The Government Accountability Office (GAO), the audit agency that reports to Congress, released the public version of its audit of federal preparations for post-quantum cryptography on October 6, 2026. In fieldwork that ended in September 2025, GAO found that none of the 24 agencies it examined had fully carried out three preparatory practices drawn mainly from guidance the Office of Management and Budget (OMB) issued in November 2022.
Post-quantum cryptography consists of algorithms designed to resist attacks by future quantum computers. The three practices were a prioritized inventory of systems that use quantum-vulnerable cryptography, an estimate of the funding needed to migrate them, and tests of the new algorithms in agency environments.
GAO found one complete inventory among the 24 agencies and no agency that had tested post-quantum cryptography in its own environment. At the six agencies it examined in depth, none could produce documents supporting the algorithms listed for every system GAO sampled.
GAO ran the audit from February 2024 to September 2025 at the request of Senator Maggie Hassan, ranking member of the Joint Economic Committee. It first reported the findings in a sensitive report on September 11, 2025, with 89 recommendations to the Cybersecurity and Infrastructure Security Agency (CISA) and 23 of the 24 agencies. GAO made no new recommendations in the public report.
Citing industry experts, GAO wrote that a quantum computer able to break the public-key cryptography that federal systems rely on could be developed as soon as the 2030s. GAO also noted that experts consider the probability of one being built in the next 10 years low.
Inventories
In memorandum M-23-02, OMB directed agencies to send a prioritized inventory of systems with quantum-vulnerable cryptography, excluding national security systems, to the Office of the National Cyber Director (ONCD) and CISA by May 4, 2023, and every year after that until 2035. The inventories were to cover high-value assets, high-impact systems, systems holding data expected to remain sensitive in 2035, and access-control systems based on public-key infrastructure.
High-value assets and high-impact systems are the federal systems that would cause the most harm if compromised. GAO found that most agencies left some of their high-value assets out of their inventories and that a majority missed some high-impact systems. A majority of agencies also did not include or consider the other two categories.
To test accuracy, GAO randomly selected six agencies and asked officials for documents supporting the algorithms listed for three systems sampled from each inventory. Two agencies supported the algorithms for some sampled systems, three supported none, and the sixth had no inventory.
Expertise, processes, and tools
GAO attributed the gaps partly to a lack of cryptography expertise and of documented processes for building inventories. None of the 18 agencies that reported lacking cryptography expertise had a plan to fill that gap. Twenty-three agencies had no documented process for maintaining their inventories.
Officials at 15 agencies told GAO it was too early to use automated tools for their inventories or that they were waiting for CISA to identify suitable ones. Nineteen agencies used no such tools to find or verify inventory data. CISA officials told GAO that the agency had not told departments and agencies to wait for it to identify tools.
Funding and testing
Of the 24 agencies, 21 produced partial assessments of their migration funding needs and three produced none. Only one agency based its assessment on a complete inventory of priority systems. All 21 agencies with assessments told GAO their data were not fully accurate.
In a July 2024 report, OMB used those assessments to give Congress an estimate, developed by ONCD, that migrating prioritized systems from 2025 to 2035 would cost about $7.1 billion in 2024 dollars. OMB and ONCD officials told GAO the assessments “were reliable for the purposes for which they have been used.”
Sixteen agencies told GAO it was too early to identify candidates for testing. ONCD officials called testing voluntary, but GAO wrote that “OMB’s guidance does not indicate that PQC testing is to be a voluntary activity.” GAO also wrote that open-source tools such as Open Quantum Safe had been available for at least four years.
New requirements
President Trump signed Executive Order 14412 on June 22, 2026, after the audit ended. In it, he directed OMB to require agencies to move their high-value assets and high-impact systems to post-quantum key establishment by December 31, 2030, and to post-quantum digital signatures by December 31, 2031. Key establishment is the step in which two systems agree on a shared encryption key.
In memorandum M-26-15, issued two days after the order, OMB required each agency to submit a migration plan to OMB and ONCD within 120 days, by October 22, 2026. Agencies must describe in the plan the methods and automated tools they use for their cryptographic inventories and estimate the funding and staff they need.
Under the same order, the Department of Homeland Security, working through CISA with the National Institute of Standards and Technology, has until March 19, 2027, to publish the minimum elements of a cryptographic bill of materials. Such a bill is a structured record of the algorithms, keys, and certificates in a product.
Update, November 12, 2026: GAO reissued the report on October 14 to clarify how it described its coordination with agencies on removing sensitive information. It did not change the findings.
