Government Accountability Office (GAO): 24 Agencies Fail PQC

On October 6, 2026, the Government Accountability Office (GAO) released a report finding that none of the 24 major federal CFO Act agencies had fully addressed the three basic practices for preparing to migrate to post-quantum cryptography. Measured against Office of Management and Budget (OMB) guidance, only one agency fully completed its cryptographic inventory, none had an accurate funding estimate, and none had tested quantum-resistant algorithms. The report landed about two weeks before the October 22 deadline for civilian agencies to submit their migration plans to OMB under memorandum M-26-15.

For enterprise security leaders, this is not a government story to read and move past. It is a preview of your own readiness, because the reasons the agencies fell short, scattered cryptography, thin expertise, and waiting on vendors, are the same obstacles most organizations face. If institutions operating under a legal mandate, firm deadlines, and a multibillion-dollar cost estimate are this far behind, organizations without those forcing functions should assume they are further behind still.

Let’s unpack what GAO found, why the failures follow a predictable order, and what to do about it.

Key Takeaways

• GAO audited 24 major federal agencies and found none had fully addressed the three core post-quantum preparation practices.
• Only 1 of 24 fully completed a prioritized cryptographic inventory, and 19 used no automated discovery tools at all.
• 0 of 24 had accurate funding estimates, and 0 of 24 had tested post-quantum algorithms in their environments.
• The failures cascade: you cannot budget for a migration you have not scoped, and you cannot scope one you have not inventoried.
• The fix starts with an automated cryptographic inventory, followed by scoping, testing, and crypto-agility.

Executive Summary for Security, PKI, and Compliance Teams

If you lead one of these functions, here is the decision this report supports and the quick-reference action for it.

• Security and PKI teams: build a complete, prioritized inventory of systems using vulnerable cryptography, using automated discovery rather than manual spreadsheets.
• Finance and program teams: scope the migration from that inventory before producing a budget, since cost estimates built on incomplete inventories are unreliable.
• Engineering teams: stand up a test environment and begin validating quantum-resistant algorithms now, rather than waiting for vendors to declare readiness.
• Compliance teams: treat post-quantum readiness as a multi-year program with owners, milestones, and funding tied to identified systems.

What GAO Measured, and How Agencies Scored

GAO assessed the 24 agencies against three practices drawn from OMB guidance. The audit ran from February 2024 to September 2025.

Practice	Fully addressed	What GAO found
Prioritized inventory of systems with vulnerable cryptography	1 of 24	22 agencies left priority systems out, one had no inventory, and 19 used no automated discovery tools
Funding needed to move priority systems to post-quantum cryptography	0 of 24	21 agencies submitted estimates they said were not fully accurate, and three submitted none
Testing of post-quantum algorithms in agency environments	0 of 24	One agency identified vendor products to test but ran no tests, and 23 addressed neither

Read those results in order and the dominoes are clear. The inventory failure is not one problem among three. It is the root cause of the other two.

The Excuses Agencies Gave, and Why They Matter to You

The most useful part of the report is not the scores, it is the reasons behind them. GAO traced the gaps to four causes, and every one appears in enterprise environments too:

• Expertise: 18 agencies reported a lack of cryptography expertise and had no plan to fill it.
• Tooling: 15 said it was too early for automated discovery tools, or that they were waiting for CISA to identify some.
• Cost data: 11 said the lack of mature commercial products and pricing made funding estimates difficult to build.
• Testing: 16 said testing was premature because vendors were still adding the algorithms to their products.

GAO did not accept the testing excuse, and it is worth understanding why. OMB encouraged agencies to begin testing in November 2022, before NIST finalized FIPS 203 and its companion standards in August 2024, and open-source prototyping tools have existed for years. “The vendors are not ready” did not survive contact with the facts. The capability to start existed. The visibility and the will did not.

Why This Is Your Preview, Not Their Problem

Federal agencies had every reason to be ahead. Executive Order 14412 set hard deadlines, post-quantum key establishment by the end of 2030 and digital signatures by the end of 2031. OMB put the rough cost of migrating prioritized federal systems at roughly $7.1 billion. And a reporting deadline loomed. Even so, they could not produce a complete inventory, an accurate budget, or a single test.

Private enterprises have fewer forcing functions and the same underlying obstacles. The encouraging part is that the fix is not exotic and does not depend on waiting for anyone. The one agency that completed its inventory did so because it used the right approach, while 19 of those that failed used no automated discovery at all. That gap is the difference between a program and a guess.

What You Should Do Next

1. Start with an automated cryptographic inventory. Discover every system, key, certificate, and algorithm that depends on vulnerable cryptography, using tooling rather than tribal knowledge. A continuous cryptographic discovery and inventory is the step the agencies most often skipped, and the one everything else depends on.
2. Scope before you budget. Let the inventory drive your cost estimate, not the other way around. An inaccurate budget is what you get when you price a migration you have not fully mapped.
3. Test now, not when vendors declare readiness. Validate interoperability and performance in non-production environments today, so you discover gaps on your terms.
4. Prioritize by data lifetime and criticality. Focus first on long-lived confidential data and the systems that protect it, which are most exposed to harvest-now-decrypt-later.
5. Run it as a program. Connect identified systems to accountable owners, testing milestones, and funding, and build the crypto-agility to adopt and swap algorithms as standards mature, as part of a structured post-quantum readiness roadmap.

How Can Encryption Consulting Help?

The GAO report is, in effect, a checklist of what not to skip, and it maps directly to where Encryption Consulting helps.

CBOM Secure delivers the automated cryptographic discovery and inventory that the audit found almost entirely missing, finding vulnerable cryptography across code, cloud, and infrastructure and scoring quantum risk so you know which systems to prioritize. That inventory is what turns an inaccurate budget into a defensible one. For the systems that depend on certificates and keys, CertSecure Manager and our PKI and HSM services provide the lifecycle control and key protection a migration needs. And our 9-phase post-quantum readiness roadmap and PQC Center of Excellence turn the “multi-year program, not a project” framing into an owned, sequenced plan.

Conclusion

The quiet lesson of this report is not that the government is behind. It is that post-quantum readiness fails in a predictable order, and it starts with not knowing where your cryptography lives. Twenty-three agencies could not test, every agency struggled to budget accurately, and all of it traced back to inventories that were incomplete or missing.

You do not need a federal mandate to avoid that outcome. You need to answer one question before anyone forces you to: where does our cryptography actually live. The organizations that can answer it are already migrating. The ones that cannot are writing their own version of this report.

Frequently Asked Questions

What did the GAO post-quantum report find?

GAO found that none of the 24 major federal CFO Act agencies had fully addressed the three core practices for post-quantum preparation. Only one had completed a prioritized cryptographic inventory, none had accurate funding estimates, and none had tested post-quantum algorithms.

Why is cryptographic inventory the first step?

Because you cannot scope, budget, or migrate cryptography you cannot see. GAO’s findings show the failures cascade from an incomplete inventory, which is why every major guidance names inventory first.

Does this report only matter to federal agencies?

No. The obstacles GAO identified, scattered cryptography, limited expertise, and waiting on vendors, are common in the private sector. If agencies under a mandate are behind, enterprises without one should assume they are further behind.

What are the federal post-quantum deadlines?

Under Executive Order 14412, federal high-value systems must adopt post-quantum key establishment by December 31, 2030, and post-quantum digital signatures by December 31, 2031.

How should organizations start preparing?

Begin with an automated cryptographic inventory, scope the migration from it, test algorithms in non-production environments, prioritize long-lived data, and run the effort as a multi-year program with crypto-agility built in.