 140-3. This lack of transparency only heightens our concern and complicates our planning. If tax professionals and DSC users are forced to discard their current hardware prematurely, it's not just an unnecessary expense but also an environmentally unsustainable practice.

Moreover, the Certificate Authorities , Resellers , OEM's  &  Distributors continued to sell their existing 140-2 tokens to the general public even as on today while leaving no room for the users , organizations and business partners to utilize any existing unused stock

We urge policymakers to reconsider the mandatory timelines imposed. By extending the deadline beyond September 21, 2026, to align with NIST's recommendations, professionals like us could continue operating efficiently and securely without needless expenditure. This extension would also allow time for OEMs to formulate and announce clear plans for transitioning to FIPS 140-3, including any necessary buying-back programs or incentives.

Help us advocate for a reasonable extension that ensures financial fairness and security for all users. Sign this petition and join us in requesting that both our hardware's usage and our industry's best interests are rightly acknowledged and protected."}

Honorable High Court of Delhi has already requsite directions to the Department to consider representations from the Industry. Any Impacted party can join the writ petition and also send their grevience to the below email ID : 

cca@cca.gov.in​ , secretary@meity.gov.in​ , moeit@gov.in​ , rahul@lexpractica.com

 

 

 

 

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Petition created on September 17, 2026