The Swiss Financial Market Supervisory Authority (FINMA) recommended on July 9, 2026, that the banks, insurers, and other institutions it supervises draw up a roadmap for migrating to post-quantum cryptography (PQC) by mid-2027 at the latest. PQC refers to cryptographic algorithms designed to resist attacks by future quantum computers.
FINMA set out the recommendation in FINMA Guidance 05/2026, an eight-page document titled “Quantum computing,” alongside a survey of 60 Swiss financial institutions. In most cases, FINMA said, the institutions lacked a clear roadmap.
Unlike FINMA’s ordinances and circulars, its guidance “is not a supervisory tool” and “does not have legal impact,” according to the regulator’s website. Supervised institutions therefore face no legal deadline in mid-2027, but FINMA wrote that governance and risk-management rules already in force cover quantum risk. It also said it would give the topic “greater prominence” in its ongoing supervisory activities.
Survey results
FINMA surveyed 60 authorized banks, insurance companies, managers of collective assets, and financial market infrastructures between November 2025 and January 2026. Around two-thirds expected the cyber risks of quantum computing to affect them directly within seven years, according to the guidance, with 17% choosing one to three years and 52% choosing four to seven.
About two-thirds expected that, within 10 years at the latest, a quantum computer would be able to crack 2048-bit RSA encryption within 24 hours. Respondents named data security as the area of greatest risk. Other risks they listed included incomplete migration, a lack of expertise, and harvest-now, decrypt-later attacks, in which encrypted data is collected today for decryption once a capable quantum computer exists.
Seventy-two percent said they had neither planned nor implemented any measures for quantum-safe encryption, FINMA reported. The other 28% had taken a strategic decision, including 20% of all respondents with a project under way. The 8% with a specific roadmap usually assumed four to five years to make their critical data and processes quantum-safe.
Around half of the institutions planned to draw up a roadmap within one to three years, and another 43% had not yet decided whether to do so. In the survey, 73% rated crypto-agility as important or very important. FINMA defined crypto-agility as the ability of IT systems to replace cryptographic algorithms flexibly, without major changes to software architecture.
Seventy-six percent saw high or very high added value in an inventory of their cryptographic methods. Sixty percent were in contact with software suppliers about the transition or planned to be.
Five recommendations
FINMA limited its recommendations to the transition to quantum-safe algorithms and left quantum key distribution (QKD), a method of sharing encryption keys through quantum states of light, out of scope. It cited NIST’s standards for ML-KEM, ML-DSA, and SLH-DSA, formerly known as CRYSTALS-Kyber, CRYSTALS-Dilithium, and SPHINCS+, published as FIPS 203, FIPS 204, and FIPS 205.
On strategy, FINMA recommended that migration work be based on a strategy adopted by the board of directors, with milestones and priorities set out in an implementation plan. The strategy can form part of an existing one, such as a strategy on cyber risks, FINMA wrote.
FINMA recommended drawing up the PQC roadmap by mid-2027 at the latest. The implementation plan should include target dates for complete migration and for critical business processes, the regulator wrote, without specifying those dates.
For risk analysis, FINMA recommended examining all business processes to identify the encryption, signature, and authentication technologies they use. It extended that review to all information and communication technology (ICT) systems, including distributed ledger technology and outsourced systems and services.
FINMA also recommended a continuously updated cryptographic inventory covering data in transmission and in storage, digital signatures, key management, and authentication. For systems using quantum-vulnerable algorithms, such as RSA, ECDSA, EdDSA, DH, and EC-DH, FINMA considered a migration plan “commensurate with the associated risk” appropriate.
On critical data, FINMA recommended identifying information that needs long-term guarantees of confidentiality, integrity, or non-repudiation, the assurance that a signer cannot later deny a signature. Data that needs to remain protected in the long term should get priority for PQC protection, FINMA wrote. It recommended taking the risk of harvest-now, decrypt-later attacks into account.
On hybrid schemes, which pair a classical algorithm with a post-quantum one, FINMA reported what other organizations recommend. It wrote that “various organisations recommend a hybrid solution over pure PQC algorithms in the short to medium term,” citing a 2025 joint statement that it described as coming from partners in 21 European states.
FINMA added that an institution’s internal risk analysis “may also indicate the need to use hybrid solutions” during system migration. It also wrote that hybrid solutions add complexity and, with it, implementation risk.
FINMA wrote that algorithms regarded as secure today, PQC algorithms included, should be expected to need replacing in the future. It recommended crypto-agility “as a requirement for ICT systems and applications to be procured or developed.”
On external providers, FINMA wrote that PQC migration generally depends on outsourced functions and external interfaces, whose providers must also move to quantum-safe cryptography. In all cases, it wrote, the outsourcing institution stays responsible for an outsourced function. It recommended making crypto-agility a prerequisite for all new outsourcing arrangements in the software and data sectors and adding it to existing arrangements “at the earliest opportunity.”
Outlook
FINMA wrote that cryptographically relevant quantum computers, machines able to break today’s public-key encryption, “do not yet exist” but can be expected to emerge in the coming years. It called the risk of harvest-now, decrypt-later attacks “already very real.” It recommended that supervised institutions have a PQC roadmap in place by mid-2027.
