Software Security Req For UNII Devices

Federal Communications Commission
Office of Engineering and Technology

Laboratory Division
July 10, 2014
SOFTWARE SECURITY REQUIREMENTS FOR U-NII DEVICES
I. INTRODUCTION
On March 31, 2014, the Commission revised the rules in Part 15 that permits U-NII devices in the 5 GHz
Band. 1 As part of that revision, the Commission required that all U-NII device software be secured to
prevent its modification to ensure that the device operates as authorized thus reducing the potential for
harmful interference to authorized users. 2 Although, the Commission refused to set specific security
protocols, the methods used by manufacturers to implement the security requirements must be well
documented in the application for equipment authorization. In this document, we provide general
guidance on the type of information that should be submitted in the equipment authorization application.
The security description provided in the application must cover software security, configuration, and
authentication protocols descriptions, as appropriate. This guidance applies to master and client devices.
Special circumstances that apply only to client devices are also addressed.
II. SOFTWARE SECURITY DESCRIPTION GUIDE
An applicant must describe the overall security measures and systems that ensure that only:
1. Authenticated software is loaded and operating the device; and

2. The device is not easily modified to operate with RF parameters outside of the authorization.
The description of the software must address the following questions in the operational description for the
device and clearly demonstrate how the device meets the security requirements. 3 While the Commission
did not adopt any specific standards, it is suggested that the manufacturers may consider applying existing
industry standards. 4 Also, this guide is not intended to be exhaustive and may be modified in the future.
There may be follow-up questions based on the responses provide by the applicant for authorization.
SOFTWARE SECURITY DESCRIPTION

General Description 1. Describe how any software/firmware update will be obtained,
downloaded, and installed.
1
See Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-
NII) Devices in the 5 GHz Band, First Report and Order, ET Docket No. 13-49 (2014) (1st R&O).
2
For U-NII devices certified as SDR, see KDB Publication 442812 D01.
3
An exhibit that is part of the Operational Description can be subject to confidentiality. Applicants may request that
the software description, as part of the operational description exhibit type, be held confidential. If the software
description is submitted as the software information exhibit, it is automatically held confidential.
4
It is suggested that manufacturers follow existing security standards and definitions: X.800, RFC 2828, and IEEE
802.11i.
594280 D02 U-NII Device Security v01r01

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2. Describe all the radio frequency parameters that are modified by any
software/firmware without any hardware changes. Are these parameters
in some way limited, such that, it will not exceed the authorized
parameters?
3. Are there any authentication protocols in place to ensure that the source
of the software/firmware is legitimate? If so, describe in details; if not,
explain how the software is secured from modification.
4. Are there any verification protocols in place to ensure that the
software/firmware is legitimate? If so, describe in details.
5. Describe, if any, encryption methods used.
6. For a device that can be configured as a master and client (with active or
passive scanning), explain how the device ensures compliance for each
mode? In particular if the device acts as master in some band of
operation and client in another; how is compliance ensured in each band
of operation?
Third-Party Access Control 1. How are unauthorized software/firmware changes prevented?

2. Is it possible for third parties to load device drivers that could modify the
RF parameters, country of operation or other parameters which impact
device compliance? If so, describe procedures to ensure that only
approved drivers are loaded.
3. Explain if any third parties have the capability to operate a US sold device
on any other regulatory domain, frequencies, or in any manner that is in
violation of the certification.
4. What prevents third parties from loading non-US versions of the
software/firmware on the device?
5. For modular devices, describe how authentication is achieved when used
with different hosts.

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III. SOFTWARE CONFIGURATION DESCRIPTION GUIDE
In addition to the general security consideration, for devices which have “User Interfaces” (UI) to
configure the device in a manner that may impact the operational parameter, the following questions shall
be answered by the applicant and the information included in the operational description. The description
must address if the device supports any of the country code configurations or peer-peer mode
communications discussed in KDB 594280 Publication D01. 5
SOFTWARE CONFIGURATION DESCRIPTION

USER CONFIGURATION 1. To whom is the UI accessible? (Professional installer, end user, other.)
GUIDE a) What parameters are viewable to the professional installer/end-user? 6
b) What parameters are accessible or modifiable to the professional
installer?
i) Are the parameters in some way limited, so that the installers will
not enter parameters that exceed those authorized?
ii) What controls exist that the user cannot operate the device
outside its authorization in the U.S.?
c) What configuration options are available to the end-user?
i) Are the parameters in some way limited, so that the installers will
not enter parameters that exceed those authorized?
ii) What controls exist that the user cannot operate the device
outside its authorization in the U.S.?
d) Is the country code factory set? Can it be changed in the UI?
i) If so, what controls exist to ensure that the device can only operate
within its authorization in the U.S.?
e) What are the default parameters when the device is restarted?
2. Can the radio be configured in bridge or mesh mode? If yes, an attestation
may be required. Further information is available in KDB Publication 905462
D02.
3. For a device that can be configured as a master and client (with active or
passive scanning),if this is user configurable, describe what controls exist,
within the UI, to ensure compliance for each mode. If the device acts as a
master in some bands and client in others, how is this configured to ensure
compliance?
4. For a device that can be configured as different types of access points, such
as point-to-point or point-to-multipoint, and use different types of antennas,
describe what controls exist to ensure compliance with applicable limits and
the proper antenna is used for each mode of operation. (See Section
15.407(a))
5
See KDB Publication 594280 D01Software Configuration Control for Devices. The document provides guidance
for devices permitting device configurations and limitations on configuration parameters accessible to the third
parties.
6
The specific parameters of interest for this purpose are those that may impact the compliance of the device. These
typically include frequency of operation, power settings, antenna types, DFS settings, receiver thresholds, or country
code settings which indirectly programs the operational parameters.

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Change Notice
07/10/2014: 594280 D02 UNII Device Security v01 has been changed to 594280 D02 UNII Device
Security v01r01. Changes to items 3 and 4 in the Software Configuration Description table.

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Federal Communications Commission

Office of Engineering and Technology

July 10, 2014

SOFTWARE SECURITY REQUIREMENTS FOR U-NII DEVICES

II. SOFTWARE SECURITY DESCRIPTION GUIDE

1. Authenticated software is loaded and operating the device; and

SOFTWARE SECURITY DESCRIPTION

594280 D02 U-NII Device Security v01r01

Third-Party Access Control 1. How are unauthorized software/firmware changes prevented?

594280 D02 U-NII Device Security v01r01

SOFTWARE CONFIGURATION DESCRIPTION

594280 D02 U-NII Device Security v01r01

594280 D02 U-NII Device Security v01r01

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