Since June 2026, federal agencies have had mandatory deadlines for moving to post-quantum cryptography (PQC), algorithms designed to resist attack by both conventional and quantum computers. Under Section 4(b) of President Donald Trump’s Executive Order (EO) 14412, they must 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. In memorandum M-26-15, the Office of Management and Budget (OMB) told agencies to migrate “with the objective of mitigating as much quantum risk as feasible by December 31, 2030.” The government’s classified, intelligence, and military systems, known as national security systems, have had mandatory dates since the 2024 update to Committee on National Security Systems Policy 15, according to the National Security Agency (NSA).
From January 1, 2027, new acquisitions for those systems must comply with the Commercial National Security Algorithm Suite 2.0 (CNSA 2.0), the algorithms NSA approves for them. Under 44 U.S.C. 3552, national security systems include systems that contractors operate for agencies. Outside national security systems, companies face none of these dates directly. Trump’s route to them is a Federal Acquisition Regulation (FAR) rule that the FAR Council must propose by December 19, 2026, requiring “covered contractors” to comply with post-quantum standards from the National Institute of Standards and Technology (NIST) by December 31, 2030.
Under the federal measures reviewed here, a binding U.S. post-quantum date reaches a company in November 2026 only through its work for the federal government, and the contracting rule that would set that date for most vendors has not yet been proposed. In 2026, the Federal Reserve, the Treasury, the Federal Communications Commission, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission each addressed quantum risk without imposing a requirement.
The statute
Congress set the legal base in the Quantum Computing Cybersecurity Preparedness Act, Public Law 117-260, signed on December 21, 2022. Under the Act, OMB had 180 days to issue guidance requiring each agency to keep a prioritized inventory of information technology vulnerable to quantum decryption. OMB also had one year from NIST’s issuance of post-quantum standards to issue guidance requiring agencies to prioritize their migration and plan it. Congress excluded national security systems from all of the Act’s requirements.
NIST issued its first three post-quantum standards on August 13, 2024. Counting from those three standards, the migration guidance was due by August 2025. OMB issued M-26-15 on June 24, 2026, about 10 months after that date, and wrote in it that the memorandum fulfills OMB’s responsibility under the Act.
Under the Act, OMB must also report to Congress on “the progress of agencies in adopting post-quantum cryptography standards,” from one year after the migration guidance until five years after NIST issued the standards. OMB must submit each of those reports with its annual report to Congress on federal information security under 44 U.S.C. 3553(c). Counting from M-26-15, the first is due by June 24, 2027. Counting from the first three standards, OMB must keep reporting until August 2029.
OMB had already asked agencies for inventories in memorandum M-23-02 of November 18, 2022, with annual updates until 2035. In an audit released on October 6, 2026, the Government Accountability Office (GAO) found one complete inventory among the 24 agencies it examined. In M-26-15, OMB neither cited nor rescinded M-23-02.
The executive orders
President Joe Biden set the 2035 horizon in National Security Memorandum 10 (NSM-10) on May 4, 2022, with the goal of “mitigating as much of the quantum risk as is feasible by 2035.” In Executive Order 14306 of June 6, 2025, Trump rewrote the post-quantum section of Biden’s January 2025 cybersecurity order and cited NSM-10.
Under the rewritten section, the Cybersecurity and Infrastructure Security Agency (CISA) had until December 1, 2025, to list product categories in which PQC-capable products are widely available. Agencies must support TLS 1.3, the current version of the protocol that secures web connections, by January 2, 2030, a requirement OMB repeated in M-26-15.
Trump signed EO 14412, “Securing the Nation Against Advanced Cryptographic Attacks,” on June 22, 2026, three days before the Federal Register published it. Under Section 4(b), OMB had 90 days to require each agency to move all high-value assets and high-impact systems to PQC, for key establishment by the end of 2030 and for digital signatures by the end of 2031. Trump excluded national security systems only from the section’s first item, a review of agencies’ inventories. He wrote no such exclusion into the two migration deadlines.
High-value assets are the systems and information that agencies designate as such under OMB memorandum M-19-03. A high-impact system is one rated “high” for confidentiality, integrity, or availability under Federal Information Processing Standard (FIPS) 199. In key establishment, two systems agree on a shared secret key. A digital signature lets a recipient check who sent data and that nobody altered it.
Trump also gave NIST, NSA, and CISA deadlines of their own in the order. NIST must start a PQC migration pilot on some of its own systems by December 19, 2026, and finish it by the end of 2027. By the same December date, NIST must also revise its Cryptographic Module Validation Program to speed up validations.
NSA must send the President its first annual report on PQC migration in national security systems by December 19 as well. CISA, working with NIST, must publish guidance on the minimum elements of a cryptographic bill of materials (CBOM), a machine-readable record of the cryptography in a product, by March 19, 2027.
Disclosure: Quantum Observer’s Editor-in-Chief Marin Ivezic is a co-author of the Applied Quantum CBOM Profile, published by Applied Quantum, the quantum systems integration and consulting firm he founded and leads.
Also on June 22, Trump signed Executive Order 14413, “Ushering in the Next Frontier of Quantum Innovation,” on quantum research, sensing, and supply chains. In it, he mentioned PQC once, when he asked the Director of National Intelligence and the Secretary of War to assess the national security implications of scaling commercial quantum computers, “such as the implications for the migration to post-quantum cryptography.” Their report is due within a year.
OMB’s memorandum
OMB Director Russell Vought issued M-26-15, “Execution of the Migration to Post-Quantum Cryptography,” on June 24, 2026. In it, OMB told agencies to “execute a prioritized migration of cryptographic systems” with the December 31, 2030 objective. Each agency had 120 days, until October 22, 2026, to send OMB and the Office of the National Cyber Director a migration plan aligned with NIST’s transition guidance.
OMB divided the migration into five phases that run to 2035. Agencies are to spend 2026 and 2027 on strategy, planning, and discovery, and 2027 and 2028 on pilots and early migration. From 2028 to 2030, they move key establishment on their priority systems to PQC. Agencies move signatures in 2031 and complete the remaining systems by 2035, “based on risk assessment and the availability of commercial offerings.”
OMB wrote that the memorandum “does not apply to national security systems.” It let agencies choose hybrid schemes, which combine a classical and a post-quantum algorithm, based on their own risk assessments and technical requirements. Agencies considering a hybrid “should perform a thorough evaluation of its tradeoffs,” OMB wrote. It called the approach “an intricate and resource-intensive stopgap.”
On purchasing, OMB wrote that agencies “should reference” CISA’s product categories list and should make sure their requirements for products in those categories include PQC integration. OMB also wrote that CISA and the Department of War, with the General Services Administration, “will lead PQC migration” for providers authorized under FedRAMP, the federal cloud authorization program, and for software, platform, and infrastructure services used by more than one agency.
NIST’s standards
NIST issued the three standards on August 13, 2024, according to its release. In FIPS 203, NIST standardized ML-KEM, a key-encapsulation mechanism derived from CRYSTALS-Kyber that two parties use to agree on a shared key. In FIPS 204, it standardized ML-DSA, a signature scheme derived from CRYSTALS-Dilithium. In FIPS 205, it standardized SLH-DSA, a hash-based signature scheme derived from SPHINCS+.
On its project page, last updated on October 27, 2026, NIST described the standardization of Falcon, the basis of the planned FN-DSA signature standard, and of HQC, a second key-encapsulation mechanism, as underway.
For federal civilian systems, NIST’s FIPS are mandatory under federal law. Under 40 U.S.C. 11331, the information security standards that the Secretary of Commerce prescribes for federal systems are “compulsory and binding.” In the same section, Congress left standards for national security systems to other authorities.
NIST published the final version of NIST IR 8547, its transition plan, on October 27, 2026. In it, NIST deprecated RSA, elliptic-curve, and finite-field Diffie-Hellman algorithms at every approved key size after 2030 and disallowed them after 2035, Quantum Observer reported. Under NIST’s definitions, an organization may keep using a deprecated algorithm if the data owner examines the risk and decides to continue, but it may not use a disallowed one.
NIST wrote that the 2030–2035 window is meant for lower-risk systems and legacy constraints and that federal agencies must still meet the earlier deadlines. Agencies also need the new algorithms inside validated modules. Under NIST’s guidance, agencies should not put modules validated under the older FIPS 140-2 standard into new systems after September 21, 2026, Quantum Observer reported.
In vendor evidence gathered in July, MITRE found no category of enterprise technology in which a general-release product ran its post-quantum functions through a module validated under FIPS 140-3, the current standard.
National security systems
Under 44 U.S.C. 3552, national security systems (NSS) are those used for intelligence, cryptologic work, military command, weapons, or classified information, including systems operated by “a contractor of an agency.” For those systems, NSA sets cryptographic requirements through the Committee on National Security Systems (CNSS).
CNSA 2.0 is NSA’s suite of approved algorithms for these systems. In version 2.1 of its CNSA 2.0 frequently asked questions (FAQ), published in December 2024, NSA included ML-KEM-1024 and ML-DSA-87, the strongest parameter sets of the two lattice-based standards. The agency wrote that SLH-DSA “is not approved for any use in NSS.”
In the same version, NSA cited three dates from CNSS Policy 15, starting with the January 1, 2027 acquisition rule. By December 31, 2030, equipment and services that cannot support CNSA 2.0 must be phased out. By December 31, 2031, CNSA 2.0 algorithms are “mandated for use unless otherwise noted.”
In its September 2022 CNSA 2.0 advisory, NSA set out the timetable it anticipated for each product type. It expected software and firmware signing and traditional networking equipment, such as VPNs and routers, to use CNSA 2.0 exclusively by 2030. Web browsers, servers, cloud services, operating systems, and niche equipment were to follow by 2033, the year by which custom applications and legacy equipment were to be updated or replaced. NSA expects the transition of national security systems to be complete by 2035.
In version 2.2 of the FAQ, published in October 2026, NSA named the Department of War and the defense industrial base among its audiences. “NSA does not mandate requirements on any other entity outside of NSS,” the agency wrote. It added that “these requirements may serve as guidance for entities outside of NSS.” In 2027, the National Information Assurance Partnership (NIAP), which validates commercial products used in national security systems, “will no longer accept products for certification that have not started their quantum transition,” NSA wrote in the same version.
The Department of War adopted the same 2030 and 2031 dates. In its post-quantum strategy, released on June 23, 2026, the department wrote that by December 31, 2030, “all DoW systems must support PQC or be phased out.” By December 31, 2031, “all DoW systems must use PQC, unless otherwise noted,” the department wrote. It also wrote that national security systems “must support” CNSA 2.0.
Contractors
For companies, Section 6(c) of EO 14412 is the main route. Within 180 days, the FAR Council, which writes the government’s procurement rules, must publish a proposed rule requiring “covered contractors to comply” by December 31, 2030, “with NIST’s FIPS, including all applicable FIPS incorporating PQC compliant algorithms.” Trump did not define a covered contractor in the order.
Under Section 6(d), the FAR Council must propose a second rule by March 19, 2027. Under it, covered contractors would take reports of cryptographic weaknesses, including the use of non-FIPS-approved algorithms, through their vulnerability disclosure programs. Neither proposed rule had appeared in the Federal Register as of November 12.
Defense contractors face a second route through the Department of War. In its strategy, the department wrote that it “will update the Cybersecurity Maturity Model Certification (CMMC) to include requirements for PQC.” CMMC is the scheme that certifies contractors handling sensitive defense data. On July 13, the department suspended Phase II of CMMC.
Cloud providers that sell to agencies face a third route through FedRAMP. Under proposed FedRAMP rules for 2027, providers in the program’s 20x pilot would document the post-quantum status of their key establishment and digital signatures, with a target date for the transition.
Vendors to national security systems already face the January 1, 2027 acquisition rule and NIAP’s 2027 cutoff.
Companies without federal business
In a fact sheet on EO 14412, the White House said the administration will help critical-infrastructure owners adopt the same protections. Under Section 5(a) of the order, agencies that serve as sector risk management agencies must work with CISA “to assist critical infrastructure owners and operators in developing their PQC migration plans.”
CISA published its product categories list on January 23, 2026, as guidance. In the order, Trump described the coming CBOM elements as “public guidance.”
In its September 2026 report to Congress, the Federal Reserve Board called quantum computing “another significant emerging risk area on the horizon.” The board described steps that other federal agencies had suggested to institutions and stated no supervisory expectation.
On August 24, the Treasury announced a Quantum-Readiness Task Force of government, financial institutions, financial market infrastructures, and technology providers, with workstreams on sector alignment, vendor readiness, and digital assets. The Treasury announced no deliverables or deadlines for it. On July 31, the Federal Communications Commission asked in a proposed rule whether it should account for quantum risk “through post-quantum cryptography” when it authenticates emergency alerts.
In its final rule for stablecoin issuers, published on October 23, the Office of the Comptroller of the Currency (OCC) declined to add technical standards that commenters had proposed, among them “quantum computing risk management standards.” The OCC wrote that those standards “may be overly burdensome and at risk of becoming outdated quickly.” On October 6, the Securities and Exchange Commission asked, in Request for Comment 59 of its custody proposal, whether an adviser should “consider the threat of quantum computing to the security of a crypto asset.”
Timeline
| Date | Requirement | Who is bound | Source |
|---|---|---|---|
| October 22, 2026 | PQC migration plans to OMB and the Office of the National Cyber Director | Federal agencies, excluding national security systems | M-26-15 |
| December 19, 2026 | Proposed FAR rule on contractor compliance with PQC standards, revised module validation, NIST pilot start, first NSA report | FAR Council, NIST and NSA | EO 14412 |
| January 1, 2027 | New acquisitions comply with CNSA 2.0 | Owners, operators and vendors of national security systems | NSA CNSA 2.0 FAQ |
| March 19, 2027 | CBOM minimum elements (guidance) and proposed FAR rule on vulnerability disclosure | CISA with NIST, and the FAR Council | EO 14412 |
| January 2, 2030 | Support for TLS 1.3 | Federal agencies | EO 14306 |
| December 31, 2030 | PQC key establishment for high-value assets and high-impact systems (an objective in M-26-15) | Federal agencies, except national security systems (M-26-15) | EO 14412, Section 4(b), M-26-15 |
| December 31, 2030 | Phase-out of equipment that cannot support CNSA 2.0 | National security systems | NSA CNSA 2.0 FAQ |
| December 31, 2030 | All DoW systems support PQC or are phased out | Department of War | DoW PQC strategy |
| December 31, 2030 | Compliance with FIPS, including PQC algorithms, if the FAR rule is adopted | Covered contractors (term undefined) | EO 14412 |
| After 2030 | RSA, elliptic-curve and finite-field Diffie-Hellman algorithms deprecated | Systems that follow NIST standards | NIST IR 8547 |
| December 31, 2031 | PQC digital signatures for high-value assets and high-impact systems | Federal agencies, except national security systems (M-26-15) | EO 14412, Section 4(b), M-26-15 |
| December 31, 2031 | CNSA 2.0 algorithms mandated | National security systems | NSA CNSA 2.0 FAQ |
| December 31, 2031 | All DoW systems use PQC unless otherwise noted | Department of War | DoW PQC strategy |
| 2033 | NSA’s anticipated date for exclusive CNSA 2.0 use in browsers, servers, cloud services, operating systems and niche equipment | National security systems | NSA CNSA 2.0 advisory |
| 2035 | Remaining systems migrated, and quantum-vulnerable algorithms disallowed after 2035 | Federal agencies and systems that follow NIST | M-26-15, NIST IR 8547 |
The case that companies are already bound
The law firm Skadden, Arps, Slate, Meagher & Flom wrote in June that the orders “establish timelines and enforceable obligations for federal agencies and government contractors.” The firm also wrote that the FAR requirement is expected to flow through the government’s supply chain. On that view, vendors that sell to agencies would build the 2030 date into products they also sell to commercial buyers. Skadden stopped there, but on the same logic other buyers would then base their own requirements on CISA’s list and the CBOM guidance.
Skadden described the effect of a final rule. As of November 12, the FAR Council had published no proposal for a class of companies, “covered contractors,” that Trump left undefined. The council normally seeks public comment on a proposed procurement rule before it adopts a final version. A bank or hospital with no federal contract would face no dated federal duty even then.
In Section 7 of EO 14412, Trump wrote that the order creates no right enforceable at law, and he made its implementation subject to appropriations. For agencies, the dates in EO 14412 and M-26-15 are binding instructions from the President and OMB, enforced through OMB’s oversight and the budget process.
The EU’s 2030 date for high-risk uses remains a recommendation that no EU law yet imposes on a company, Quantum Observer found in its companion analysis of NIS2 and DORA.
What would confirm or overturn this reading
The FAR Council’s proposal, due December 19, is the first test. If the council defines covered contractors broadly enough to reach commercial products, it would extend the 2030 date to much of the U.S. technology market. If it defines them narrowly, most companies would stay outside the rule.
Congress will see how far agencies have moved when OMB sends its first progress report under the 2022 Act, due by June 24, 2027. Whether agencies filed the migration plans they owed in October 2026 would be one measure of that progress.
A sector regulator could overturn the second half of this reading. If the Federal Reserve, the OCC, or another supervisor turned its statements on quantum risk into dated examination expectations, private companies would face post-quantum obligations through supervision as well as procurement.
