In the FATT process, working group chairs decide at the time of adoption
whether a document needs FATT review.

>From https://github.com/tlswg/tls-fatt:

"When a document is adopted by the working group the chairs will make a
determination whether the change proposed by the document requires review
by the FATT to determine if formal protocol analysis is necessary for the
change. For example a proposal that modifies the TLS key schedule or the
authentication process or any other part of the cryptographic protocol that
has been formally modeled and analyzed in the past would likely result in
asking the FATT, whereas a change such as modifying the SSLKEYLOG format
would not. The working group chairs will inform the working group of this
decision."

The chairs made this decision because the mechanism in this draft fits into
a well defined place in the TLS protocol and does not change the protocol
itself. The purpose of the FATT is to evaluate the potential security
impact of a change in the protocol, not to evaluate the merits of a
specific cryptographic algorithm such as ML-KEM. Unfortunately, the chairs
did not announce this decision on the list (this is something that should
be corrected in the process)

This decision is supported by references from Thom Wiggers and others on
the list that identify the security properties required by TLS 1.3 key
exchange.

The ML-KEM draft does not modify the TLS key schedule or protocol messages
in any way other than what is anticipated by RFC 8446/8446bis. RFC8446bis
explicitly defines key reuse as a SHOULD NOT.

The considerations applied also for ecdhe-mlkem, which has already gone
through the WG process and also did not undergo FATT review.

Joe
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