Post-quantum readiness
Find where your organization relies on cryptography a quantum computer could break. Leave with an inventory, a risk ranking and a migration plan dated against the rules that apply to you.
What it answers.
- Where do we rely on RSA and elliptic-curve cryptography, including inside the products our vendors run for us?
- Which of our data would still do harm if it were recorded today and decrypted years from now?
- What can we show our regulator and our board by the next deadline?
- What can we change now, and what has to wait for a vendor?
What is in scope.
Cryptographic discovery, inventory and quantum risk assessment across your systems, suppliers and internet-facing services, measured from outside and checked from inside. The exact boundary is written into the authorization before work starts.
- Internet-facing services: websites, APIs, mail, remote access and SSH
- Internal protocols: TLS between services, VPN and IPsec links, SSH and wireless
- Public key infrastructure: certificate authorities, smart cards, device certificates, and code and firmware signing
- Hardware security modules and key management systems, including the firmware they run
- Payment and card systems, including the cipher suites and protocols PCI DSS asks you to document
- Databases, file stores and backups, and how long each must stay confidential
- Cryptographic libraries in the software you build
- Vendor, cloud and CDN products, through their published roadmaps and our questions to each supplier
How it runs.
-
Map the rules
We list the texts that apply to you, such as SAMA’s circular or the CBK’s CORF, the dates each sets, and guidance such as NIST’s timeline.
-
Measure from outside
We test every internet-facing host you authorize, as we did for the main websites of 159 banks and regulators: handshakes only, nothing requested or changed.
-
Discover inside
With your teams we combine network traffic, configuration, endpoint and code sources, and ask vendors what their products embed.
-
Rank by data lifetime
Each asset is ranked by how long its data must stay secret, how exposed it is to recording and what depends on it.
-
Check suppliers
We record each vendor’s, cloud provider’s and CDN’s post-quantum roadmap, and what your contracts let you require.
-
Plan and report
Changes you can make now come first, then a migration plan dated against your deadlines, presented to the agreed audience.
What you receive.
- A cryptographic inventory in CycloneDX CBOM format and as a spreadsheet, with algorithm, key size, protocol, owner and data lifetime for each entry
- An external measurement report for every host tested
- A quantum risk assessment ranking assets by data lifetime, exposure and dependency
- A supplier register of vendor, cloud and CDN post-quantum roadmaps and gaps
- A list of changes you can make now, such as hybrid key exchange where your software already supports it
- A migration plan with milestones set against each deadline that applies to you
- A table tracing each finding to the regulator item it answers
- A summary for your board and its risk committees
What we need from you.
- Written authorization for external measurement and internal discovery, naming who can approve each
- Your asset inventory, network diagrams, and data classification and retention schedules
- A contact for each of PKI, HSMs, payments, networks and software development
- Your list of technology vendors and service providers, and the relevant contract terms
- The regulatory texts and deadlines you answer to
Choose a post-quantum readiness assessment when a regulator, board or contract asks where you stand on quantum risk and you need an inventory and plan that hold up to review.
What the rules ask.
Each text quoted as published, with how binding it is and what this work hands back for it. Only a regulator can say whether work meets its rule.
Saudi Arabia
6 clauses Binding
-
Circular 482021280, item Second
Binding“Ensure the accuracy and comprehensiveness of the procedures for identifying and classifying all cryptographic assets of the financial institution by the end of the fourth quarter of 2026”
- What you get
- The written discovery and classification procedure, and the inventory it produces.
- Applies to
- Banks, finance companies, payment service providers and credit bureaus
-
Circular 482021280, item Second, first point
Binding“Identify the data, systems, and services associated with cryptographic assets and classify them in terms of sensitivity and priority for migration to quantum-resistant cryptographic solutions.”
- What you get
- Inventory fields for owner, data class, data lifetime and migration priority.
-
Circular 482021280, item Second, second point
Binding“Assess the level of cryptographic resilience of priority assets and identify constraints, challenges, and dependencies on third parties.”
- What you get
- An agility review of each priority asset and a supplier register.
-
Circular 482021280, item First
Binding“Conduct an enterprise-level assessment of the risks associated with quantum computing, in alignment with the financial institution’s enterprise risk management procedures, and develop action plans to address the risks identified through the assessment.”
- What you get
- The quantum risk assessment and action plans, written to drop into the risk register. Item First also names operational, legal, regulatory, strategic and staffing risks; we cover the technical and supplier risks and flag the rest for the owners.
-
Circular 482021280, item Third
Binding“Develop plans and initiatives to achieve the required level of cryptographic resilience or appropriate alternative solutions for all priority assets”
- What you get
- A migration plan per priority asset, with the alternative named where a system cannot migrate.
-
Circular 482021280, item Fourth
Binding“Include quantum computing risks as a standing item for periodic monitoring within the activities of the Information Security Supervisory Committee and the Risk Committee”
- What you get
- A board summary and a short set of measures the committees can track each quarter.
Kuwait
3 clauses Binding
-
CORF v1.0, control 7.1.4.2
Binding“Regulated Entities shall periodically assess cryptographic practices to ensure resistance to quantum computing capabilities.”
- What you get
- A baseline assessment and an inventory format that can be rerun.
- Applies to
- CBK-regulated banks and financial institutions
-
CORF v1.0, control 7.1.4.3
Binding“The strategy shall include timelines and milestones for cryptographic migration, assessment of critical systems and data at risk, third-party dependencies, and operational preparedness.”
- What you get
- The evidence base for the strategy: inventory, data-at-risk ranking, supplier register and a dated plan.
-
CORF v1.0, control 7.1.4.4
Binding“Regulated Entities shall test and validate quantum-resistant cryptographic algorithms in testing environments to ensure compatibility and performance prior to deployment.”
- What you get
- A test plan for each change in the plan, and checks of hybrid key exchange in your test environment where agreed.
United Arab Emirates
1 clause Binding
-
UAE Information Assurance Standard v2.1, control T3.4.4, sub-controls 1 and 2
Binding“1) maintain an inventory of all systems and applications that use public key cryptography. 2) test the new post quantum cryptographic standard in a lab environment before implementing it in a production environment.”
- What you get
- The public-key inventory and a lab test plan.
- Applies to
- Federal entities and critical information infrastructure, based on risk assessment
United States
21 clauses BindingPendingGuidanceReportStatement
-
Executive Order 14412, Sec. 4(b)(ii) and (iii)
Binding“transition all HVAs and high impact systems to use PQC for key establishment by December 31, 2030; transition all HVAs and high impact systems to use PQC for digital signatures by December 31, 2031”
- What you get
- A plan that moves key establishment first and signatures second, the sequence the order sets.
- Applies to
- Federal agencies, not banks. National security systems excluded
-
Executive Order 14412, Sec. 5(a)
Binding“shall work with the Department of Homeland Security through the Director of CISA to assist critical infrastructure owners and operators in developing their PQC migration plans.”
- What you get
- A migration plan in the shape the federal guidance uses, ready for any sector request.
- Applies to
- Sector Risk Management Agencies and CISA
-
Executive Order 14412, Sec. 5(d)
Pending“These elements shall enable the automated assessment of the cryptographic assets utilized by a hardware or software element.”
- What you get
- A machine-readable inventory in CycloneDX CBOM format, so it can be mapped to CISA’s elements when they are published.
- Applies to
- CISA with NIST. The guidance will be advisory
-
Executive Order 14412, Sec. 6(c)
Pending“require covered contractors to comply by December 31, 2030, with NIST's FIPS, including all applicable FIPS incorporating PQC compliant algorithms.”
- What you get
- For institutions that hold federal contracts, a list of systems in contract scope that use non-FIPS or quantum-vulnerable algorithms.
- Applies to
- Covered federal contractors, once the FAR rule is adopted. The proposed rule is due December 19, 2026
-
Executive Order 14412, Sec. 6(d)
Pending“VDPs incorporate reports of cryptographic vulnerabilities, including testing for lack of encryption and the use of non-FIPS approved algorithms.”
- What you get
- External tests for unencrypted services and non-approved algorithms, findings you can fix before an outside reporter finds them.
- Applies to
- Federal contractors, through the FAR Council
-
M-26-15, Sec. 3.C.2
Binding“Contain data expected to remain mission-sensitive in 2030.”
- What you get
- A ranking by data lifetime, with 2030 as the reference line.
- Applies to
- Federal agencies, not banks
-
M-26-15, Sec. 3.C.3
Binding“Systems incapable of supporting PQC or hybrid cryptography must be identified and given priority for replacement or decommissioning.”
- What you get
- A list of systems that cannot migrate, with the reason and the owner.
-
M-26-15, Sec. 3.D, Phase 3
Binding“Ensure all systems are cryptographically agile.”
- What you get
- An agility review: whether algorithms are set in configuration or compiled in, and whether key systems can hold post-quantum keys.
-
M-26-15, Appendix A, Sec. 4
Binding“agencies must support Transport Layer Security (TLS) protocol version 1.3 or a successor version as soon as practicable, but not later than January 2, 2030.”
- What you get
- Every host in scope tested for TLS 1.3, which hybrid TLS key exchange needs.
-
M-26-15, Appendix A, Sec. 5
Binding“The systems responsible for managing cryptographic keys (Key Management Service (KMS), Hardware Security Module (HSMs)) must also be agile.”
- What you get
- An HSM and key management review: models, firmware, validated algorithms and vendor plans.
-
M-26-15, Appendix A, Sec. 6
Binding“This inventory should be created and maintained through automated tools wherever possible, including by use of Software Composition Analysis (SCA) to analyze Software Bills of Materials (SBOMs), Static/Dynamic Application Security Testing (SAST/DAST) to find cryptographic functions in code, and network scanners to detect protocols and cipher suites.”
- What you get
- Discovery that combines network, code and configuration sources, with each method recorded.
-
M-26-15, Appendix A, Sec. 7, Networks
Binding“All network infrastructure that terminates TLS or IPsec sessions or other relevant protocols ... must be configured to support PQC-capable key exchanges that utilize NIST PQC algorithms.”
- What you get
- A check of every TLS and IPsec terminator in scope, inside and at the edge.
-
M-26-15, Appendix A, Sec. 7, Data
Binding“Agencies must prioritize identifying and re-encrypting long-lived sensitive data using keys protected by PQC mechanisms.”
- What you get
- Databases, file stores and backups ranked by how long they must stay confidential, and how their keys are wrapped.
-
M-26-15, Appendix B, Sec. 2
Binding“The methodologies and automated tools used for the cryptographic inventory”
- What you get
- A method record listing every tool, source and limit, and a third-party coordination plan.
-
M-23-02, Sec. II.A, inventory item 8
Binding“Lifecycle characteristics of the data contained in the system, including types of data (as described by national records management categories) and how long the data and associated metadata need protection (i.e., “time to live”).”
- What you get
- Inventory fields that follow M-23-02’s list, time to live included.
- Applies to
- Federal agencies, not banks. We found no rescission in M-26-15
-
Quantum-Readiness factsheet, Prepare a cryptographic inventory
Guidance“Organizations should ask vendors for lists of embedded cryptography within their products.”
- What you get
- A vendor questionnaire and the answers, recorded in the supplier register.
- Applies to
- Organizations, especially those supporting critical infrastructure
-
Quantum-Readiness factsheet, Prepare a cryptographic inventory
Guidance“Organizations should include in their inventory when and where quantum-vulnerable cryptography is being leveraged to protect the most sensitive and critical datasets and include estimates on length of protection for these datasets.”
- What you get
- Data lifetime recorded against each inventory entry.
-
Quantum-Readiness factsheet, Supply chain quantum-readiness
Guidance“An organization’s quantum-readiness roadmap should include details of when and how each COTS vendor plans to deliver updates or upgrades to enable the use of PQC, as well as the expected cost associated with migration to PQC.”
- What you get
- Vendor, cloud and CDN roadmaps collected from their own publications, with gaps marked.
-
Product categories for technologies that use post-quantum cryptography standards
Guidance“organizations should acquire only PQC-capable products when planning acquisitions and procuring products in these categories.”
- What you get
- Procurement checks for products due for renewal in the listed categories.
- Applies to
- Federal buyers. M-26-15 tells agencies to use it
-
Cybersecurity and Financial System Resilience Report, Current and Emerging Cybersecurity Threats
Report“Banks and service providers should be aware of the risk implications and should consider how to effectively monitor developments in quantum computing as they manage future infrastructure investments.”
- What you get
- A board-level view of exposure for a US bank that has no dated duty yet.
- Applies to
- Report to Congress on OCC-supervised banks
-
Treasury Announces the Quantum-Readiness Task Force
Statement“It will focus on practical, risk-based approaches to quantum readiness, including identifying critical dependencies, improving cryptographic agility, promoting interoperability, strengthening operational resilience, and addressing implementation challenges related to third-party dependencies and digital assets.”
- What you get
- Dependency mapping, an agility review and a supplier register in the terms the task force uses.
- Applies to
- Press release announcing a public-private initiative for the US financial sector
Standards
9 clauses StandardGuidance
-
IR 8547 (final), Sec. 4
Standard“NIST will deprecate quantum-vulnerable public-key cryptography after 2030 and disallow its use under NIST standards and guidelines after 2035.”
- What you get
- A plan with every quantum-vulnerable asset dated against 2030 and 2035.
- Applies to
- Systems that follow NIST standards
-
IR 8547 (final), Sec. 3
Standard“if “X” represents the number of years that data must be kept secure, and “Y” is the estimated time needed to complete the transition, then organizations must start transitioning to post-quantum algorithms before X + Y exceeds the expected time Z”
- What you get
- Harvest now, decrypt later exposure scored per data class from your retention schedules and the plan.
-
IR 8547 (final), Sec. 3
Standard“While signatures are not vulnerable to HNDL attacks, transitioning to post-quantum signatures is also urgent due to the longer duration and greater complexity of the transition process and the need for a greater number of parties to coordinate.”
- What you get
- A PKI, code signing and identity track in the plan, separate from key exchange.
-
IR 8547 (final), Sec. 4.1.2
Standard“as long as at least one of the inputs to an approved composite (i.e., hybrid) key-establishment technique comes from an approved key-establishment scheme, the combination can be FIPS 140-validated, even if other inputs are disallowed.”
- What you get
- Quick wins: where your current software can offer hybrid ML-KEM key exchange, and whether the FIPS-certified part is the one RFC 10024 requires.
-
IR 8547 (final), Sec. 4.2
Standard“TLS is an early priority for the migration as it protects data in transit for nearly every federal system and service, making it a primary target for “harvest now, decrypt later” collection”
- What you get
- Every TLS endpoint in scope measured first, outside and in.
-
IR 8547 (final), Sec. 2.2.3
Standard“Hardware modules must be upgraded or redesigned to support PQC algorithms, which often have larger key sizes and different computational requirements.”
- What you get
- HSM models and firmware recorded, with each vendor’s stated support.
-
IR 8547 (final), Sec. 3.1.1
Standard“it is important for the devices to be designed to require quantum-resistant signatures on the executable code if there is a risk that the devices will still be in use after cryptanalytically relevant quantum computers become available.”
- What you get
- Code and firmware signing chains listed, with devices whose verification cannot be updated flagged.
-
SP 1800-38B, preliminary draft, Sec. 4.1.4
Guidance“how they can be obtained from passive network observations, active network scans, endpoint monitoring, or configuration information”
- What you get
- Discovery that draws on all four sources and records which one found each asset.
- Applies to
- A preliminary draft. We found no later version on October 30, 2026
-
ECMA-424, CycloneDX Bill of materials specification, 2nd edition
Standard“supporting domain-specific modelling for cryptographic artefacts and machine learning models”
- What you get
- The inventory in CycloneDX’s cryptography bill of materials format, which this standard defines, so other tools can read it.
Financial sector
3 clauses ContractualGuidanceStatement
-
Summary of changes from PCI DSS v3.2.1 to v4.0, requirement 12.3.3
Contractual“New requirement to document and review cryptographic cipher suites and protocols in use at least once every 12 months.”
- What you get
- The cipher suite and protocol inventory for the card environment, from the same discovery.
- Applies to
- Entities that store, process or transmit card data. PCI DSS v4.0.1 is the current version; v4.0 was retired on December 31, 2024
-
FAQ 1491
Guidance“It is considered best practice to implement TLS versions and cipher suites that support forward secrecy and the implementation of ciphers utilizing post-quantum cryptography (for key exchange and end-point authentication).”
- What you get
- Card-environment TLS endpoints tested for forward secrecy, early TLS and hybrid key exchange.
-
Statement on a coordinated post-quantum roadmap, phase 2, Discovery and inventory
Statement“Comprehensive inventory of cryptographic assets, communication protocols, and relevant third-party dependencies.”
- What you get
- The inventory, organized so it also serves the G7 phases of risk assessment and planning.
- Applies to
- G7 financial sectors. The statement says it “does not set guidance or regulatory expectations”
Common questions.
Short answers, each resting on the texts quoted above or on our published reference pages.
- What does SAMA require by December 31, 2026?
- Item Second of circular 482021280 requires financial institutions to ensure the accuracy and comprehensiveness of their procedures for identifying and classifying all cryptographic assets by the end of the fourth quarter of 2026. It asks for procedures and a classification, not a finished migration. Item First, an enterprise quantum risk assessment with action plans, is due by the end of the first quarter of 2027.
- What does Kuwait’s central bank require?
- CORF v1.0 control 7.1.4.3 requires a quantum readiness strategy that includes “timelines and milestones for cryptographic migration, assessment of critical systems and data at risk, third-party dependencies, and operational preparedness.” Controls 7.1.4.2 and 7.1.4.4 add periodic assessment and testing before deployment. CORF sets no completion date.
- What applies in the UAE and the rest of the Gulf?
- Control T3.4.4 of the UAE Information Assurance Standard v2.1 requires federal entities and critical information infrastructure, on a risk basis, to keep an inventory of systems that use public-key cryptography and to test post-quantum standards in a lab first. The UAE government portal says the National Encryption Policy defines requirements for post-quantum cryptography; we could not open its text on October 30, 2026. Our reference section records no published post-quantum rule in Qatar, Bahrain or Oman.
- Does a US bank have a post-quantum deadline?
- Not from its regulators, as far as we found by October 30, 2026. The OCC says banks “should be aware of the risk implications”. Treasury launched a public-private Quantum-Readiness Task Force on August 24, 2026. The 2030 and 2031 dates in Executive Order 14412 bind federal agencies, and NIST’s 2030 and 2035 dates apply to systems that follow NIST standards. A bank that holds federal contracts may face 2030 once the FAR rule the order calls for is adopted.
- Our website already negotiates post-quantum key exchange through our CDN. Are we done?
- No. That protects the connection between visitors and the CDN. In our measurement of October 29, 2026, all 93 banks and regulators that negotiated post-quantum key exchange did so through a CDN or cloud edge. The link from the edge to your servers, internal traffic, VPNs, mail, payment links, HSMs and certificates cannot be seen from outside. The assessment covers them.
- Should we replace our certificates first?
- Usually not first. NIST says signatures are not vulnerable to harvest now, decrypt later, so moving key exchange protects recorded data sooner. NIST also calls the signature move urgent, because it takes longer and needs more parties. None of the 148 banks and regulators we reached presented a post-quantum certificate. The plan starts PKI work now and switches key exchange first.
- Is hybrid key exchange allowed in a FIPS environment?
- NIST says a hybrid can be FIPS 140-validated as long as at least one input comes from an approved scheme. RFC 10024 adds that for X25519MLKEM768 the ML-KEM implementation is the part that must be certified. OMB calls hybrid “an intricate and resource-intensive stopgap” for federal agencies and leaves the choice to their risk assessments. We check which applies to each system.
- What can we change straight away?
- Often key exchange. Hybrid ML-KEM key exchange is an IETF standard for TLS 1.3, and OpenSSH has used hybrid ML-KEM key exchange (mlkem768x25519-sha256) by default since version 10.0. In our measurement, 33 of the 55 institutions without post-quantum key exchange did not negotiate TLS 1.3 at all, and hybrid TLS key exchange needs it. We list what your current software already supports.
- Which data should move first?
- Data that must stay confidential longest and that crosses networks where it could be recorded. NIST frames this with Mosca’s theorem: start before the years data must stay secure plus the years migration takes exceed the time until a quantum computer can break it. We take the first number from your retention schedules and the second from your plan. We use 2030, the line OMB set for federal data, as a reference.
- What format will the inventory be in?
- CycloneDX’s cryptography bill of materials format, part of the Ecma standard ECMA-424, and a spreadsheet. Executive Order 14412 orders CISA to publish the minimum elements of a cryptographic bill of materials by March 19, 2027. A machine-readable inventory can be mapped to those elements once they appear.
- How do you handle systems our vendors run?
- SAMA asks you to identify “dependencies on third parties”, and the CBK’s strategy must cover “third-party dependencies”. Discovery tools often cannot see cryptography embedded in a product, so CISA, NSA and NIST advise asking vendors for lists of it. We send those questions, read each vendor’s published roadmap and record the gaps in a supplier register.
- Will your report satisfy our regulator?
- Only your regulator can say. We trace every finding to the item it answers, such as SAMA item Second or CORF control 7.1.4.3, so your team can show what was done and what is still open.
- Do you need access inside our network?
- The external measurement needs only your written authorization. The internal inventory needs read access to configurations, network data and code, and time with the owners of PKI, HSMs and payment systems. We agree the depth before we start.
The reference behind it.
Our dated, sourced pages on the rules, terms and evidence this service draws on.
Are US and Gulf banks ready for post-quantum encryption?
Our test of the main websites of 159 US and Gulf banks and financial regulators, and what an outside test cannot see.
Measured October 29, 2026SAMA’s quantum circular, item by item
The four requirements of circular 482021280 for Saudi financial institutions, its two deadlines and what it leaves open.
Deadline December 31, 2026Post-quantum deadlines, United States and the Gulf
Every dated duty and target we could trace, on a timeline to 2035, marked binding or guidance.
Timeline to 2035Harvest now, decrypt later, and other terms
What each quantum security term means, from crypto-agility to a cryptographic inventory, and whether it is a standard, a product or research.
GlossaryQuantum security reference
Rules, deadlines, estimates and our bank measurement in one dated section, reviewed every week.
Section home
Name the deadline you are working to.
Write from your organization’s email address. Tell us what is in scope, your deadline and who can authorize testing. Leave sensitive details out of the first message.