Does AWS Sign a HIPAA Business Associate Agreement?
By BAA Generator Editorial · Published Apr 19, 2026 · Last reviewed Apr 19, 2026 · 4 min read
Key Takeaways
- ✓ Yes — AWS offers a HIPAA BAA (Business Associate Addendum) to all commercial accounts
- ✓ Self-service acceptance through AWS Artifact — no sales contact required
- ✓ BAA covers only HIPAA-eligible services — AWS maintains a published eligible services list
- ⚠ Using non-eligible services with PHI is a violation even after the BAA is accepted
- ✓ You are still responsible for securing your AWS environment — the BAA covers AWS's obligations, not your configuration
AWS is the dominant cloud infrastructure provider for healthcare workloads. Hospitals, health systems, digital health startups, and healthcare SaaS companies all run PHI on AWS. Here's the complete picture on AWS's HIPAA BAA — what it covers, how to get it, and the critical restrictions you need to understand.
How to Accept the AWS HIPAA BAA
The AWS BAA is self-service and costs nothing beyond your normal AWS usage:
- Log in to the AWS Management Console
- Navigate to AWS Artifact (search "Artifact" in the services search bar)
- Go to Agreements → AWS Business Associate Addendum
- Review the BAA and click Accept
- The BAA is effective immediately and applies to your entire account
The BAA applies at the account level. If you have multiple AWS accounts (e.g., separate production and development accounts), you must accept the BAA in each account where PHI will be processed.
HIPAA-Eligible vs. Non-Eligible AWS Services
This is the most critical thing to understand about AWS's HIPAA BAA. The BAA only covers services on AWS's official HIPAA-eligible services list. Using a non-eligible service with PHI — even after the BAA is accepted — is a compliance violation.
Commonly used HIPAA-eligible AWS services include:
- Compute: EC2, Lambda, ECS, EKS, Fargate, Elastic Beanstalk
- Storage: S3, EBS, EFS, Glacier
- Database: RDS, Aurora, DynamoDB, ElastiCache, Redshift
- Networking: VPC, Route 53, CloudFront, Elastic Load Balancing, API Gateway
- Security: IAM, KMS, CloudTrail, GuardDuty, Security Hub, WAF
- AI/ML: SageMaker, Comprehend Medical, HealthLake
- Messaging: SQS, SNS, SES (with caveats)
Always verify the current eligibility of any service at AWS's official HIPAA Eligible Services reference page before using it with PHI, as the list is updated regularly as services are added.
What the AWS BAA Covers
The AWS Business Associate Addendum establishes AWS's obligations as a business associate when handling PHI stored in your AWS environment. It covers:
- AWS's commitment to implement appropriate safeguards for PHI in its infrastructure
- Breach notification obligations to your organization
- AWS's subprocessor arrangements
- Return or deletion of PHI upon termination of services
Critically, the AWS BAA covers AWS's responsibilities — not yours. You remain responsible for how you configure and secure your AWS environment. Misconfigured S3 buckets, unencrypted EBS volumes, improper IAM policies, and insecure application code are all your responsibility regardless of the BAA.
Shared Responsibility Under the AWS BAA
AWS operates under a shared responsibility model for security. For HIPAA workloads:
- AWS is responsible for: physical data center security, hypervisor security, network infrastructure, hardware
- You are responsible for: encryption configuration, access controls, application security, data classification, audit logging configuration, incident response
The BAA doesn't make your AWS workload HIPAA compliant — it establishes the contractual framework. Compliance requires proper technical and administrative controls on your side.
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