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Encryption RFP Template and Checklist (2026): Customer-Controlled Keys for Cloud, SaaS and Databases

Encryption RFP template and data encryption RFP checklist for customer-controlled keys: requirements, scoring model, vendor questions, PoC tests, exit clauses.

DuoKey Team··24 min read

This encryption RFP template and data encryption RFP checklist gives you a vendor-neutral set of requirements for protecting data at rest in cloud, SaaS and database platforms with keys that you control. It covers eleven requirement groups (scope, encryption models, key control and sovereignty, platform integrations, availability, cryptography, access policies, audit, regulatory mapping, deployment and exit, vendor and support), a weighted scoring model, 20 vendor questions, red flags, a proof-of-concept plan and contract clauses. Every table can be copied into a spreadsheet.


Table of Contents

  1. Who this is for and how to use it
  2. Before you write the RFP
  3. The requirements checklist
  4. Weighted scoring model
  5. 20 vendor questions to ask in the response
  6. Red flags in vendor answers
  7. Proof-of-concept plan with pass/fail tests
  8. Contract and exit clauses
  9. Copy-ready RFP introduction
  10. FAQ
  11. Conclusion
  12. References

Who this is for and how to use it

This template is for security architects, CISOs, data protection officers, procurement and cloud platform owners who must buy, or re-tender, an enterprise data encryption solution in which the customer, not the cloud or SaaS provider, controls the keys. It applies whether you call the result BYOK, HYOK, external key management (EKM), double key encryption (DKE), client-side encryption, tokenization or field-level encryption.

How to use it:

  1. Copy the introduction at the end into your RFP and adapt the scope.
  2. Paste the requirement tables into a spreadsheet. Keep the ID column: it lets you score vendors and trace evidence later.
  3. Delete requirements that do not apply (for example, the Salesforce rows if you do not use Salesforce) and re-weight the scoring model.
  4. Ask for evidence, not assertions. Each row names the evidence to request.

Priorities are Must (disqualifying if absent), Should (scored, a gap is acceptable with a plan) and Advanced (differentiating capabilities that a serious product may offer but that you should not make mandatory unless your risk model needs them).

This page is a procurement aid, not legal advice. Check regulatory wording with your counsel.


Before you write the RFP

Most failed encryption projects fail before the RFP, on scope. Settle these five things first.

1. Inventory and classify the data. List the platforms that hold regulated or confidential data: Microsoft 365 (Exchange, SharePoint, OneDrive, Teams), Salesforce, ServiceNow, AWS storage and databases, Azure, SQL Server, Oracle, Snowflake, Databricks, and AI services such as OpenAI. Attach a classification (public, internal, confidential, regulated) to each and note data volumes and residency constraints.

2. Pick the threat you are buying protection against. Different models answer different questions:

Threat or goalWhat it needs
Cloud provider staff or a breach at the provider reading your dataCustomer-held keys the provider cannot use without your key service
A foreign legal request addressed to the providerKeys held under your jurisdiction and a provider that cannot decrypt alone
Regulator or auditor asking who can decryptKey-use audit trail you control
Insider or compromised admin account in your own tenantAccess policies on key use, separation of duties, quorum approvals
Lost or stolen storage mediaStandard encryption at rest is enough

3. Decide which encryption model per workload. A single model rarely fits every platform. See Hold Your Own Key (HYOK) for the trade-offs between server-side, BYOK and HYOK, and what BYOK really means.

4. Name the stakeholders. Security architecture, cloud platform owners, application owners, DPO or legal, operations/SRE (they will run the key service), procurement and internal audit.

5. Fix your decision criteria and weights before you read any response. The scoring model below gives a starting point.


The requirements checklist

Each group is a table with four columns: ID, Requirement, Priority and Evidence to request. Requirements are written so that a serious product in this category can satisfy and evidence them.

Group 1. Scope and data classification

IDRequirementPriorityEvidence to request
SC-1The solution supports the platforms listed in Appendix A (your inventory) and states per platform which encryption model is usedMustPlatform support matrix with documentation links
SC-2Protection can be applied by data classification (for example, regulated data keyed separately from internal data)ShouldConfiguration walkthrough or demo of per-classification keys
SC-3Data in transit between platform and key service is protected with TLS 1.2 or higherMustArchitecture diagram, TLS configuration documentation
SC-4The vendor states which data is not covered (metadata, search indexes, logs, backups, caches)MustWritten scope statement per platform
SC-5Coverage of new and existing data is described, including re-encryption of historical dataShouldMigration procedure, throughput figures from a reference deployment

Group 2. Encryption models

IDRequirementPriorityEvidence to request
EM-1Each supported platform is labelled with its model: provider-managed, customer-managed (BYOK), external key (HYOK/EKM) or client-sideMustMatrix with the model per platform
EM-2For external-key models, the vendor explains where the cryptographic operation happens (provider side with a wrapped key, or at your key service)MustData-flow diagram of one encrypt and one decrypt
EM-3Where the platform offers a double-key option, both keys are required to decrypt (for example Microsoft 365 DKE)ShouldDocumentation and a test showing decryption fails without either key
EM-4Client-side or application-level encryption (SDK or proxy) is available for platforms without native external-key supportShouldSDK documentation, supported languages
EM-5Tokenization or field-level encryption is available for structured data, with format-preserving options where neededShouldFeature documentation, sample schema
EM-6Transparent database encryption (TDE) integration with an external key manager is supported for the databases in scopeMust (if databases in scope)Supported versions list, install guide
EM-7Where a platform cannot support customer-held keys, the vendor says so explicitly instead of marketing a weaker model under the same nameMustWritten limitations list

Group 3. Key control and sovereignty

IDRequirementPriorityEvidence to request
KC-1Keys are generated and stored in a key manager under the customer's control (own datacenter, dedicated tenancy or a named jurisdiction)MustDeployment options, hosting locations
KC-2The vendor lists which parties (vendor staff, hosting provider, cloud provider) can access key material or invoke key operations, and under which conditionsMustWritten statement, access-control description
KC-3The customer can revoke platform access to keys unilaterally, and the effect on data is documented (including cached keys)MustRevocation test, documentation of cache lifetimes
KC-4Key material never leaves the key manager in clear textMustArchitecture description, HSM or equivalent certification
KC-5The jurisdiction of the vendor and of the key-hosting entity is stated, with its exposure to foreign legal requestsMustLegal entity chart, hosting contract extract
KC-6Root keys can be backed by an HSM certified to FIPS 140-3 (or FIPS 140-2 while valid) or an equivalent assurance levelShouldCertificate numbers
KC-7Key generation, rotation, disable, destroy and import are supported with documented lifecycle statesMustLifecycle documentation
KC-8Key splitting or multi-party control so that no single administrator or machine holds a complete keyAdvancedArchitecture paper, quorum configuration demo

Group 4. Platform integrations

Keep only the rows you need. "Supported" means documented, tested against current platform versions and supported by the vendor, not "possible with custom work".

IDRequirementPriorityEvidence to request
PI-1Microsoft 365: double key encryption for labelled content and/or customer key for service encryptionShouldSetup guide, supported workloads, known limitations
PI-2Salesforce: Shield Platform Encryption with an external key serviceShouldSupported key-use modes, setup guide
PI-3ServiceNow: customer-controlled key integrationShouldSupported editions and setup guide
PI-4AWS: external key store (XKS) or KMS-integrated key management for S3, EBS, RDS and similarShouldXKS proxy compatibility statement, tested services list
PI-5Azure: Key Vault or managed HSM integration or external key capability for storage and databasesShouldIntegration document
PI-6SQL Server and Oracle TDE through an external key manager (EKM / PKCS#11)ShouldSupported versions, performance figures
PI-7Snowflake: customer-held key as part of Tri-Secret SecureShouldSetup guide
PI-8Databricks and other data platforms: customer-managed keys for storage and workspacesShouldSetup guide
PI-9AI services (for example OpenAI enterprise key management): customer-held key registrationShouldDocumentation, description of where the key service sits in the data path
PI-10Standard interfaces for custom needs: KMIP, PKCS#11, REST APIShouldInterface documentation
PI-11An integration does not require the vendor to receive plaintext business data unless explicitly statedMustData-flow diagram

Group 5. Performance and availability

External key services put your key manager on the critical path of your cloud data. This group is the one most often under-specified.

IDRequirementPriorityEvidence to request
PA-1The vendor documents behaviour when the key service is unreachable per platform: fail-closed (data inaccessible) or fail-open/cachedMustBehaviour table, outage test results
PA-2Latency added per key operation is stated for each platform, with the platform's own timeout limitsMustBenchmark, platform documentation reference
PA-3A highly available deployment (active-active or active-passive across independent nodes or zones) is supported and documentedMustHA architecture, failover test
PA-4Stated availability objective (SLA) for the managed service, or sizing guidance for self-hostedMustSLA, runbook
PA-5Capacity: sustained operations per second tested at your expected peak, with headroomShouldLoad-test report
PA-6Disaster recovery of the key service itself (backup, restore, regional recovery) with stated RPO and RTOMustDR plan, last test date
PA-7Planned maintenance and upgrades do not interrupt key operationsShouldUpgrade procedure
PA-8A documented break-glass procedure exists, with its own audit trail and approvalShouldProcedure document

Group 6. Cryptography and post-quantum readiness

IDRequirementPriorityEvidence to request
CR-1AES-256 for data encryption keys; RSA (3072 or higher) or elliptic-curve options for key wrapping where the platform requires themMustAlgorithm list
CR-2Algorithms and parameters follow current national guidance (NIST SP 800-57 and equivalents, BSI TR-02102)ShouldConformance statement
CR-3Key rotation without service interruption, with automatic and on-demand modesMustRotation demo
CR-4Post-quantum roadmap: support for ML-KEM (FIPS 203), ML-DSA (FIPS 204) and SLH-DSA (FIPS 205), with datesShouldRoadmap, current status per algorithm
CR-5Crypto-agility: algorithms can be changed by configuration, not by re-architectureShouldDesign description
CR-6Random number generation from a validated sourceMustDocumentation, certificate
CR-7Hybrid (classical plus post-quantum) key establishment option where the platform allows itAdvancedProduct documentation

Group 7. Access policies

IDRequirementPriorityEvidence to request
AP-1Role-based access control for key administration, separated from key useMustRole model
AP-2Policies per key define which application, identity, tenant or service may use itMustPolicy examples
AP-3Strong authentication for administrators (MFA, SSO integration with your identity provider)MustAuthentication options
AP-4Conditional policies on key use (time, network, identity attributes, rate)ShouldPolicy language reference
AP-5Separation of duties: the person who creates a key cannot alone authorize its destructionShouldWorkflow demo
AP-6Approval quorum (M-of-N) for sensitive administrative actionsAdvancedQuorum configuration
AP-7Policy changes are versioned and reviewableShouldChange history sample

Group 8. Audit and monitoring

IDRequirementPriorityEvidence to request
AU-1Every key operation (use, administration, policy change, failed attempt) is logged with identity, time, key and outcomeMustLog schema and sample
AU-2Logs are exportable to your SIEM through standard formats or APIs, in near real timeMustIntegration documentation
AU-3Logs are protected against alteration; retention is configurableMustDescription of protection
AU-4Alerts on anomalous use (volume spikes, unusual source, repeated denials)ShouldAlert rules
AU-5Behaviour if the audit record cannot be written is defined (refuse the operation vs continue) and configurable by the customerShouldDocumentation of the audit failure mode
AU-6Tamper-evident audit (hash chaining or signed records) that an auditor can verify independentlyAdvancedVerification procedure
AU-7Reports for auditors that map key controls to your frameworksShouldSample report

Group 9. Regulatory mapping

Ask the vendor to map capabilities to the rules that apply to you, in their own words. Do not accept a logo list. The references below are generic anchors, not a compliance claim.

IDRequirementPriorityEvidence to request
RG-1GDPR: support for technical measures under Article 32 (encryption, resilience) and for controller-processor responsibilities under Article 28; documented handling of third-country transfersMust (EU/EEA data)Data processing agreement, transfer analysis
RG-2Swiss FADP: support for data security obligations and cross-border disclosure rulesMust (Swiss data)Mapping document
RG-3DORA: support for ICT risk management, including cryptographic controls and key management (Article 9), and ICT third-party risk requirementsMust (EU financial entities)Mapping document, contractual provisions
RG-4NIS2: support for the policies on cryptography and encryption required as a cybersecurity risk-management measure (Article 21)Must (in-scope entities)Mapping document
RG-5FINMA: support for outsourcing, operational resilience and data-protection expectations for supervised institutions (Circular 2023/1)Must (supervised Swiss entities)Mapping document
RG-6HIPAA: support for the Security Rule technical safeguards, including encryption of ePHI, and willingness to sign a business associate agreement where applicableMust (US health data)BAA template, mapping
RG-7Independent assurance of the vendor (ISO/IEC 27001 certificate, SOC 2 report or equivalent) with scope covering the key serviceMustCertificate and scope statement
RG-8Vendor supports regulator and customer audit and inspection rightsShouldContract clause

Group 10. Deployment and exit/portability

IDRequirementPriorityEvidence to request
DX-1Deployment options: SaaS, dedicated tenancy, self-hosted/on-premises, or hybrid, with the responsibilities of eachMustDeployment guide
DX-2Time to deploy for a first platform, with a realistic planShouldProject plan from a reference customer
DX-3Infrastructure-as-code or API automation for key and policy configurationShouldAPI/Terraform documentation
DX-4Exit: keys can be exported or re-wrapped to another key manager in a documented procedure, or data can be re-encrypted under new keysMustExit procedure
DX-5Exit does not leave data unreadable: the vendor describes the steps and time needed per platformMustExit plan
DX-6Open interfaces (KMIP, PKCS#11, documented REST API) reduce lock-inShouldInterface list
DX-7Key and policy data can be exported in a documented formatShouldExport sample

Group 11. Vendor and support

IDRequirementPriorityEvidence to request
VS-1Support hours and response times by severity, in your time zones and languagesMustSupport policy
VS-2Named technical contact or customer success for the projectShouldContract
VS-3Vulnerability disclosure and patch policy with timelinesMustPolicy
VS-4Product roadmap relevant to your platforms, shared under NDA if neededShouldRoadmap
VS-5Reference customers in your sector and size, contactableShouldReference list
VS-6Financial and operational stability, subcontractor list and change notificationShouldCorporate information
VS-7Training and documentation for administratorsShouldDocumentation set

Weighted scoring model

Weights should reflect your risk model. The table below is an example with made-up generic numbers.

CategoryExample weight
Key control and sovereignty (Group 3)20%
Encryption models and platform integrations (Groups 2 and 4)20%
Performance and availability (Group 5)15%
Audit and access policies (Groups 7 and 8)10%
Cryptography and PQC readiness (Group 6)5%
Regulatory mapping (Group 9)10%
Deployment and exit (Group 10)10%
Vendor, support and commercial (Group 11 and price)10%
Total100%

0 to 5 scale for each requirement:

ScoreMeaning
0Not offered or no answer
1Planned but not available
2Available with significant custom work or gaps
3Available and documented, partial coverage
4Available, documented, evidenced in a demo or PoC
5Fully meets and exceeds, evidenced by reference customer

Apply a pass/fail gate first: any Must scored 0 or 1 disqualifies, or requires a written remediation before shortlist.

Worked example (illustrative numbers only). Vendor A averages 4.0 on key control, 3.5 on integrations, 3.0 on availability, 4.0 on audit, 3.0 on cryptography, 4.0 on regulatory, 3.0 on deployment and exit, 3.5 on vendor. Weighted: 0.20 x 4.0 + 0.20 x 3.5 + 0.15 x 3.0 + 0.10 x 4.0 + 0.05 x 3.0 + 0.10 x 4.0 + 0.10 x 3.0 + 0.10 x 3.5 = 0.80 + 0.70 + 0.45 + 0.40 + 0.15 + 0.40 + 0.30 + 0.35 = 3.55 out of 5. Compare it with other vendors scored the same way, and with the price over five years.


20 vendor questions to ask in the response

  1. For each platform in our scope, which encryption model do you actually deliver (provider-managed, BYOK, HYOK/EKM, client-side)?
  2. Where does the cryptographic operation take place on a decrypt: at your service, or at the cloud provider with a key you gave it?
  3. Who, in your organisation and in your hosting chain, can invoke or access key operations? Under what controls?
  4. In which legal jurisdiction is the key service hosted and operated? Which authorities could compel you or your hosting provider?
  5. What happens to our data when the key service is unreachable, per platform? Is it fail-closed, and for how long do caches keep working?
  6. What latency does a key operation add, and what are the timeouts of each platform you integrate with?
  7. Show us your highest-availability reference architecture and your last failover test.
  8. What are your RPO and RTO for the key service itself?
  9. How do we revoke the platform's access, and what is the measured time until data becomes inaccessible?
  10. How are keys rotated, and does rotation require re-encryption of data?
  11. Which HSMs or equivalents back root keys, and with which certifications?
  12. How is administrator access authenticated, and can we require approvals from several people?
  13. What is logged, where can it be exported, and how do we verify logs were not altered?
  14. What happens if an audit record cannot be written?
  15. Which of our regulations (GDPR, FADP, DORA, NIS2, FINMA, HIPAA) have you been assessed against by customers or auditors, and what do you provide for audits?
  16. What is your post-quantum roadmap, with dates, for key wrapping and signatures?
  17. Which parts of the solution are your own code, and which are third-party or open-source components?
  18. Describe the exit: how do we leave in 90 days with all data readable?
  19. What are the known limitations for each platform integration (features that stop working under customer-held keys)?
  20. Which customers in our sector run this in production, and how long?

Red flags in vendor answers

  • "Encrypted at rest" offered as the whole answer. That is provider-managed encryption; it does not address key control.
  • No written statement of who can access keys, or an answer that depends on "trust".
  • BYOK sold as HYOK. If the provider ends up holding a usable copy of the key, it is not HYOK.
  • Fail-open behaviour presented as a feature, with no explanation of what that does to the control you are buying.
  • No latency or capacity figures for the platform that matters most to you.
  • High availability described as "cloud-native" without a failover test.
  • Exit plan answered with "contact support".
  • Compliance claims as a list of regulations with no mapping to capabilities.
  • Post-quantum "ready" without named algorithms or dates.
  • References that cannot be called.

Proof-of-concept plan with pass/fail tests

Run the PoC on the two or three platforms that carry the most risk. Define pass/fail before the PoC starts.

TestPass criterion
Deploy the key service and connect platform 1Encrypt and decrypt succeed within the agreed time; documented steps are reproducible by your team
Connect platform 2 (for example a database with TDE)Same as above, with measured performance overhead within your threshold
Revoke accessData becomes inaccessible within the documented time; restoring access recovers it
Key service outageBehaviour matches the documented fail-closed or cached behaviour; recovery requires no manual re-encryption
FailoverPlanned node failure without failed operations beyond the stated threshold
Key rotationRotation completes without service interruption
Access policyAn unauthorised identity and an unauthorised application are denied and logged
AuditOperations appear in your SIEM within the agreed delay; an altered record is detected (if tamper-evidence is required)
LoadSustained peak throughput with agreed latency and no errors
ExitData re-encrypted or re-wrapped under a different key manager in the PoC, with no data loss

Contract and exit clauses

  • Data and key ownership. Keys, key metadata and audit logs belong to the customer.
  • Jurisdiction and access. Hosting location, entities with potential access, and an obligation to notify the customer of any legal request unless prohibited by law.
  • Subprocessors. List, change notification and objection right.
  • Availability. SLA with credits, defined fail-closed or fail-open behaviour and maintenance windows.
  • Security. Vulnerability disclosure timelines, breach notification period, audit and inspection rights.
  • Regulatory. Clauses addressing the specific frameworks that apply to you (for example DORA contractual provisions for ICT third-party services).
  • Exit. Assistance, export formats, transition period, price for exit services, and deletion certificates.
  • Escrow or continuity where the key service is critical.
  • Termination for convenience or for regulatory change.

Copy-ready RFP introduction

[Company] is seeking proposals for an enterprise data encryption solution that protects data at rest in [list of platforms: for example Microsoft 365, Salesforce, ServiceNow, AWS, Azure, SQL Server, Oracle, Snowflake, Databricks and AI services] using cryptographic keys that remain under [Company]'s control. The solution must allow [Company] to determine who can use and revoke keys, document the behaviour of each platform when the key service is unavailable, provide audit evidence suitable for [applicable regulations: GDPR, Swiss FADP, DORA, NIS2, FINMA, HIPAA] and offer a documented exit path. Respondents must complete the requirement tables in Appendix B, state their assumptions for each platform, and provide evidence for each Must requirement. Respondents will be evaluated with the weighted model in Appendix C and shortlisted vendors will take part in a proof of concept with pass/fail criteria.


FAQ

What should an encryption RFP include?

It should include scope and classification, the encryption models by platform, key control and jurisdiction, integrations, failure behaviour, cryptography, access policies, audit, regulatory mapping, deployment and exit, and vendor support. Add a scoring model and a PoC. The checklist above provides all of these as copyable tables.

What is the difference between BYOK and HYOK in an RFP?

With BYOK you generate or import a key that the provider then holds and uses. With HYOK or external key management the key stays in your key manager and the provider calls it for each operation. Require the vendor to state which model applies per platform, and see BYOK explained.

Should we require fail-closed behaviour?

For regulated data, fail-closed is usually what you want: if the key service is unreachable or refuses, data stays inaccessible. The price is that your key service becomes critical infrastructure. Ask for high availability, outage tests and documented cache behaviour for each platform, and decide fail-closed versus fail-open per workload.

Do we need client-side or double key encryption?

Not for every workload. Double key encryption, such as Microsoft 365 DKE, is meant for a small set of highly sensitive content because some features, such as server-side search, are limited on protected content. Use external key management for the broad estate and double-key or client-side protection for the crown jewels. See the DKE setup guide.

How do we compare HSM-based and software or multi-party key services?

Compare them on the same requirements: who can access keys, certifications, availability, performance, audit and exit. Do not exclude a category by rule unless your regulation does. The KMS RFP template covers key management products in more depth.

How should we handle post-quantum cryptography in the RFP?

Treat it as a roadmap and crypto-agility requirement: ask which algorithms from FIPS 203, 204 and 205 are supported, when, and how algorithms are changed. See the post-quantum RFP template for a dedicated checklist.

Is a vendor outside the EU or Switzerland acceptable?

It depends on your risk assessment, the data and your regulator. What matters is who can access keys and under which legal system. Ask for the jurisdiction of the vendor and of the hosting entity, and read data sovereignty and encryption keys.


Conclusion

A good encryption RFP is a test of control, not of features. Ask who holds the keys at runtime, what happens when the key service goes down, how you revoke, how you prove it to an auditor and how you leave. Score vendors with the same weights, and validate in a PoC. DuoKey provides customer-controlled key management across the platforms above, and you can compare it against others using the comparison pages, Fortanix and Entrust. Include DuoKey, and every other vendor, only on the strength of evidence.


References

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DuoKey Team

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