6. ZKS and Interaction with Existing Standards (Informative)

6.1 Purpose and Scope

This section describes how the Zero-Knowledge Sovereignty (ZKS) Standard relates to other commonly adopted standards and guidance, including Zero Trust Architecture (ZTA), privacy frameworks, identity standards, and cryptographic/key management guidance.

This section is informative. It does not impose new normative requirements beyond those already defined in Sections 1–5. Its objectives are to:

• prevent category errors (e.g., equating ZKS with ZTA or with "end-to-end encryption" marketing claims);
• provide a vocabulary and mapping for auditors and procurement teams operating in environments governed by existing standards; and
• position ZKS as a complementary standard focused on sovereign control of decryptability capability, including key material possession constraints, revocation semantics, topological sovereignty, and multi-intermediary incapability (Sections 2–5).

Where existing standards use terms that appear similar to ZKS concepts (e.g., "zero trust," "zero knowledge," "customer-managed keys"), ZKS SHALL be interpreted according to its capability-based definition (Section 2.1) and operative semantics (Section 2.2), not according to contractual or policy-driven interpretations.

6.2 ZKS and Zero Trust Architecture (ZTA)

6.2.1 Relationship and Non-Equivalence

ZKS is complementary to Zero Trust Architecture (ZTA). The two standards address different primary problems:

• ZTA focuses on controlling access to enterprise resources under the assumption that networks are hostile and no implicit trust should be granted based on network location. Its central concern is continuous verification and access decision enforcement.
• ZKS focuses on preventing any third party in the digital supply chain from accessing, deriving, or intercepting the complete set of components required to decrypt user information (given ciphertext availability), and from being able to revoke decryptability for authorized users (Sections 2.1 and 2.2.6).

Key Distinction: ZTA primarily governs who may access resources; ZKS governs who can technically decrypt, and whether a third party can revoke decryptability.

In ZKS terms:

• Access control is not sufficient if the provider or intermediary still possesses or can derive the decryption capability.
• A ZTA policy engine may deny access to encrypted content; ZKS additionally requires that the policy engine itself is cryptographically blind to decryptability unless it resides inside the user's sovereignty domain.

A system may be ZTA-aligned yet not ZKS-compliant (e.g., a zero trust enterprise system that still stores keys in provider-controlled KMS). Conversely, a system may be ZKS-compliant while operating in an environment that is not fully ZTA-aligned (e.g., a personal device-to-device encrypted system with minimal enterprise access controls).

6.2.2 Alignment Points

ZKS aligns with ZTA in several practical and conceptual areas:

• Assumption of hostile intermediaries. Both ZKS and ZTA assume networks and intermediaries may be compromised or malicious.
• Minimization of implicit trust. ZKS removes trust assumptions from ciphertext storage providers and orchestration services by constraining their technical capabilities (Section 3).
• Strong identity and device authorization. ZKS requires sovereign device authorization and revocation models (Section 2.3 Tenet 6; Section 4 scenarios).

6.2.3 Combined Deployment Guidance (Informative)

In enterprise deployments, ZKS and ZTA should be viewed as layered controls:

• ZTA governs network and service access decisions.
• ZKS governs ciphertext/key custody, topology, and irreducible decryptability control.

A combined ZTA + ZKS deployment SHOULD ensure that:

• ZTA enforcement points do not require decryption outside the CSD;
• ZTA telemetry and logging do not undermine ZKS metadata minimization requirements (Section 3.6);
• ZTA policy engines do not become indirect revocation points for decryptability; and
• ZTA policy engines are configured to enforce policy based on verifiable metadata, identity attributes, and cryptographic proofs rather than plaintext inspection.

This latter point means that traditional network-based Data Loss Prevention (DLP) or content scanning - which requires plaintext inspection - is incompatible with ZKS-compliant systems. Alternative DLP approaches based on metadata analysis, behavioral patterns, or client-side enforcement may be compatible."

6.3 ZKS and Privacy Frameworks

6.3.1 Complementarity and Limits

ZKS contributes to privacy objectives by minimizing the capability of third parties to access plaintext and by constraining metadata exposure. However, privacy frameworks typically cover a broader scope, including:

• lawful processing, consent, purpose limitation;
• data subject rights and governance processes;
• organizational controls and accountability.

ZKS does not replace these frameworks; it provides a technical sovereignty baseline that can reduce exposure and centralization risks.

6.3.2 Metadata Minimization and Privacy-by-Design

ZKS introduces explicit normative requirements regarding metadata minimization outside the sovereignty boundary (Section 3.6). This intersects with privacy-by-design principles commonly found in privacy frameworks:

• minimize data collection and retention;
• reduce correlatability across services;
• design out centralized aggregation risks.

ZKS further adds a sovereignty requirement that metadata must not be sufficient to enable reconstruction of decryption workflows or to facilitate assembly of decryptability by correlation under collusion assumptions (see Section 3.6; Tenet 4; Sections 5.3.5–5.3.6 for normative requirements).

6.3.3 Audit Implications

Privacy audits often focus on policy statements and data inventory. ZKS audits must additionally examine capability pathways, including:

• whether metadata pipelines create correlation points that undermine sovereignty claims;
• whether external services store artifacts that, when combined, yield decryptability.

Accordingly, organizations should treat ZKS evidence requirements (Section 7.5) as complementary to privacy audit evidence, not a substitute.

6.4 ZKS and Identity & Authentication Standards

6.4.1 Identity is Necessary but Not Sufficient

Identity and authentication standards generally ensure that the right party is authenticated, that credentials are managed properly, and that sessions can be established securely.

ZKS requires strong identity and authentication to support:

• sovereign device enrollment and revocation (Section 4.5);
• protection of key release or recovery actions (Section 4.10);
• prevention of account takeovers that could induce unauthorized key distribution.

However, identity assurance alone does not imply sovereignty. A perfectly authenticated user may still be non-sovereign if a provider possesses or can derive the key material.

6.4.2 Recovery and Reset Flows as High-Risk Interfaces

Identity standards frequently include account recovery and reset flows. In many systems, these flows become de facto key recovery mechanisms, often involving provider-side intervention. Common examples include OIDC account recovery and SAML-based SSO with provider-held recovery.

ZKS treats these flows as a primary sovereignty risk surface (Section 5.3.2 and 5.3.8). Therefore, ZKS-compliant systems must ensure that identity recovery does not grant the provider decryptability and that 'support reset' workflows do not reintroduce centralized key custody or provider-controlled key release. See Sections 5.3.2 and 5.3.8 for the normative requirements governing these interfaces.

6.4.3 Out-of-Band Authorization

ZKS key separation operations may require OOB authorization (Section 3.3.4; Section 4.10). Identity standards that support multi-factor authentication and independent authenticators may be used for this purpose, provided that:

• the OOB channel does not become a provider-side bypass mechanism; and
• the user retains a sovereign restoration pathway independent of provider discretionary action.

6.5 ZKS and Cryptographic / Key Management Standards

6.5.1 Algorithm Neutrality vs Capability Requirements

ZKS is algorithm-neutral; it does not mandate specific cryptographic algorithms or key sizes. However, ZKS is not neutral with respect to capability outcomes:

• If cryptographic choices or implementations enable third parties to access, derive, or intercept key material sufficient to enable decryptability, the system is not ZKS-compliant (Sections 1.1, 2.2.2, 5.3.3).

Therefore, cryptographic standards and best practices remain relevant for ZKS implementations as enabling mechanisms, not as compliance substitutes.

6.5.2 "Customer-Managed Keys" vs Key Material Possession

Many cloud security models describe "customer-managed keys" where the customer controls key policy while the cloud provider possesses key material inside provider-managed HSMs.

ZKS explicitly rejects policy-only interpretations of control. ZKS requires that key material possession remain exclusively under user control (Section 1.4) and that no third party possess the complete set of components required to decrypt user information (Section 2.1).

Accordingly:

• Cloud KMS models may be compatible with ZKS only if they do not result in third-party key possession and do not permit third-party revocation of decryptability - conditions that many conventional cloud KMS offerings do not satisfy by default.

Terminological Note on BYOK, HYOK, and DKE: Industry terms such as "Bring Your Own Key" (BYOK) frequently describe models where the user imports key material into a vendor-controlled HSM. Because the vendor retains the technical capability to use the key (even if policy limits it), standard BYOK implementations are typically NOT ZKS-compliant.

ZKS aligns closer to "Hold Your Own Key" (HYOK) or "Double Key Encryption" (DKE) models, provided that the user retains exclusive control over the unwrapping service and the vendor cannot bypass this control. See Section 2.1 (ZKS definition) and A2 (Exclusive Key Material Possession, Section 7.4.2) for the normative basis of this distinction.

6.5.3 Key Wrapping, Key Separation, and Cryptographic Blindness

ZKS permits external storage of wrapped key packets in KCS or UKRS systems only under strict constraints:

• external services must remain cryptographically blind (cannot unwrap or derive plaintext keys);
• wrapped key storage must not create a provider kill switch for decryptability (Section 4.10 and Section 5.3.2);
• recovery must include a sovereign restoration pathway independent of provider discretion.

This aligns with key management principles emphasizing separation of duties and minimizing trusted custodians, but ZKS adds enforceable constraints on the technical capability of custodians.

6.5.4 TEEs, Secure Elements, and Hardware Trust

ZKS explicitly includes TEEs and secure elements as components of the cryptographic engine within the CSD (Section 3). These technologies can strengthen endpoint key protection and reduce exposure to local extraction. However:

• TEEs do not change the sovereignty boundary; they remain part of the CSD.
• Remote attestation and hardware-backed key protection may assist evidence generation, but they do not substitute for capability-based constraints on third parties.

6.6 ZKS and Regulatory Mapping (Non-Normative)

6.6.1 Positioning

ZKS may support compliance goals in regulated environments by reducing centralized access risk and limiting third-party capability to access plaintext. However, regulatory obligations vary by jurisdiction and context, and ZKS is not a legal compliance standard.

6.6.2 Typical Contributions to Compliance Programs (Informative)

Organizations may use ZKS architectures to support common compliance objectives such as:

• reducing breach impact by eliminating provider plaintext access;
• limiting insider risk by reducing centralized key custody;
• improving auditability through capability-based evidence rather than policy claims;
• supporting data minimization by reducing metadata exposure; and
• facilitating cross-border data transfer compliance.

In particular, by ensuring that ciphertext stored in foreign jurisdictions remains technically undecryptable by the storage provider or local authorities (absent user participation), ZKS architectures can support "Schrems II" and data residency requirements arising from the Schrems II ruling (CJEU Case C-311/18) and data residency obligations by demonstrating that the data remains sovereign to the originating jurisdiction.

6.6.3 Avoiding Overclaim

Organizations SHOULD avoid claiming that ZKS compliance alone ensures compliance with any particular law or regulation. ZKS provides a technical sovereignty baseline; legal compliance depends on additional controls and governance measures outside the scope of this Standard.