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Cryptographic migration

Standards and regulatory dates

Find the relevant publication, understand its status and build a checklist for your own migration. Regulatory dates follow the checklist.

Why this matters. Publication dates are not compliance deadlines. Knowing which documents are final, and which are drafts, keeps a migration plan honest.

Key terms 6
ML-KEM
Module-Lattice-Based Key-Encapsulation Mechanism, standardised by NIST in FIPS 203 for post-quantum key establishment.
ML-DSA
Module-Lattice-Based Digital Signature Algorithm, standardised by NIST in FIPS 204 for post-quantum signatures.
SLH-DSA
Stateless Hash-Based Digital Signature Algorithm, standardised by NIST in FIPS 205 for post-quantum signatures.
Harvest now, decrypt later
Recording encrypted traffic today in the expectation of decrypting it once a sufficiently capable quantum computer exists.
CBOM
Cryptographic bill of materials: an inventory of the algorithms, keys, certificates and libraries a system uses, and where each is used.
Crypto-agility
The ability to replace algorithms, keys and certificates through a tested process without redesigning the system.

Read: You are not migrating to post-quantum. Your CDN is.

These are publication dates, not deadlines for your organisation. Applicability depends on your systems and requirements. Drafts remain marked as drafts.

About these references

References are published by NIST: Federal Information Processing Standards (FIPS), Special Publications (SP), and Interagency or Internal Reports (IR).

Sources checked . Check the publisher's latest version and errata before making a migration decision.

0 selected · 7 shown

Final publication

FIPS 203 / ML-KEM key establishment

Defines the Module-Lattice-Based Key-Encapsulation Mechanism (ML-KEM) and its parameter sets.

Planning action and context

Planning action Inventory key-establishment dependencies and review available ML-KEM support.

Review the publisher’s current errata alongside the final publication.

Publication date

Read the primary publication
Final publication

FIPS 204 / ML-DSA digital signatures

Defines the Module-Lattice-Based Digital Signature Algorithm (ML-DSA).

Planning action and context

Planning action Inventory signing and verification dependencies, including long-lived signed data.

Review the publisher’s current errata alongside the final publication.

Publication date

Read the primary publication
Final publication

FIPS 205 / SLH-DSA digital signatures

Defines the Stateless Hash-Based Digital Signature Algorithm (SLH-DSA).

Planning action and context

Planning action Evaluate signature size, performance and protocol compatibility for relevant uses.

Algorithm selection also depends on protocol support and operational requirements.

Publication date

Read the primary publication
Final publication

SP 800-208 / LMS and XMSS stateful hash-based signatures

Specifies the Leighton-Micali (LMS) and eXtended Merkle (XMSS) stateful hash-based signature schemes and their multi-tree variants.

Planning action and context

Planning action Identify firmware and code-signing uses where a stateful scheme and its key-state management fit.

Each one-time key may be used only once, so signing keys need managed state that is never reused or restored from an old backup.

Publication date

Read the primary publication
Final publication

SP 800-227 / Using key-encapsulation mechanisms

Provides recommendations for implementing and using key-encapsulation mechanisms.

Planning action and context

Planning action Review the KEM integration design and its key-management assumptions.

Use this guidance alongside the applicable algorithm and protocol specifications.

Publication date

Read the primary publication
Final publication

IR 8545 / Fourth-round report: HQC selected

Reports on the fourth round of the post-quantum process and selects HQC as an additional key-establishment algorithm to be standardised.

Planning action and context

Planning action Track the HQC standard as an alternative to ML-KEM in key-establishment plans.

This is a selection report; the HQC standard itself is a separate, later publication.

Publication date

Read the primary publication
Initial public draft

IR 8547 / Post-quantum transition planning

NIST’s initial public draft outlines its proposed transition approach for quantum-vulnerable algorithms.

Planning action and context

Planning action Compare the draft transition approach with your system’s crypto inventory and assurance requirements.

Draft milestones include 2030 and 2035. Check the publication’s algorithm-specific scope; these are not a universal deadline for every system.

Publication date

Read the primary publication

Dates, not advice

Regulatory dates

Dates from EU law, the EU post-quantum roadmap and PCI DSS, each paired with the related control. Applicability depends on sector, size and jurisdiction; confirm it with counsel. Sources checked .

  1. NIS2 Directive (EU) 2022/2555 / National measures apply

    Member States apply the measures transposing the Directive from this date (Article 41).

    Control Cybersecurity risk-management measures under Article 21, including policies and procedures on the use of cryptography and, where appropriate, encryption (Article 21(2)(h)).

  2. DORA, Regulation (EU) 2022/2554 / Applies to EU financial entities

    The Regulation applies from this date (Article 64). Article 26 sets threat-led penetration testing for identified financial entities.

    Control For entities identified by their competent authority, threat-led penetration testing (TLPT) of critical or important functions on live production systems at least every three years.

  3. PCI DSS v4.0.1, Requirement 12.3.3 / Future-dated requirements become mandatory

    Requirements introduced in v4.0 as best practice are required from this date; v4.0.1 did not change it.

    Control Cryptographic cipher suites and protocols in use are documented and reviewed at least once every 12 months.

  4. Cyber Resilience Act, Regulation (EU) 2024/2847 / Manufacturer reporting obligations apply

    Article 14 applies from this date (Article 71).

    Control A process to notify actively exploited vulnerabilities and severe incidents affecting products with digital elements to the coordinating CSIRT and ENISA through the single reporting platform.

  5. EU coordinated PQC roadmap (NIS Cooperation Group) / First steps and initial national roadmaps

    Member States have implemented the First Steps and started transition planning and pilots for high- and medium-risk use cases.

    Control Cryptographic asset management and dependency maps in place, with a quantum risk analysis that includes the supply chain.

    A coordination roadmap addressed to Member States, not a legal obligation on organisations.

  6. Cyber Resilience Act, Regulation (EU) 2024/2847 / Main obligations apply

    The Regulation applies in full from this date (Article 71).

    Control Products placed on the EU market meet the essential cybersecurity requirements, and vulnerabilities are handled for the support period, including a machine-readable SBOM covering at least top-level dependencies (Annex I, Part II).

  7. EU coordinated PQC roadmap (NIS Cooperation Group) / High-risk use cases migrated

    The PQC transition for high-risk use cases is completed, and quantum-safe software and firmware upgrades are enabled by default.

    Control Post-quantum protection in place for high-risk use cases, and an upgrade path to PQC for systems expected to remain in use beyond 2030.

    A coordination roadmap addressed to Member States, not a legal obligation on organisations.

  8. EU coordinated PQC roadmap (NIS Cooperation Group) / Medium-risk use cases migrated

    The PQC transition for medium-risk use cases is completed, and for low-risk use cases as far as feasible.

    Control Remaining medium-risk systems migrated, with any low-risk exceptions recorded and owned.

    A coordination roadmap addressed to Member States, not a legal obligation on organisations.