The Infinite Unknown

Overview: Two Tracks for Federal Agencies

The U.S. federal government’s PQC transition has two parallel tracks:

1. National Security Systems (NSA → CNSA 2.0) — Covered in the NSA CNSA 2.0 entry
2. Civilian Federal Agencies (CISA → OMB M-23-02) — Covered here

CISA (Cybersecurity and Infrastructure Security Agency) operates under the Department of Homeland Security and leads PQC guidance for civilian agencies, critical infrastructure, and state/local governments. These entities don’t necessarily handle classified data but may handle sensitive or critical infrastructure information.

OMB M-23-02: The Federal Mandate (November 18, 2022)

On November 18, 2022, the White House Office of Management and Budget (OMB) issued Memorandum 23-02 “Migrating to Post-Quantum Cryptography” to all executive departments, CFO Act agencies, and federal IT organizations.

Key Requirements of M-23-02

1. Cryptographic System Inventory (Deadline: May 4, 2023; Recurring Annually)

Each agency must submit an inventory of cryptographic systems to the Office of the National Cyber Director (ONCD) and CISA, including:

• System name and description
• Cryptographic algorithms used (RSA key sizes, ECDH, ECDSA, etc.)
• Quantum vulnerability assessment
• Implementation status (in-service, planned, decommissioned)
• Data confidentiality requirements (how long must encryption last?)
• Migration feasibility and timeline estimate

Current status (2026): Agencies have been submitting annual inventories since 2023. CISA publishes aggregate findings.

2. Transition Planning (Deadline: Ongoing; Plan Due by May 4 each year)

Agencies must develop and update migration roadmaps including:

• Prioritization of systems (risk-based)
• Timeline for transition to NIST-standardized PQC algorithms
• Budgeting and resource allocation
• Testing and validation approach
• Vendor engagement plan

3. Funding Estimates (Deadline: Ongoing)

The preliminary government-wide cost estimate for PQC migration from 2025–2035 is approximately $7.1 billion (in 2024 dollars). Individual agencies must provide budget justification to OMB.

Compliance Mechanism

• Non-compliance risk: OMB can condition IT funding on demonstrated PQC migration progress
• Reporting: Annual submission to ONCD/CISA by May 4
• Enforcement: OMB Circular A-130 (cybersecurity requirements for federal IT systems) ties compliance to agency funding

CISA PQC Guidance & Roadmap

CISA has issued multiple guidance documents and announcements:

Executive Order 14306 (June 2025)

The White House issued an executive order directing CISA and DHS to:

1. Identify product categories where PQC-capable solutions are commercially available
2. Publish guidance on procuring only PQC-capable products in those categories by January 1, 2026
3. Update the list quarterly as the market matures

Impact: This creates federal procurement requirements for covered product categories.

CISA Product Categories for PQC Standards (January 23, 2026)

Product Categories for Technologies That Use Post-Quantum Cryptography Standards

Effective January 23, 2026, CISA published an initial list of product categories in which PQC-capable options are widely available. Federal agencies are required to procure only from PQC-capable vendors in these categories starting immediately (January 2026).

Examples of covered categories:

• TLS/HTTPS servers and clients
• VPN products (IKEv2/IPsec support required by RFC 9242/9370)
• Certificate authorities and PKI solutions
• Hardware security modules (HSMs)
• Cloud services (AWS, Azure, Google Cloud PQC support)
• SSH implementations
• Email/messaging encryption

Update frequency: CISA will update the list quarterly as:

• Vendors release PQC-capable versions
• New product categories mature
• Market adoption increases

Implication for 2026: Agencies procuring IT equipment must now verify PQC capabilities for all covered categories. Non-compliance can invalidate federal IT contracts.

CISA Migration Roadmap (Ongoing)

CISA publishes recommendations for organizations to develop their own PQC migration roadmaps:

1. Phase 1 (2024–2025): Assess & Plan

   • Inventory cryptographic systems
   • Assess quantum vulnerability
   • Identify priority systems for early migration
   • Engage vendors and system owners

2. Phase 2 (2025–2030): Deploy & Transition

   • Test NIST-standardized algorithms in pilot systems
   • Deploy hybrid mode (classical + PQC in parallel)
   • Upgrade high-priority systems
   • Monitor vendor support and standards evolution

3. Phase 3 (2030–2035): Full Migration

   • Complete transition to PQC-only systems
   • Decommission unsupported legacy systems
   • Validate full compliance with CNSA 2.0 (for NSS) or NIST standards (for civilian systems)

CISA’s emphasis: Start now (2025–2026); the 10-year window is tight for large organizations with complex infrastructure.

CISA/NSA Joint Advisories for Critical Infrastructure

CISA and NSA have published sector-specific joint guidance for critical infrastructure organizations:

Covered Sectors

• Water & Wastewater Systems — CISA joint advisory on PQC for SCADA/ICS
• Energy Sector — Guidance on utility grid cryptography upgrades
• Finance — Banking and payment system PQC requirements
• Communications — Telecom providers and backbone infrastructure
• Transportation — Air traffic control, rail, maritime systems

Key Message

Critical infrastructure operators must begin PQC migration planning immediately, with priority on systems protecting data with long confidentiality needs (e.g., power grid control algorithms, financial settlement systems).

FedRAMP Implications

FedRAMP (Federal Risk and Authorization Management Program) is the U.S. government’s program for certifying cloud services for federal use. As of April 2026, FedRAMP has begun integrating PQC requirements:

FedRAMP PQC Integration (2025–2026)

Current status:

• FedRAMP updates its baseline security requirements (FedRAMP Security Requirements for Cloud Service Providers) to include PQC support
• Cloud service providers (AWS GovCloud, Azure Government, Google Cloud Government) are implementing PQC options

What this means:

• New FedRAMP authorizations (starting 2026) must demonstrate PQC-capable TLS/encryption
• Re-authorizations (3-year cycle) will require PQC readiness plans
• By 2028, FedRAMP expects all authorized cloud services to offer PQC options

Implication: Federal agencies using cloud services for sensitive data must verify that their cloud providers have achieved PQC-capable certifications by their re-authorization deadlines.

NIST SP 800-175B (Guidance for Federal Cryptography)

NIST Special Publication 800-175B: Guideline for Using Cryptographic Standards in the Federal Government provides federal IT organizations with recommendations for algorithm selection.

PQC Updates (2025–2026)

• ML-KEM-768 or ML-KEM-1024 — Recommended for federal systems requiring long-term confidentiality
• ML-DSA-65 or ML-DSA-87 — Recommended for digital signatures
• Hybrid mode — Classical algorithm + PQC algorithm in parallel during transition phase (through ~2030–2033)
• Transition timeline — Agencies should support PQC by 2026, prefer it by 2030, use it exclusively by 2035

Key principle: SP 800-175B recommends a risk-based approach where agencies prioritize systems based on data sensitivity and longevity.

Federal Civilian Agency Compliance Timeline

Implementation Guidance for Agencies

Priority System Categories (Risk-Based Approach)

Tier 1 (Highest Priority – Migrate by 2027):

• Systems protecting data with >10 year confidentiality requirements
• Systems processing sensitive personal information (PII, health data)
• Systems protecting critical infrastructure control algorithms
• High-value targets for espionage (“harvest now, decrypt later” risk)

Tier 2 (Medium Priority – Migrate by 2030):

• Systems with 5–10 year data sensitivity
• Administrative and financial systems
• General IT infrastructure

Tier 3 (Lower Priority – Migrate by 2035):

• Short-lived session data
• Non-sensitive operational systems
• Systems with shorter useful life

Hybrid Transition Strategy

Recommended approach for 2026–2030:

1. Generate dual key pairs (classical + PQC)
2. Encrypt with both algorithms in sequence (classical-then-PQC or via hybrid KEM composition)
3. Receiver can decrypt with either key type, ensuring backward compatibility
4. By 2030, begin enforcing PQC-only mode
5. By 2035, classical-only systems must be decommissioned or upgraded

Benefits:

• Backward compatibility with legacy clients
• Provides quantum resistance immediately (via PQC)
• Maintains classical security as fallback
• Smooth transition without forcing overnight cutover

CISA Resources & Support

CISA PQC Central Hub

https://www.cisa.gov/pqc — CISA’s main PQC page with:

• Migration planning templates
• Vendor readiness checklists
• Sector-specific guidance
• Training and webinars

CISA & NSA Joint Guidance (2024–2026)

“Moving to Post-Quantum Cryptography” — A comprehensive guide for organizations on:

• Migration roadmap development
• Hybrid cryptography deployment
• Crypto-agility architecture
• Testing and validation

NIST PQC Project Page

https://csrc.nist.gov/projects/post-quantum-cryptography — Official NIST resource with:

• FIPS standards documents
• Implementation guidance
• Cryptanalytic reports
• Algorithm specifications

Cost & Resource Implications

Government-wide estimate (2025–2035): ~$7.1 billion (2024 dollars)

Per-agency breakdown (varies):

• Small agencies: $5–20 million
• Medium agencies: $50–200 million
• Large agencies (DoD, VA, Treasury): $500 million – $2+ billion each

Cost drivers:

1. Hardware upgrades (HSMs, cryptographic accelerators supporting PQC)
2. Software licensing and upgrades
3. Testing, validation, and consulting
4. Staff training and capability development
5. Certificate authority (CA) infrastructure modernization

Budgeting challenge: OMB expects agencies to absorb PQC costs within existing cybersecurity budgets or request supplemental appropriations through normal budget cycles.

Cross-Cutting Themes: Federal Guidance vs. NSA CNSA 2.0

See Also

• NSA CNSA 2.0 & National Security Systems — Stricter timelines for classified/sensitive systems
• IETF Protocol Standards — RFC 9242, RFC 9370, draft TLS/SSH standards agencies must implement
• NIST FIPS & PQC Standardization — Detailed algorithm specifications

References

• OMB M-23-02 (Nov 18, 2022)
• CISA PQC Central
• CISA Product Categories (Jan 23, 2026)
• Executive Order 14306 (June 2025)
• NIST SP 800-175B
• FedRAMP Updates 2025–2026