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Compliance & Regulatory Strategy

Navigate the complex landscape of PQC compliance requirements across jurisdictions and frameworks.

The PQC Compliance Landscape

Governments and standards bodies worldwide are establishing requirements for the transition to . For organizations operating across borders, navigating these overlapping and sometimes conflicting requirements is a critical challenge.

“A quantum computer of sufficient size and sophistication — also known as a cryptanalytically relevant quantum computer — will be capable of breaking much of the public-key cryptography used on digital systems across the United States and around the world.”

— Executive Order 14306, Sustaining Select Efforts to Strengthen the Nation's Cybersecurity (June 6, 2025)

Regulatory Push

NIST, NSA, ETSI, , and are all publishing PQC transition guidance with concrete deadlines.

Industry Standards

PCI DSS, HIPAA, FedRAMP, and CMMC are incorporating quantum-safe requirements into their compliance frameworks.

Cross-Border Complexity

Organizations operating in multiple jurisdictions must reconcile different algorithm preferences, timelines, and certification requirements.

Key Frameworks

Understanding the major compliance frameworks driving PQC adoption is essential for building a multi-jurisdiction strategy.

(NSA)

The Commercial National Security Algorithm Suite 2.0 mandates PQC adoption for National Security Systems. Key deadlines: software/firmware signing preferred by 2025, exclusive by 2030; new networking equipment by 2026; web/cloud/servers and all remaining NSS by 2033. Requires -1024 (FIPS 203) and -87 (FIPS 204) as minimum security levels.

NIST's transition guidance for post-quantum cryptography standards (Initial Public Draft published November 2024; comment period closed January 2025; final version pending). Recommends deprecating RSA, ECC, and other classical public-key algorithms by 2030 and disallowing them entirely after 2035. Emphasizes cryptographic agility and hybrid approaches during the transition period.

ETSI / ANSSI / BSI

European bodies have published PQC migration guidance. ANSSI recommends hybrid cryptography combining classical and PQC algorithms. BSI endorses ML-KEM (FIPS 203) and ML-DSA (FIPS 204) with specific parameter recommendations. ETSI provides interoperability guidance for hybrid key exchanges.

Hybrid Now, Pure PQC Later: The Two-Phase Transition

All major frameworks converge on a two-phase transition arc. In Phase 1 (now through roughly 2028), organizations deploy hybrid mode — running a classical algorithm alongside a PQC algorithm in parallel. ANSSI and BSI require this during transition because it preserves security even if PQC implementations have undiscovered flaws. In Phase 2 (2028 onward, timed to your earliest jurisdiction deadline), organizations move to pure PQC: CNSA 2.0's “exclusive” requirements mean dropping the classical component once FIPS 140-3 validated implementations are widely available and proven.

Executive rule of thumb: Start hybrid deployments now. Plan your transition to pure PQC to meet your earliest jurisdiction deadline — which you will identify in the Jurisdiction Mapper workshop below.

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