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Top 5 Root CA Key Signing Ceremony Mistakes to Avoid

A root CA key signing ceremony is the foundation of any Public Key Infrastructure (PKI). It’s a formal, controlled process where a root CA’s private key is generated, verified, and protected, with multiple participants overseeing each step to ensure trust, security, and compliance. Properly executed, it sets the standard for the entire certificate hierarchy. 

A well-planned ceremony includes:

  • Preparation: Developing a detailed script, securing the environment, and assigning roles. 
  • Role Separation: Engaging independent participants such as Security Officers, System Administrators, Auditors, and witnesses. 
  • Execution: Generating the key pair inside a Hardware Security Module (HSM) under strict controls. 
  • Verification: Checking all cryptographic parameters, fingerprints, and outputs before moving forward. 
  • Documentation & Archival: Capturing every step with signed logs, video/audio evidence, and secure storage of all artifacts. 

Even with these guidelines, mistakes happen. Here are the five most common pitfalls that can compromise a root CA ceremony—and why they occur. 

Even with clear steps in place, root CA ceremonies are not immune to failure. The process is complex, highly procedural, and often involves people who may be unfamiliar with such a formalized event. Even small oversights, whether due to lack of preparation, unclear responsibilities, or inadequate security, can create weaknesses that ripple through the entire PKI. Below are the most common mistakes that organizations make during a root CA key signing ceremony. 

Top 5 Mistakes for Organizations

Skipping Rehearsal or Dry Run

Many organizations go into the ceremony “cold,” treating it as a one-time event that doesn’t require practice. Participants walk in with scripts they’ve never used before, and steps that involve multiple people can feel confusing when performed live for the first time. 

Why does this happen? 

This happens because organizations underestimate how complicated the ceremony actually is. With multiple roles, precise cryptographic procedures, and strict compliance requirements, even a single pause or misstep can create confusion, cause delays, or, in the worst case, force the entire process to restart. 

Weak Role Separation and Oversight

A small team, or in some cases, just one or two people—ends up carrying out most of the critical actions. The same person may initialize the HSM, generate keys, and validate outputs. It’s important to have a separation of roles and even if they are directly involved in the ceremony, they oversee and verify all steps are done correctly.  

Why does this happen? 

This happens because organizations either don’t have enough staff trained for specific roles or believe that fewer participants will make the process faster. But when responsibilities overlap, there is no independent oversight. This introduces risk, since mistakes can go unnoticed and the opportunity for intentional misuse of the private key increases significantly. In a true ceremony, roles are designed to act as checks and balances against one another. 

Visual idea: Role matrix (columns = roles, rows = responsibilities). 

Skipping Validation and Verification Steps

The ceremony moves forward without confirming cryptographic details such as key length, algorithm selection, or fingerprint hashes. Sometimes, participants assume that the HSM outputs are automatically correct and skip the manual checks. 

Why does this happen? 

This happens because teams may be under pressure to complete the ceremony quickly or assume “the tool handles it.” But the reality is that even small errors—like generating a key with the wrong algorithm or not matching a fingerprint exactly—can invalidate the root. If these issues aren’t caught in the moment, the only solution is to restart the ceremony entirely, which is costly and undermines trust in the PKI.

Poor Documentation and Artifact Preservation

The ceremony takes place, but records are incomplete, inconsistent, or not securely stored. For example, video recordings may be missing, participant logs might not be signed, or generated artifacts may not be preserved in a tamper-evident way. 

Why does this happen? 

This often happens because organizations treat documentation as an afterthought, focusing only on the execution itself. But auditors, regulators, and relying parties may need proof of how the root was created years or even decades later. Without complete evidence, there is no way to prove that the ceremony was trustworthy, and the credibility of the root CA—and the PKI built on it—can be questioned. 

Visual idea: Image of a binder labeled “Root Ceremony Record” with signatures + video recording symbol.

Environmental or Physical Security Gaps

The ceremony is conducted in an unsecured or poorly controlled environment. Examples include holding it in a standard conference room, allowing mobile devices inside, or connecting the offline root CA system to a network for convenience. 

Why does this happen? 

This happens because physical security often feels secondary to the cryptographic steps. But the environment itself is part of the trust model. If unauthorized individuals can access the room, or if the root CA is ever exposed to the internet, the entire security model collapses. Once compromised, an offline root cannot be trusted again, and the whole PKI may need to be rebuilt. 

Visual idea: Illustration of a locked server room with a “No Internet” symbol over the root CA. 

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How Encryption Consulting Can Help?

Conducting a root CA key ceremony correctly requires expertise, planning, and strict adherence to best practices. Encryption Consulting provides: 

  • PKI Advisory Services 
  • End-to-end Planning and Design of your Key Generation Ceremony Onsite or remote facilitation to ensure flawless execution. 
  • Full documentation and archival support to meet compliance and audit requirements. 
  • Independent oversight and training so your team gains lasting confidence in the process. 

With Encryption Consulting, you can be confident that your Root CA ceremony is secure, auditable, and trusted for decades to come.

Conclusion

A root key signing ceremony is the origin of trust for your PKI. Skipping rehearsal, concentrating too much responsibility in a few people, rushing past verification, neglecting documentation, and failing to secure the environment are the most common ways ceremonies go wrong. These mistakes can have lasting consequences, which is why planning, rigor, and oversight are essential from the very first step. 

Why Today’s Code Signatures May Break Tomorrow and How CodeSign Secure Fixes It

Introduction

Consider the possibility that your program now has a digital signature that reads, “I’m authentic and safe.”  However, that identical signature can have no relevance in five years.  It’s similar to leaving a wax seal on a letter only to find out later that a machine has been created that can accurately duplicate it.

Quantum computing isn’t science fiction anymore. What used to be tucked away in academic papers is inching toward machines powerful enough to rip apart the math behind the cryptography we rely on, RSA, ECC, the works. When that happens, the guarantees behind “trusted” software updates and signed binaries start to unravel.

And here’s the kicker: attackers don’t need to wait. They can collect signed software today, stash it away, and patiently bide their time. This tactic has a name: Harvest Now, Decrypt Later (HNDL). Once quantum machines catch up, those carefully stored signatures become entry points. Imagine malware wearing a “valid” digital certificate mask, ready to walk straight through defences because the old math gave out.

Why Code Signing is Especially Exposed?

At its core, code signing is about one thing: trust. When you download an update or install a new app, the signature on that software is supposed to prove two things: who it came from and that it hasn’t been tampered with along the way. It’s like the digital version of checking the seal on a medicine bottle.

The problem is that today’s code signing almost always leans on RSA or ECC keys. Both of these depend on math problems that are tough for normal computers to crack but easy targets for a quantum computer. Once that barrier falls, the signature isn’t proof anymore, it’s just decoration.

And the risks aren’t abstract. Imagine a fake software update that looks perfectly legitimate because its forged signature checks out. Or malware dressed up with your company’s certificate, spreading under your name. Beyond the technical mess, the bigger hit is trust: customers, partners, and even regulators won’t care if you explain “quantum broke our crypto.” They’ll just see your brand on something unsafe.

The Countdown to Post-Quantum

NIST has been running the world’s biggest crypto bake-off for the past few years, testing, breaking, and finally picking the algorithms that are strong enough to survive quantum attacks. The first set of standards is already here, and the rest are on the way. That’s not theory anymore, that’s the clock ticking.

Most experts agree we’ve got a 3–5-year window before quantum machines start putting serious dents in today’s crypto. Sounds like plenty of time, right? The catch is that software doesn’t disappear when you release the next version. Signed code lives on in embedded devices, IoT sensors, industrial control systems, and medical gear, places where “just patch it” isn’t realistic.

This is why waiting is a losing strategy. A signature you generate today might still need to hold up a decade from now. If it can’t, then all that carefully built trust in your supply chain can evaporate overnight. The question isn’t whether you’ll need quantum-safe signing, it’s whether you’ll be ready before your attackers are.

Preparing for Quantum-Safe Code Signing

Getting ready for the post-quantum world isn’t about hitting a switch one day; it’s about laying the groundwork now. A few concrete steps make all the difference:

  • Cryptographic Inventory: You can’t fix what you don’t know about. Start by mapping out where your signing keys actually live, what algorithms they use, and which systems depend on them. Think of it as taking attendance. Every key, every cert, every signing process should raise its hand.
  • Crypto Agility: Hard-coding one algorithm into your setup is like pouring concrete over your lock and key. You want flexibility, so when new standards arrive, you can swap algorithms without tearing your systems apart. Build your signing processes in a way that supports change instead of dreading it.
  • Hybrid Approaches: Since PQC standards are still being fine-tuned, a smart interim move is to pair them with today’s algorithms. That way, you get the best of both: the trust people already rely on plus a hedge against quantum threats down the road.
  • Policy & Governance: Even the strongest algorithms are useless if keys are lying around unprotected. Lock them down with proper storage (think HSMs or secure services), enforce who can use them, and rotate them before they turn stale. Good rules and oversight keep mistakes and misuse in check.

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How CodeSign Secure Accelerates the Journey?

All the theory in the world won’t help if the tools you use for signing can’t keep up. That’s where our CodeSign Secure comes in; it’s built with the future in mind but solves today’s problems at the same time.

  • Built-in crypto agility: When NIST stamps the final PQC winners, you won’t be scrambling. Our tool is designed so you can shift to new algorithms without ripping apart your signing pipeline.
  • CI/CD integration: Modern development never sleeps, and neither should your security. Our tool seamlessly integrates with your CI/CD flow (such as Jenkins, Azure DevOps, GitLab, Bamboo, TeamCity, and others), ensuring that every build, release, and update is signed and protected before it leaves the door.
  • HSM & cloud CA support: Private keys are like crown jewels; you don’t leave them lying around. Our tool works with FIPS 140-2 Level 3 certified HSMs and cloud CAs to make sure those keys stay locked down but still accessible when needed.
  • Future-proof design: We’re already using PQC algorithms like LMS and ML-DSA, so when “quantum-safe” becomes the new normal, our tool is ready. No retrofitting required.
  • Reporting & audit: Visibility matters. Our tool gives you the logs, reports, and insights to know exactly which algorithms are in use, how keys are managed, and whether compliance boxes are ticked.

In short, our tool isn’t just another code signing tool; it’s your fast track to being quantum-ready without slowing down today’s release cycles.

Conclusion

Quantum isn’t some distant storm; it’s a train on the tracks. The good news? Organizations that start preparing now won’t just scrape through Q-Day; they’ll be in a stronger position to win trust when others are scrambling.

That’s the real story: code signing isn’t just about meeting today’s security checklists—it’s about making sure your software can still be trusted years down the line. Whether it’s medical devices, industrial controls, or everyday apps, signatures you create today may still be in play a decade from now.

This is where our tool, CodeSign Secure, fits as more than a tool; it’s the bridge between today’s trust anchors and tomorrow’s quantum-safe world. With crypto agility, PQC readiness, and full integration into how software actually ships, our tool makes sure the promise behind your signatures holds up, no matter what computing power comes next.

The software you sign today must still be trusted in a decade. Make sure your signatures are quantum safe.

Current Landscape of Post-Quantum Cryptography Migration

Encryption ensures the security of everything we do online. Whether logging into your bank, sending messages, or connecting to corporate networks, cryptographic protocols work silently to protect those interactions. However, the problem is that much of today’s protection, mainly RSA and ECC, was designed for classical computers. As quantum computing rises, these algorithms can eventually be broken. The threat becomes more serious with each passing day. The potential for “harvest now, decrypt later” assaults is already being anticipated by governments, businesses, and security professionals.

Classical algorithms, once the foundation of digital security, are becoming increasingly less relevant. Quantum computers, once purely theoretical, are now a hardware reality. Capable of solving certain mathematical problems exponentially faster than classical computers, they pose a threat to widely used cryptographic algorithms, such as RSA and ECC. For every organization that relies on cryptography to protect communications, transactions, and identities, the journey to post-quantum safety comes with promise, urgency, and an overwhelming number of challenges.

But where do things actually stand today? How far have we come in making the internet, VPNs, email, and certificates quantum-safe? The Post-Quantum Cryptography Coalition (PQCC) provides a clear answer by publishing monthly “State of the Migration” heatmaps that track the ongoing progress across these critical areas. These heatmaps serve as snapshots, illustrating how various security standards are evolving toward quantum safety. Let’s take a closer look at what they tell us.

Understanding the Heatmaps

Each PQCC heatmap is a visual representation that maps the progress of leading cryptographic protocols and standards as they transition to quantum-resistant methods. At first glance, the heatmap’s numeric codes can seem abstract, but each number tells a story about the status of post-quantum migration for a specific protocol and use case. A quick glance at any heatmap displays not only the current condition of each procedure, but also the subtle changes that occur month after month. These changes are more than just statistics; they represent indicators of industry momentum, goals, and obstacles that still need to be addressed.

understanding the heatmap

Each heatmap employs a numerical scale from 0 to 9, where zero represents either no progress or a consensus not to include PQC in a standard, and nine signifies broad adoption of post-quantum techniques in real-world deployments. The color spectrum, ranging from red tones for low scores to lush greens and purples for higher scores, enables viewers to interpret the maturity of each protocol’s PQC readiness instantly. This visual language is an effective way to track standards like TLS, SSH, and DNSSEC as they either advance or lag on the quantum safety path.

How the Heatmap Works

The heatmap is organized as a grid.

Rows

  • Major security standards and protocols (e.g., SSH, TLS 1.3, X.509, S/MIME, OpenPGP, IKE/IPSec, MLS, DNSSec).
  • SSH serves as the foundation for remote administration and secure server access, enabling encrypted file transfers and command-line interfaces that are essential to managing IT infrastructure. TLS 1.3 protects most internet traffic, ensuring safe communications for web browsing, banking, and online data transfers. X.509 digital certificates form the foundation of Public Key Infrastructure, authenticating users and devices for secure connections to websites and VPNs.
  • Standards like S/MIME and OpenPGP maintain email security. S/MIME provides end-to-end email encryption and digital signatures, which are essential for safeguarding business correspondence. OpenPGP, popular among privacy-conscious users, secures emails, files, and software with robust encryption and signing features.
  • On the network level, IKE/IPSec enables VPNs that guard data in transit between remote locations, mobile users, and cloud resources. Messaging Layer Security (MLS) is emerging to secure group messaging and collaboration platforms, while DNSSec adds integrity checks to domain name lookups, protecting the internet’s “address book” from tampering.

Columns

The columns in the heatmap are designed to indicate the status and maturity of each protocol’s migration toward post-quantum cryptography, allowing for a clear comparison of progress across different protection mechanisms.

  • Overall Range: Indicates the general maturity of migration for the standard.
  • Pure PQC Encrypt: Status of post-quantum encryption.
  • Hybrid PQC Encrypt: Status of hybrid approaches (combining classical and post-quantum methods).
  • Pure PQC Sig: Status of post-quantum digital signatures.
  • Hybrid PQC Sig: Status of hybrid digital signatures.

Each cell is filled with a numeric code, where higher numbers represent greater progress or adoption:

Monthly Heatmaps

The sections that follow provide a detailed breakdown of the monthly Heatmaps, beginning with March 2025, to illustrate the evolution of the migration to post-quantum cryptography.

March Heatmap

The March 2025 heatmap provides a snapshot of when major cryptographic standards began to take shape as the migration to PQC started to emerge. Most protocols are still in the early stages, with proposals being drafted, prototypes being run, and testing underway to determine how quantum-safe methods can be integrated into existing systems.

Some protocols stand out more than others. SSH, TLS 1.3, X.509, and S/MIME dominate the map, with scores ranging from 2 to 8. This illustrates a combination of early integration work and active development efforts. For example, during the PQC Standardization breakout session at IETF (Mike Ounsworth’s presentation, Austin 2025), researchers discussed real-world tests and integrations for these protocols, moving them beyond theory.

In contrast, TLS 1.2 remains stuck at zero. There’s a clear industry consensus that PQC won’t be added to this older standard. That means organizations still relying on TLS 1.2 should view this as a wake-up call; it’s time to redirect energy and investment toward TLS 1.3 or newer protocols that can support hybrid and quantum-safe encryption.

TLS 1.3, in particular, shows strong momentum. Pure PQ encryption already scores a 6, while hybrid PQ encryption hits 8, signaling that pilot deployments are underway. The IETF TLS Working Group’s draft on hybrid key exchange, which combines classical ECDHE with post-quantum KEMs like ML-KEM, is a significant step forward. This hybrid approach delivers the best of both worlds: the reliability of established classical methods with the resilience of quantum-safe algorithms. As a result, TLS 1.3 is quickly becoming the frontrunner for organizations preparing their infrastructures for the quantum era.

Meanwhile, OpenPGP and IKE/IPSec are making slower progress. They’re still in transition phases, with work focused on proposals and drafts rather than large-scale adoption. DNSSEC comes in lowest on the map, underscoring the challenges of adapting core internet infrastructure to post-quantum methods.

Transport issues add another layer of complexity. The TCP Initial Congestion Window continues to struggle with latency and efficiency. The IKE first packet, crucial for starting VPN sessions, hasn’t seen much improvement in reliability or security. And QUIC amplification protection, designed to block DDoS-style reflection attacks, continues to lag. Taken together, these underscore the fact that PQC migration isn’t just about new cryptographic algorithms; it also requires technical work at the network layer to ensure performance and security remain intact.

April Heatmap

april heatmap

By April, the heatmap begins to show visible momentum. Some protocols that were only in the planning phase a month earlier are now starting to move toward real adoption. SSH and IKE/IPSec take notable steps forward, especially with hybrid PQ encryption reaching a score of 8, indicating that testing and broader implementation are now underway.

TLS 1.3 continues to build on its strong position, maintaining high scores in both pure and hybrid PQ encryption, as well as in digital signatures. This steady progress reflects its role as the backbone of secure internet communication and its readiness to carry quantum-safe methods into production environments.

Other key building blocks, such as X.509 certificates and S/MIME, are also making progress. In fact, some parts are now marked as “integrated in libraries”, a clear sign that post-quantum methods are starting to move from academic drafts into the software tools developers actually use.

On the other hand, OpenPGP and Messaging Layer Security (MLS) continue to advance slowly. They’re not stalled, but their adoption pace is much more gradual compared to TLS or SSH. This highlights the uneven speed of progress across the ecosystem.

DNSSEC exhibits only slight movement, particularly in terms of signature readiness, but still remains near the bottom of the scale. This lag reinforces concerns about the fragility of domain name security in a post-quantum world. Without significant attention, DNSSEC risks becoming the weak link in an otherwise advancing security chain.

Transport layer issues remain relatively unchanged compared to March. Challenges surrounding TCP congestion control, IKE packet handling, and QUIC protections persist, underscoring that upgrading cryptography is only half the battle; network fundamentals also need to evolve in parallel.

Taken together, the April heatmap reflects a turning point: the community is no longer just drawing up plans but starting to execute them. Developers, implementers, and vendors are engaging more directly, signaling the start of broader PQC adoption across real-world systems.

May Heatmap

may heatmap

May’s heatmap reveals deeper integration progress and some adoption in key protocols. TLS 1.3 hybrid PQ encryption sees an increase, approaching full adoption, a signal that influential software libraries and major cloud providers are gearing up or already deploying quantum-safe cryptographic options.

SSH and IKE/IPSec maintain their strong hybrid PQ encryption scores, reinforcing their importance in securing infrastructure and communication. X.509 and S/MIME steadily advance with mixed progress in signature adoption and encryption capabilities. OpenPGP and MLS, although still slow, continue to advance in integration progress and experimental deployments.

DNSSEC remains one of the most lagging protocols, with low scores persisting. This highlights a systemic concern about quantum resistance in foundational internet infrastructure components.

Transport issues show incremental improvement, particularly in IKE packet handling, suggesting enhanced readiness in the secure network transport segment. May’s heatmap shows a surge in practical implementation efforts, backed by pilot deployments and an increase in positive feedback from real-world testing.

June Heatmap

june heatmap

June’s chart continues the positive trend, with most protocols maintaining or improving their standing. TLS 1.3 edges closer to broad adoption, especially for hybrid PQ encryption, with pure PQ encryption also showing strong traction.

SSH and IKE/IPSec remain leaders in PQC adoption among infrastructure protocols, further cementing their role in the migration roadmap. X.509 and S/MIME reach new milestones in signature and encryption integration, pointing to gradually expanding trust and usability in enterprise environments.

OpenPGP and MLS, despite slower progress, sustain steady improvements, reflecting ongoing experimental adoption in specialized or privacy-minded sectors.

DNSSEC’s persistent struggle to move beyond low scores remains a concern, highlighting the need for a focused and coordinated effort.

Transport-layer refinements, such as those in TCP congestion window and IKE first packet strategies, make slow but steady headway, which is critical for ensuring that PQC doesn’t introduce latency or reliability trade-offs. June’s heatmap reveals an industry that is increasingly confident in deploying PQC capabilities, driven by stronger software and interoperability support.

July Heatmap

july heatmap

The July heatmap represents the most recent and encouraging snapshot of the post-quantum cryptography (PQC) migration effort. It captures a pivotal moment where progress has shifted from cautious experimentation to confident and practical deployment.

At the forefront, TLS 1.3 stands as a clear leader. Its hybrid post-quantum encryption achieves a peak score of “9,” signaling broad industry deployment and a maturity that extends beyond theoretical validation. This indicates that quantum-safe configurations within TLS 1.3 are no longer confined to labs; they are actively protecting real web traffic, supported by major cloud providers, browser vendors, and critical internet infrastructure. Alongside this, the presence of pure PQ encryption and signatures has likewise solidified in key cryptographic libraries, providing developers with the tools needed to implement fully quantum-resistant communication channels.

SSH and IKE/IPSec, two protocols fundamental to infrastructure security and VPN connectivity, continue to gain steady adoption. Their hybrid PQ integrations have become more extensive and operational, reflecting a growing ecosystem readiness to embrace quantum-safe mechanisms in server authentication and secure remote access. This maturation ensures that critical internal networks and administrative functions receive early protection against the emerging quantum threat.

Meanwhile, standards such as X.509 and S/MIME are showing promising growth in library integration and real-world testing environments. These advancements mark a significant milestone, bridging the gap between foundational cryptographic frameworks and large-scale deployment. Although widespread adoption is still gathering momentum, the progress points towards a future where quantum-safe certificates and secure email communications will be routine components of enterprise cybersecurity.

On the other hand, OpenPGP and Messaging Layer Security (MLS) are still navigating the earlier phases of this journey. Their incremental advances underscore the varied pace within the PQC ecosystem, likely influenced by the diversity of their user bases and technical complexity. These protocols represent specialized yet vital sectors that will require continued focus and innovation to achieve full quantum readiness.

Among these developments, DNSSEC stands out as the consistent outlier. Its progress is negligible, reinforcing concerns about this critical element of internet infrastructure lagging significantly behind. Without urgent attention to quantum-safe DNS authentication, the broader cryptographic gains risk being undermined by vulnerabilities at the domain resolution level, creating a fundamental security bottleneck that the industry must address.

Transport-layer issues have also seen meaningful improvements, notably in IKE’s first packet handling. This signals that lower-level networking protocols are evolving to support the demands of PQC, ensuring that higher-layer protocols, such as TLS and VPN tunnels, can operate efficiently without introducing latency or instability. Addressing these transportation challenges is crucial to a seamless migration that maintains performance while enhancing security.

What do the Heatmaps teach us?

The heatmaps collectively offer valuable insights into the current landscape of post-quantum cryptography migration. TLS 1.3 is leading the way with rapid adoption, reflecting the web’s strong push toward quantum-safe security. Its progress is crucial, as TLS protects the vast majority of online communications and transactions. Infrastructure protocols such as SSH and VPNs are also making significant strides, ensuring that core systems and secure remote access channels are not left vulnerable during the transition.

Certificates, especially X.509, play a pivotal role in this ecosystem. Without quantum-resistant certificates, other protocols such as TLS and VPNs cannot operate securely, making the advancement of PQC essential for the comprehensive deployment of these protocols. However, not all areas are advancing at the same pace. Email and messaging protocols, including S/MIME and OpenPGP, are lagging and will require increased focus and industry collaboration to overcome their slower adoption rates. DNSSEC remains a particularly glaring weak point; its stalled progress poses a risk to the overall security framework, as secure domain name authentication is fundamental for trustworthy communications.

Lastly, the heatmaps send a clear warning that TLS 1.2, still in use in many environments, offers no path to PQC, and organizations clinging to this outdated protocol face growing security risks, underscoring the urgency of migrating to modern, quantum-safe alternatives.

These heatmaps aren’t just monthly updates. They showcase the collaborative efforts of researchers, vendors, regulators, and operations teams. They highlight the gap between an idea and a solution, as well as between hope and actual protection. For anyone planning a PQC strategy, these heatmaps serve as practical roadmaps. They guide upgrades, demonstrate the maturity of different standards, and indicate whether it’s safe to move quickly or whether it’s better to be cautious. If your systems rely on protocols still in “draft,” integration will be experimental. When the heatmap indicates a shift from adoption proposals, it signals that industry leaders are leading the way, and it’s time to follow suit.

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How can Encryption Consulting Help?

If you are wondering where to start your Post-Quantum Cryptography (PQC) journey, Encryption Consulting is here to guide you. Utilizing NIST-aligned planning, targeted risk reduction, and in-depth crypto discovery, our PQC Advisory Services enable you to transform your environment into an audit-ready, quantum-resilient infrastructure.

  • Comprehensive PQC Risk Assessment

    This foundational phase builds visibility into your cryptographic infrastructure. We identify systems at risk from quantum threats and assess the readiness of PKI, HSMs, and applications. Certificates, keys, algorithms, and protocols across on-prem, cloud, and hybrid environments are scanned. Key metadata such as algorithm type, key size, and expiration is collected, creating a detailed inventory of cryptographic assets to support risk assessment and planning.

  • Personalized PQC Strategy & Roadmap

    With visibility established, we engage stakeholders to assess quantum vulnerabilities and readiness for PQC transition. Cryptographic elements, especially RSA, ECC, and similar algorithms, are analyzed for their exposure to quantum threats. PKI and HSM configurations are reviewed, and applications with hardcoded cryptography are identified and addressed. The outcome is a comprehensive report detailing vulnerable assets, risk levels, and migration priorities.

  • Cryptographic Agility

    After identifying risks and setting priorities, we develop a tailored, phased strategy that emphasizes cryptographic agility, enabling your systems to support multiple algorithms and seamlessly transition as standards evolve flexibly. This approach aligns with business, technical, and regulatory requirements, incorporating agile system designs that allow algorithm updates without major disruptions.

  • Vendor Evaluation and Proof of Concept

    We help identify and test the right tools, technologies, and vendors to support your post-quantum goals. RFI/RFP requirements, covering algorithm support, integration, and performance, are defined, and leading PQC-capable vendors are shortlisted. Proof-of-concept testing is conducted in isolated environments to assess fit, with results summarized in a vendor comparison matrix and recommendation report.

  • Pilot Testing and Scaling

    Before full rollout, solutions are validated through controlled pilot tests to ensure readiness and reduce disruption. Cryptographic models are tested in sandbox environments, typically on one or two applications, to verify interoperability with existing systems. Feedback from IT, security, and business teams is incorporated to refine the plan. Following successful testing, a phased rollout gradually replaces legacy algorithms while maintaining security and compliance.

  • PQC Implementation

    With the strategy finalized, we execute a full-scale migration, integrating PQC into your live environment while ensuring compliance and continuity. Hybrid models that combine classical and quantum-safe algorithms enable a seamless transition. PQC support is deployed across PKI, applications, infrastructure, cloud, and APIs. We provide hands-on training, detailed documentation, and establish monitoring and lifecycle management to track cryptographic health, detect issues, and enable future upgrades.

Our services categorize data by lifespan and implement customized quantum-resistant protection for long-term confidentiality. We provide enterprise-wide crypto strategies and remediation plans to address weak or outdated algorithms. Migration to post-quantum algorithms is seamless, ensuring lasting resilience. We emphasize the development of crypto-agile PKI architectures and robust governance structures that define roles, responsibilities, and standards for cryptography in the post-quantum era.

Contact us at [email protected] to leverage our PQC Advisory Services and future-proof your cryptographic environment.

Conclusion

The journey toward post-quantum cryptography is both important and complex, and every organization needs to approach it with careful planning and consideration. Heatmaps give a clear and dynamic view of this changing landscape, offering both a big-picture overview and detailed insights into the progress of key cryptographic standards. By highlighting which protocols are moving forward quickly and which are still lagging, these heatmaps enable organizations to make informed decisions, set the right priorities, and adopt post-quantum solutions with confidence.

As quantum computing approaches reality, moving in time is not just a technical step, but a strategic one to protect digital trust and security. Using the insights from these heatmaps as a guide, organizations can turn uncertainty into opportunity and build strong, future-ready systems for the quantum era.

Compliance Trends of 2025

Introduction

In 2025, cybersecurity and regulatory compliance have become strategic priorities for organizations worldwide, transcending traditional check-the-box exercises to underpin business resilience and trust. Cyber threats, privacy concerns, and emerging technologies are prompting new laws and standards at a rapid pace. In parallel, stakeholders from investors to consumers expect organizations to not only secure data and systems but also demonstrate ethical governance and transparency.

This comprehensive overview explores key compliance trends shaping 2025, spanning data protection and privacy, encryption mandates, AI governance, breach disclosure, supply chain security, identity management, automation of compliance, and challenges in critical industries. The goal is to provide cybersecurity professionals, compliance experts, and technical stakeholders with a clear picture of the evolving global compliance landscape and practical insights for navigating the road ahead.

Global Data Protection and Privacy Regulations Evolve

Data protection regulations have continued to expand across the globe, with more countries and states enacting privacy laws. As of early 2025, 144 countries have established data protection or consumer privacy laws, covering roughly 79 to 82% of the world’s population. This represents a dramatic increase in just the last five years. In the United States, privacy regulation is shifting from a single-state phenomenon (California’s pioneering CCPA/CPRA) to a patchwork of state laws. 42% of U.S. states (21 states) have now passed comprehensive consumer privacy statutes as of 2025.

Critically, eight new state privacy laws take effect in 2025, including Delaware, Iowa, Nebraska, New Hampshire (all January 1), followed by others like Tennessee, Indiana, Montana, Oregon, Texas, and more rolling out later in the year. By year’s end, these laws will double the number of states with privacy frameworks from 16% to 32% of all states, covering an estimated 43% of the U.S. population. This rapid expansion signals a new era where data privacy is a baseline legal requirement across much of the U.S., not just a Californian-centric concern.

GDPR and international frameworks are maturing. In the EU, the landmark General Data Protection Regulation (GDPR) remains a global benchmark and is being refined and enforced rigorously. Regulators in the EU issued €1.2 billion in fines in 2024 (a decreased of 33 % from 2023)alone for GDPR violations, showing that enforcement has teeth. While GDPR’s core principles stay the same, there are discussions on simplifying compliance for SMEs and other refinements to ensure the law remains effective.

The UK, Post Brexit, is updating its own regime – the Data Protection and Digital Information Bill (often dubbed “UK GDPR”) is under review in 2025 to tweak requirements and reduce certain burdens while maintaining high standards. Outside Europe, many countries have introduced or bolstered privacy laws: e.g. India’s Digital Personal Data Protection Act (enacted 2023) is coming into force, and countries from Brazil to South Korea and Kenya have new or updated data protection statutes by 2025.

According to the UN, over 70% of countries now have data privacy legislation and another 10% are drafting laws, a nearly global adoption. This means organizations operating internationally face a variety of requirements (consent, data localization, breach notification, individual rights, etc.), and must keep up to date of regional nuances.

U.S. federal action and global alignment pressures. Despite the flurry of state level laws, the U.S. still lacks a single federal privacy law. However, public pressure is high 72% of Americans believe there should be more government regulation of how companies handle personal data, and over half of U.S. voters (in surveys) support a unified national privacy law.

The now-stalled American Data Privacy and Protection Act (ADPPA) showed bipartisan interest in Congress; while it didn’t pass, it outlined measures widely supported by the public (e.g., banning the sale of data without consent, data minimization, private rights of action). This indicates that federal standards could eventually emerge to harmonize the patchwork.

Internationally, frameworks like the OECD’s privacy guidelines and the Global Cross Border Privacy Rules (CBPR) system are gaining momentum, aiming to bridge differences and facilitate data flows between jurisdictions with mutual recognition. Notably, in 2023 the EU and U.S. agreed on a new Data Privacy Framework to permit trans Atlantic data transfers, replacing the invalidated Privacy Shield a critical development for multinational companies.

In Asia, cross border frameworks and regional agreements are also taking shape. Overall, the trend is toward greater global convergence in privacy principles, even as local compliance details proliferate.

Key implications for organizations:  Data protection compliance in 2025 requires a truly global outlook. Companies must track and implement a myriad of requirements from GDPR’s strict consent and data subject rights, to state laws granting rights like opt-outs of sales or AI profiling. They should expect more frequent updates and new laws, for example, at least 264 regulatory changes in privacy were recorded globally in a single month (May 2025), underscoring how fast moving this space is.

Enforcement is intensifying not just via fines but also via court rulings and cross border cooperation among regulators. Businesses should invest in robust privacy programs such as conduct data mapping, update privacy notices, enable consumer rights request workflows, and ensure a “privacy by design” approach for new products. The growing public awareness and concern about privacy (a majority in many countries are worried about how their data is used) means compliance is also key to maintaining customer trust and reputation. In short, protecting personal data is no longer just a legal checkbox, it’s part of core operations and brand integrity.

Encryption and Cryptographic Compliance

Encryption moves from best practice to baseline requirement. As cyber threats escalate, encryption of sensitive data has become a centerpiece of compliance and risk mitigation strategies. Organizations increasingly recognize that robust encryption both for data at rest and in transit can dramatically reduce the impact of breaches. The 2025 Global Encryption Trends Study found that 72% of organizations implementing an enterprise encryption strategy experienced reduced impacts from data breaches, highlighting how effective encryption is in safeguarding data.

Conversely, companies lacking encryption protections suffer more severe breaches; one analysis noted that organizations with comprehensive encryption in place are 70% less likely to experience a major data breach compared to those without full encryption coverage.

Regulators are taking notes. Many data protection laws explicitly or implicitly require encryption of personal data. GDPR, for instance, cites encryption as a recommended safeguard (and breach notifications can be avoided if stolen data was encrypted). In the U.S., state laws and sector regulations (like finance and healthcare) increasingly mandate encryption for certain data.

Even historically lenient regimes are stiffening: a proposed 2025 update to the U.S. HIPAA Security Rule would make encryption of electronic protected health information a mandatory requirement (where previously it was an “addressable” implementation). Similarly, the EU’s NIS2 Directive lists “policies for the use of cryptography and encryption” as a required security measure for essential services. In short, what was once optional is now expected to encrypt your data or face compliance consequences.

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Key Findings from the 2025 Encryption Report

This year’s Global Encryption Trends report (and related studies) also reveal several emerging themes in cryptographic compliance:

  • Encryption adoption is at all time highs: Enterprise adoption of encryption has surged, with more organizations applying encryption consistently across databases, applications, and cloud services. A Ponemon Institute survey noted that the past year saw the largest increase in encryption deployment in over a decade, reflecting both regulatory pressure and board level attention on data security. However, challenges remain in managing encryption keys, discovering all sensitive data to encrypt, and integrating encryption across hybrid cloud environments.
  • Automation and AI in key management: About 58% of large enterprises now leverage AI or advanced automation for encryption key management and compliance tasks. This includes using machine learning to rotate keys, detect anomalous access to cryptographic modules, and streamline encryption deployment. Automation helps address the complexity of managing thousands of keys and certificates, an area highlighted in audits as a common weakness. The trend also ties into crypto agility; organizations are investing in tools to automatically update or swap out encryption algorithms and keys when required (for example, in response to a compromise or an algorithm being deprecated).
  • Postquantum cryptography (PQC) readiness: A prominent theme in 2025 is preparation for the quantum computing era. While powerful quantum computers capable of cracking today’s encryption (like RSA or ECC) are not here yet, the “harvest now, decrypt later” threat looms large. In the Thales 2025 Data Threat survey, 63% of security professionals flagged “future encryption compromise” by quantum attacks as a major concern, and 58% are worried about adversaries harvesting encrypted data now to decrypt once quantum capabilities arrive.
  • Standards bodies are responding: NIST released new post quantum encryption standards (e.g. CRYSTALS Kyber) and a transition roadmap in 2024, recommending phasing out RSA/ECC by 2030 and ceasing their use entirely by 2035. Businesses are beginning to act. Over half of organizations (around 57–60%) report they are prototyping or evaluating PQC algorithms in 2025, and nearly half are assessing their current cryptographic inventory to identify where upgrades will be needed. Additionally, 45% say they are focusing on improving crypto agility, ensuring they can swap algorithms easily when required. Regulators may soon ask about quantum readiness in risk assessments, so early movers aim to be prepared. In some jurisdictions, government agencies have mandates to inventory and transition crypto by set deadlines signaling what may eventually trickle down to the private sector.
  • Encryption and digital sovereignty: As data protection laws proliferate, encryption is seen as a tool to enable compliance with data residency and sovereignty requirements. The Thales report highlights a growing emphasis on “who controls data and encryption keys.” With 76% of enterprises using multiple public cloud providers, organizations are asserting control via techniques like BYOK (Bring Your Own Key) and HYOK (Hold Your Own Key) encryption, where the enterprise retains custody of encryption keys rather than the cloud provider. This ensures that even if data is stored overseas or in the cloud, the company can prevent unauthorized access (including from cloud admins or governments) by withholding keys.

In 2025, 42% of organizations identified strong encryption and key management as key enablers of digital sovereignty goals (e.g., ensuring compliance with EU data transfer rules). Expect to see more solutions that allow companies to localize keys, use hardware security modules (HSMs), or employ techniques like homomorphic encryption to comply with jurisdictional requirements while still leveraging global services.

Regulatory Compliance for Cryptography

Regulations are increasingly prescriptive about cryptographic standards. For example, many laws and industry standards now specify using strong encryption algorithms (e.g., AES256, TLS 1.3) and deprecating outdated protocols. The U.S. Federal Trade Commission’s Safeguards Rule and various state laws require encryption for personal information either by law or effectively as the standard of care. The Payment Card Industry Data Security Standard (PCI DSS) 4.0 (effective March 2025) mandates encryption of cardholder data both in transit and at rest with specific technical requirements.

In healthcare, as noted, upcoming rules would remove flexibility and demand encryption and MFA outright for all systems handling patient data. Governments are also setting expectations: the U.S. White House issued directives for federal agencies to adopt quantum resistant cryptography in the coming years, and the EU’s Cybersecurity Agency (ENISA) has guidance for state-of-the-art cryptographic controls under the NIS2 directive.

Organizations should track these developments closely. Noncompliance can be costly beyond breach risk, failing to meet encryption requirements can draw fines or legal liability. On the upside, implementing strong encryption not only meets compliance obligations but also can reduce breach notification obligations (if data is properly encrypted, many laws exempt the incident from public disclosure).

For 2025 and beyond, encryption is both a compliance imperative and a business differentiator, demonstrating to customers that their data is safe. Firms should conduct crypto audits, ensure proper key management (with separation of duties and backups), and stay updated on cryptographic policy (for instance, any government restrictions on encryption use or algorithms allowed for certain data exports).

AI Governance and Algorithmic Transparency Regulations

Regulators tackle the AI revolution. Artificial Intelligence (AI) has seen explosive adoption, from machine learning in enterprise analytics to generative AI models transforming business processes. This wave has prompted urgent calls for governance to ensure AI is used responsibly, fairly, and safely. In 2025, we are witnessing the rollout of the world’s first comprehensive AI regulations.

The European Union’s AI Act was finalized as Regulation (EU) 2024/1689 and is being phased in over the next few years. The EU AI Act takes a risk based approach: it bans certain “unacceptable risk” AI uses outright (e.g., social scoring, exploitative techniques) starting February 2025 for some provisions, and imposes strict obligations on “high risk” AI systems (such as those used in critical infrastructure, employment decisions, credit scoring, medical devices, etc.

High risk AI providers and deployers will need to implement conformance assessments, transparency, human oversight, and robust risk management for their systems. For example, AI systems in recruitment or loan approvals must be tested for bias and their outcomes traceable. The Act also mandates transparency for AI in general: users must be informed when they are interacting with an AI (rather than a human), and AI generated content (like deepfakes) should be labeled as such in many cases. Some requirements start in 2025 (e.g. certain transparency rules and voluntary codes of conduct), while full compliance for high risk systems will be required by 2026 or 2027 after implementation periods.

The EU AI Act is ground breaking, it is the first major AI rulebook and is expected to influence regulations globally similar to how GDPR influenced privacy laws.

In the United States, there isn’t a single AI law yet, but regulators are using existing powers and guidelines to rein in AI. The FTC (Federal Trade Commission) has warned that it will treat biased or deceptive AI outputs as potential violations of consumer protection law (for instance, if an AI decision algorithm unfairly discriminates in lending, that could be an “unfair practice”). The U.S. Equal Employment Opportunity Commission (EEOC) has similarly cautioned employers that using AI hiring tools that have a different impact could violate discrimination laws.

We also see targeted legislation cropping up in the US, for example, the “TAKE IT DOWN” Act and other bills in Congress seek to criminalize certain malicious deepfakes (particularly sexually explicit deepfakes or those intended to incite violence). Another proposed bill would mandate that AI generated content be watermarked or carry a disclosure. While these haven’t passed as of 2025, they indicate bipartisan concern about AI misuse.

At the state level, New York City implemented a first of its kind law (effective 2023–2024) requiring companies to conduct bias audits on AI hiring tools and to notify candidates when AI or algorithms are used in hiring decisions. Other jurisdictions are considering similar algorithmic accountability measures, especially in employment and credit contexts.

Cybersecurity Disclosure and Incident Reporting Mandates

Mandated breach disclosure on the rise. One of the clearest compliance trends in cybersecurity is the move toward mandatory disclosure of cyber incidents. Gone are the days when companies could quietly handle breaches; regulators now demand timely reporting to authorities, investors, and affected individuals. In the United States, the Securities and Exchange Commission (SEC) implemented a landmark rule in 2023 (phased into 2024) that requires publicly traded companies to disclose material cybersecurity incidents to the market within 4 business days of determining an incident is material.

Starting in late 2023, companies must file an 8K report detailing the nature and impact of a major cyber incident, for example, a significant data breach or system outage that investors would consider important. The only allowed delay is if the U.S. Attorney General certifies that immediate disclosure would pose a grave risk to national security or public safety. By late 2025, even smaller reporting companies will be coming into compliance with these SEC requirements.

In addition, the SEC now requires periodic disclosures about a company’s cyber risk management, governance, and board oversight in annual 10K reports. This includes identifying which board committee is responsible for cybersecurity. In fact, the percentage of S&P 500 boards that lacked a designated cybersecurity committee dropped from 15% in 2021 to just 5% by 2024 after these rules 95% now explicitly assign cyber oversight at the board level, partly due to the SEC’s emphasis on governance accountability.

Fast incident reporting to regulators and stakeholders: Beyond the SEC’s investor focused rule, governments are imposing breach reporting in critical sectors. The U.S. enacted the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) in 2022, and by October 2025 the implementing regulations are expected to take effect. CIRCIA will require companies in designated critical infrastructure sectors (e.g. energy, healthcare, finance, transportation, and others vital to national security) to report substantial cyber incidents to the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) within 72 hours, and ransomware payments within 24 hours.

New industry specific disclosure rules are also emerging. The U.S. Department of Defense now requires defense contractors to promptly report cyber incidents that affect DoD information, or risk losing contracts. State regulators are joining in, for example, the New York Department of Financial Services (NYDFS) Cybersecurity Regulation requires regulated financial institutions to notify NYDFS of certain cyber events within 72 hours. In healthcare, HIPAA has long required breaches of health data affecting 500+ individuals to be reported to HHS and the public within 60 days; now, the trend is toward even faster reporting and greater transparency (some proposed federal legislation would tighten health breach notice timelines).

Public disclosure and communication: Another aspect is disclosure to the public and affected individuals. Privacy laws like GDPR mandate that if personal data is breached and there’s a high risk to individuals, they must be notified “without undue delay.” Many of the new state privacy laws in the U.S. also contain breach notification provisions or rely on existing state breach laws (which typically require notice to residents within 3060 days of discovery, with some variations). The result is that companies suffer reputational damage if they don’t handle breach communications well, delay or obfuscation can lead to regulatory fines on top of the incident itself.

For instance, in 2023, several companies were fined by European regulators for failing to notify customers of breaches in a timely manner. In 2025, with the SEC requiring disclosure of material incidents, we will see more companies making public statements via filings, which in turn could trigger investor lawsuits or drops in stock price if the incident is serious. This creates a new incentive to ensure strong cyber defenses: the market will directly penalize companies that get breached, in addition to regulatory penalties.

Cybersecurity as a governance and compliance issue: These disclosure requirements are forcing executive teams and boards to be directly involved in cybersecurity oversight. Since a major incident must be reported and will become public quickly, boards are asking: are we prepared to handle a breach? Compliance now means having not just technical safeguards but also clear incident response processes, internal escalation paths, and decision frameworks for what is “material”.

Interestingly, the SEC rule’s requirement to disclose how the board oversees cyber risk has led many companies to improve their governance structure (e.g., establishing a cyber risk committee or adding cyber to the audit/risk committee charter). Nearly 77% of large U.S. companies now say cybersecurity is explicitly an audit committee responsibility, up from just 25% in 2019 a dramatic shift in a few years. This means more directors are getting educated on cyber, and companies are conducting board level cyber reviews and tabletop exercises.

Preparing for the new normal: To comply with these mandates, organizations should ensure they can detect incidents quickly (you can’t report what you don’t know about). This means robust monitoring and threat detection capabilities. They should establish criteria for what constitutes a reportable incident (material impact, certain compromised data, etc.) aligned with the laws that apply to them.

Having an incident response plan that includes notification steps is crucial, for example, who contacts regulators, who drafts the public statements, and how to get accurate information while under pressure. Many companies are also securing cyber insurance, which often requires notification within strict timeframes to the insurer as well. The emphasis should be on transparency and accuracy; several regulators have indicated that while initial reports can be sparse, they expect timely follow ups as more is learned.

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Integrating Compliance with Broader Governance

Cybersecurity joins the ESG agenda. In 2025, cybersecurity and data protection are no longer seen as purely technical issues they are now squarely part of the Environmental, Social, and Governance (ESG) considerations for organizations. ESG compliance traditionally focuses on environmental sustainability, social responsibility, and corporate governance ethics. Cybersecurity has forced its way into this conversation under the “Governance” pillar (and arguably the “Social” pillar, when considering privacy as a consumer right). Investors, rating agencies, and regulators are evaluating how companies manage cyber risks as an indicator of good governance.

In a recent survey, nearly 4 out of 5 investors (79%) said boards of directors should demonstrate expertise in cybersecurity (as well as climate and other emerging risks) and detail their efforts to mitigate those risks. In other words, stakeholders expect top leadership to treat cyber risk on par with financial or strategic risks. This is a big shift,  a decade ago, cybersecurity rarely made it into annual reports or investor discussions, whereas now a major breach can destroy stock value and stakeholder confidence overnight, which investors recognize.

Regulatory drivers on the ESG side: New regulations in the ESG realm implicitly incorporate cyber and privacy. The EU’s Corporate Sustainability Reporting Directive (CSRD), effective 2025 for large companies, requires extensive disclosures on governance and risk management, which would include how companies handle risks like cybersecurity to ensure business continuity and resilience. The European Sustainability Reporting Standards (ESRS) under CSRD explicitly ask companies to report on “business conduct” matters, data security and privacy practices can fall here as part of social and governance factors.

Furthermore, regulations such as the EU Digital Operational Resilience Act (DORA) for financial entities, while primarily about cyber/operational risk, also connect to ESG by emphasizing operational resilience and stakeholder impacts of disruptions (resilience is increasingly viewed as a sustainability issue, a business can’t be sustainable if it’s constantly breached or disrupted).

Meanwhile, SEC climate disclosure rules (though currently on hold) have made boards aware that comprehensive risk disclosure is becoming the norm; many believe cyber risk disclosure could be next on the SEC’s agenda beyond the incident reporting rule. Even without explicit rulemaking, the SEC’s existing guidance calls for material cyber risks to be disclosed in annual reports if they could impact investors.

From a social responsibility perspective, safeguarding customer data is an ESG issue. Large data breaches can harm customers (identity theft, privacy invasion), so companies are being evaluated on how well they protect data, much like they’d be evaluated on product safety. Rating agencies that provide ESG scores often include data privacy and security as a subfactor in the “Social” or “Governance” score.

For instance, MSCI and Sustainalytics ESG ratings incorporate whether a company has had recent data breaches or fines for privacy violations, and what policies it has in place for information security. Thus, good cybersecurity is rewarded with better ESG scores, and conversely, a breach or compliance failure can hurt an ESG rating.

In summary, the trend for 2025 is that cybersecurity compliance is not siloed; it is part of the larger ESG narrative. Organizations that excel in this area treat cybersecurity as a core element of corporate governance, openly report on their security posture and improvements, and frame data protection as central to their social responsibility. This not only meets emerging compliance demands but also appeals to investors and customers who are increasingly valuing digital trust as an asset.

Supply Chain and Third-Party Risk Management Compliance

Third-party cyber risk under scrutiny: High profile incidents in recent years (from the SolarWinds backdoor to breaches via HVAC contractors) have taught regulators that a company is only as secure as its weakest link – often a supplier or service provider. In 2025, compliance requirements are zeroing in on supply chain cybersecurity. Organizations are expected to manage risks not just within their walls, but across a web of vendors, cloud providers, software suppliers, and partners.

According to a global survey of CISOs, a whopping 88% of organizations are worried about cyber risks stemming from their supply chain, and with good reason: over 70% had experienced a significant cybersecurity incident originating from a third party in the past year. These can include breaches caused by compromised software updates, vendor credentials being stolen, or data being stolen from a less secure partner.

Despite the concern, the same survey revealed a dangerous gap,  less than half of organizations monitor even 50% of their suppliers for cybersecurity issues. In other words, visibility into third party risk is poor. Regulators see this gap and are responding by mandating more rigorous third party risk management (TPRM) practices.

Regulations mandating supply chain security: The EU’s NIS2 Directive is a prime example of codifying supply chain security obligations. NIS2, which as discussed applies to a broad range of critical and important entities, makes comprehensive supply chain risk management mandatory (no longer just guidance). Companies under NIS2 must identify and assess cyber risks associated with each supplier and digital service provider, implement appropriate security controls based on those assessments, and continuously monitor supplier risks. This effectively forces organizations to have a vendor security assessment program.

Additionally, NIS2 emphasizes supplier accountability, it expects organizations to flow down cybersecurity requirements to suppliers via contracts, set clear security expectations, and conduct regular audits of suppliers. In fact, Recital 85 of NIS2 suggests that major suppliers could be held jointly responsible if their negligence leads to incidents. This is a significant development, the era of finger pointing is ending, and both customers and suppliers may share liability for security lapses. NIS2 also requires coordination with suppliers during incident response, meaning you must have communication channels ready for when an incident involves a third party.

In the financial sector, the EU’s Digital Operational Resilience Act (DORA), effective January 2025, similarly requires banks and financial entities to manage ICT third party risk. DORA obliges firms to inventory their critical ICT providers, assess risks of outsourcing, and ensure contractual provisions for security and incident reporting. It also gives regulators power to oversee critical tech providers (e.g., cloud providers serving banks might be designated and directly supervised). The UK and other jurisdictions are considering similar rules, where cloud and technology providers for banks could be subject to regulation due to systemic risk concerns.

Software and hardware supply chain rules: Another dimension is product security: laws like the EU Cyber Resilience Act (CRA) (adopted in 2024, with enforcement by 2027) will require that manufacturers of digital products (software, IoT devices, etc.) build in cybersecurity and provide vulnerability disclosure mechanisms. While CRA’s full effect is a couple years out, its presence influences compliance strategy now, especially for any company that sells tech in Europe.

It basically says insecure products are noncompliant products. In the U.S., new IoT cybersecurity labeling (“Cyber Trust Mark”) is being launched so consumers can tell which devices meet certain security criteria. Governments have also banned or restricted certain high risk vendors from supply chains for security reasons (for example, bans on Chinese telecom equipment like Huawei in critical networks). Compliance now entails ensuring none of your suppliers are on prohibited lists and that you aren’t using components with known security issues.

Third-party risk management (TPRM) best practices are turning mandatory. Many organizations have implemented TPRM programs involving questionnaires, audits, and contract standards. Now these are being cemented into compliance obligations. As noted, NIS2 and others expect to see security requirements in contracts, meaning procurement and legal teams must include clauses for things like data handling, incident notice (e.g. requiring a vendor to notify you within X hours if they have a breach), the right to audit, and possibly minimum security certifications (like ISO 27001 or SOC 2).

Government and industry standards increasingly call for continuous monitoring of vendor security, not just an annual check-the-box. Given that only 26% of organizations integrate vendor incident response presently, this is a growth area. Automated tools that scan suppliers’ external cyber posture (using ratings services, etc.) are being adopted to meet the continuous monitoring expectation.

Implications for compliance programs: Companies should enhance their third-party risk assessments before regulators force the issue. This means cataloging all critical vendors and partners, classifying them by risk tier (e.g., who has access to sensitive data or systems), and performing due diligence on each. Due diligence can range from sending a detailed security questionnaire, to reviewing their audit reports, to onsite assessments for the most critical ones.

Many firms are now requiring vendors to have security certifications or assessments, e.g., a cloud provider with SOC 2 Type II report or an ISO 27001 certification to provide assurance. It’s also prudent to monitor news and threat intel for breaches at your suppliers, since sometimes you learn of an issue from media before the vendor notifies you.

Another key step is updating contracts, ensure new and renewal contracts include cybersecurity clauses. For instance, a clause that the vendor maintains a minimum security program, complies with relevant standards/laws, notifies of incidents within e.g., 48 hours, cooperates in investigations, and perhaps provides indemnity for security incidents. These contractual measures not only move you toward compliance (and align with laws like NIS2) but also protect you if something goes wrong.

Identity and Access Management and Zero Trust Mandates

Identity and access management (IAM) as a compliance cornerstone. Many cybersecurity frameworks and regulations now prioritize IAM controls like never before. The reasoning is simple: most breaches involve compromised credentials or abuse of excessive access. In 2025, virtually every major cyber regulation or standard includes requirements for strong authentication and access governance.

For example, the EU NIS2 Directive explicitly mandates the use of multifactor authentication (MFA) “where appropriate” as a baseline control for affected entities. It also calls for strict access controls and periodic review of accounts.

Likewise, proposed HIPAA Security Rule changes in the U.S. health sector will make MFA mandatory for any access to patient data systems, and require formal identity proofing and authorization procedures for healthcare workforce members.

These moves mirror what has already been best practice: Multifactor authentication is now effectively required in many industries, e.g., the Payment Card Industry (PCI) standards require MFA for administrators and remote access, the NYDFS bank cyber rule requires MFA for any access to sensitive data, and cyber insurers often insist on MFA as a condition of coverage. Regulators have explicitly stated that single-factor (password-only) logins for privileged or sensitive access are no longer acceptable.

Specific mandates for IAM controls

A clear trend is turning what used to be recommendations into requirements:

  • Multifactor Authentication (MFA): As noted, MFA is required or strongly implied by many regulations now. For instance, NIS2’s 10th baseline measure specifically lists using multifactor or continuous authentication solutions for access to sensitive systems. The proposed HIPAA update would require MFA for administrators and remote access to health data systems. The U.S. President’s executive order in 2021 required MFA across all federal systems, and many state laws (like recent insurance data security laws based on the NAIC model) require MFA for access to nonpublic information. In practice, regulators expect MFA to be everywhere: one survey found that implementing MFA can prevent 99.9% of account compromise attacks, a statistic often cited by security agencies. So, compliance auditors now frequently ask, “Do you have MFA enabled for all users, especially privileged and remote access?”
  • Least privilege and access reviews: Regulations also demand strict access governance. NIS2, for example, requires policies for access controls and that companies maintain an overview of all assets and ensure proper use and handling of sensitive data with role-based controls. Many standards require regular user access reviews, e.g., checking quarterly that ex-employees are removed and current users have appropriate rights. In the financial industry, regulators like FFIEC emphasize role-based access controls and immediate removal of access when no longer needed. We also see requirements for privileged access management (PAM), ensuring that powerful accounts are closely managed (unique credentials, MFA, and monitoring of admin sessions).
  • Network segmentation and device trust: Zero Trust is not just about user identity but also device and network. Compliance is reflecting this by asking for segmentation of networks to limit lateral movement. For instance, the updated HIPAA proposal explicitly calls for network segmentation and periodic network testing as requirements, effectively urging healthcare entities to implement Zero Trust style network controls (splitting clinical devices, corporate IT, etc., and controlling communications between them). Other critical infrastructure guidelines, such as U.S. electric power NERC CIP standards, require segmentation between control systems and business networks. Additionally, ensuring only trusted devices connect (through device certificates or verification) is becoming part of the compliance checklist in highersecurity environments.
  • Government and industry frameworks pushing Zero Trust: Even if not codified in law, many organizations are pursuing Zero Trust under the influence of government frameworks. For example, CISA’s Zero Trust Maturity Model provides a roadmap that some sectors are adopting as substandard. The U.S. Department of Defense released a Zero Trust Strategy in 2022, aiming for its networks to meet advanced Zero Trust capabilities by 2027, this trickles down to defense contractors who will need to align with those practices. Industry groups like the Cloud Security Alliance have Zero Trust guidelines that can shape compliance audits for cloud services. The general expectation emerging: “default deny”, assume every access request could be malicious until proven otherwise.
  • Identity governance and compliance: Regulators also care about how organizations manage identities over their lifecycle. For example, ensuring onboarding and offboarding processes are in place (so accounts are created with correct roles and promptly deactivated upon employee exit) is often audited. Some privacy regulations intersect with IAM too, e.g., GDPR’s data minimization and security principles mean users should only access data they need, and logs/monitoring of access might be needed to prove compliance. Identity is at the center of both security and compliance; it’s no surprise that 80% of data breaches involve compromised or stolen credentials, so addressing identity issues mitigates compliance risk across the board.

Impacts and actions

For compliance officers and CISOs, aligning with these IAM and Zero Trust mandates means:

  • Implement MFA whereever feasible: This is step one and likely the highest ROI security control. If there are legacy systems that can’t support MFA, plan to phase them out or put compensating controls. Document your MFA coverage, because auditors will ask.
  • Enforce least privilege rigorously: Implement role based access control (RBAC) where possible and keep a tight process for privilege elevation (and only grant what’s needed, temporarily if possible). Use identity governance tools to automate access reviews and certifications, this both improves security and generates evidence for compliance. Data shows organizations with robust RBAC are 50% less likely to experience a major incident due to misuse of credentials.
  • Adopt elements of Zero Trust Architecture: This includes segmenting networks (don’t have flat networks where an intruder can reach everything), verifying device health (through endpoint security enforcement), and deploying continuous monitoring of user behavior (UEBA) to detect if a legitimate account is acting suspiciously. While not all regulations explicitly state, “Zero Trust,” implementing it will inherently satisfy many specific controls that are required.
  • User training and culture. People are part of IAM too, training users on good password hygiene, phishing awareness (since MFA isn’t foolproof, e.g., MFA fatigue attacks). Many regulations (like NIS2 and others) require cybersecurity awareness training for staff, and emphasizing identity-related threats (phishing, social engineering) in those trainings helps meet compliance and reduce incidents.

In summary, 2025’s compliance environment essentially demands that organizations prove they know who is accessing what, when, why, and how at all times. This identity-centric approach is the crux of Zero Trust. Forward looking organizations are not treating Zero Trust as just a buzzword, but translating it into concrete policies and controls that auditors can verify from MFA dashboards to access review records and micro segmentation diagrams.

In doing so, they not only comply with current rules but are better prepared for the future, where even more stringent access control requirements are likely to appear (for instance, we might see insurance regulators or others codify Zero Trust explicitly).

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Industry Specific Compliance Challenges

While many compliance trends are broad based, certain challenges are unique to specific industries. In 2025, industries like financial services, healthcare, and critical infrastructure face tailored regulations and threats that require specialized attention. Below, we examine a few industry specific landscapes:

Financial Services

Financial institutions have long been heavily regulated, but now cybersecurity and technology risk are at the forefront of banking compliance. Banks, insurers, and investment firms not only must protect sensitive customer data (to comply with privacy laws and GLBA in the U.S.) but also ensure the resilience of critical financial systems against cyberattacks.

Digital Operational Resilience in the EU: The Digital Operational Resilience Act (DORA), taking full effect in the EU in January 2025, is a game changer for banks and finance companies. DORA requires firms to implement a comprehensive ICT risk management framework, conduct regular stress tests and scenario testing of their cyber resilience, and maintain business continuity plans that account for cyber incidents. It also mandates incident reporting to regulators within tight deadlines and formalizes oversight of third-party tech providers (like cloud services that many banks rely on).

Essentially, DORA bundles many best practices (which banks may have followed under guidance) into law, complete with penalties for non-compliance. A bank in Europe will need to show regulators evidence of things like annual penetration tests, network recovery drills, and governance where the board reviews cyber risks regularly. This raises the bar significantly and is likely a model that could be copied by regulators in other jurisdictions.

Cyber disclosure and governance: Financial firms globally are under pressure to be transparent about cyber risks. In the U.S., beyond the SEC rules for public companies, banking regulators expect notification of major incidents (as noted, within 36 hours). If a bank’s ATM network goes down due to a hack, regulators want to know right away.

The financial sector has also pioneered cyber info sharing (through FSISAC, etc.), and now compliance frameworks encourage participation in such information sharing as part of a strong security posture. Boards of financial institutions are expected to be particularly engaged , the New York Fed has even run workshops on cyber for bank directors.

Antifraud and data security: Financial services face unique threats like account takeovers and payment fraud, so compliance intersects with consumer protection. Regulations like the EU’s PSD2 (Second Payment Services Directive) require Strong Customer Authentication for online payments, which is basically MFA for banking customers.

In the U.S., banks must comply with the FTC Safeguards Rule (recently tightened in 2023), which dictates specific security controls for customer data, including encryption and access controls. There’s also an expectation to monitor transactions for fraud (AML/KYC laws), which now often involves cybersecurity teams because cyber fraud (phishing leading to wire fraud, etc.) is rampant.

Payments and PCI DSS 4.0: Any financial entity (or retailer, but many financial firms handle payments) must comply with the Payment Card Industry Data Security Standard version 4.0 by March 2025. PCI DSS 4.0 introduces new requirements, like more frequent phishing training, stricter MFA, more robust logging access, and an explicit focus on continuous compliance rather than a one-time standard. This is not a law but a contractual/regulatory requirement heavily enforced by payment networks. For banks issuing credit cards or merchants processing them, failure to comply can mean fines or even loss of ability to process card payments.

Financial firms should ensure they meet the highest common denominator of requirements. This often means adopting frameworks like NIST or ISO 27001 companywide, then overlaying specific regs. Strong encryption of financial data, continuous monitoring (many banks have 24/7 SOCs), third-party audits, and board reporting are must-haves. Given the personal liability in some cases (e.g., NIS2 could hold management liable, and in the UK, the senior managers’ regime could arguably be extended to tech risks), senior management involvement is key.

Ultimately, regulators in finance care about the stability of the financial system, a major cyber incident could cause loss of confidence or economic issues, so they are treating it on par with financial solvency. Compliance teams need to treat cyber controls with the same rigor as capital adequacy controls.

Healthcare

Healthcare organizations face the dual challenge of protecting highly sensitive personal health information and ensuring patient safety in an increasingly digital, connected care environment. Compliance requirements in this sector are tightening after years in which healthcare lagged other industries in security maturity.

In the U.S., the Health Insurance Portability and Accountability Act (HIPAA) has long set the baseline for health data privacy and security. However, its Security Rule (dating back to 2005) gave covered entities some flexibility with “addressable” controls. Now regulators are moving to eliminate that flexibility in light of current threats.

As mentioned, HHS proposed in January 2025 a rule to require all previously addressable specs, making encryption, multifactor auth, risk analysis, and incident response explicitly mandatory, among other changes. The proposal also introduces modern requirements: annual technical security assessments, asset inventory maintenance, network mapping, and documented recovery plans.

This is a big change many smaller clinics or business associates who were doing minimal compliance will have to step up significantly (e.g., if a clinic hadn’t encrypted its databases or used MFA for EHR access, that would no longer fly). HHS is also pushing for cybersecurity practices adoption under a 2021 law (HR 7898) that gives breach investigation leniency to entities that follow recognized security practices (like NIST HC Cybersecurity Framework). So effectively, healthcare providers are incentivized to adopt robust frameworks or face harsher penalties after incidents.

Medical device and IoT security: Hospitals are filled with connected devices (imaging machines, IV pumps, etc.). Recognizing the risk, the U.S. FDA now requires cybersecurity disclosures for new medical devices in the approval process (as of 2023 via the PATCH Act). Device makers must provide an SBOM and commit to patches.

For hospital compliance, this means maintaining an inventory of devices and their software, applying patches quickly, and segmenting devices on networks. The Joint Commission (a body that accredits hospitals) also introduced new standards in 2022-2023 around technology risk management, which hospitals must meet to stay accredited. In the EU, the MDR (Medical Device Regulation) includes essential requirements for cybersecurity of devices as well. Healthcare delivery organizations thus need to include device security in their overall compliance.

Privacy and patient rights: Privacy compliance remains huge; GDPR applies to EU patient data, which affects any multinational pharma or research. Interoperability initiatives (like the U.S. Cures Act, which gives patients more access to data via APIs) introduce new surface area for breaches, so compliance now also means vetting those third-party apps.

Healthcare entities often must navigate not just HIPAA but 42 CFR Part 2 (for substance abuse records confidentiality), state laws like California’s Confidentiality of Medical Information Act (CMIA), and now the new state privacy laws which often don’t exempt all health data (if an entity isn’t fully covered by HIPAA, they might have state obligations). Thus, healthcare compliance officers are dealing with a complex matrix of privacy rules.

Ensuring ePHI security in practice: Common compliance gaps in healthcare have been basic unpatched systems, old Windows machines, shared passwords. Regulators are done being lenient. The Office for Civil Rights (OCR) has levied multimillion-dollar fines for breaches and will likely increase enforcement as new rules come in. One trend is the enforcement of risk analysis. OCR often fines entities not because a breach occurred, but because their risk assessment was insufficient or not updated, which is a HIPAA requirement. Going forward, a thorough annual (or continuous) risk assessment is a must do.

Healthcare organizations should update their compliance programs to be much more prescriptive. If the HIPAA rule gets finalized, they’ll need to tick every box (encryption of all PHI at rest and in transit, MFA on all accounts, unique IDs for users, emergency mode ops plans tested annually, etc.). In preparation, many are aligning with NIST’s Health Cybersecurity Framework or adopting HITRUST certification (a common framework in healthcare that combines multiple standards).

Employee training is key since phishing is rampant and healthcare workers are busy and sometimes not cyber conscious, but breaches via insiders or stolen creds are common, so compliance includes robust training regimens (often required by law too).

Overall, healthcare’s main challenge is catching up to other sectors in security maturity under heavy regulatory prodding, all while juggling lifeanddeath service delivery and often tight budgets. The trend is that compliance frameworks in health will increasingly resemble those in finance in strictness, given the criticality of the service.

Critical Infrastructure

Critical infrastructure sectors, such as energy (electricity, oil & gas), water utilities, transportation (airlines, rail, ports), telecommunications, and others, are facing perhaps the most intense regulatory focus in cybersecurity. These are the industries where a cyber incident could not only cause data loss but potentially large-scale physical or economic harm. Governments in 2025 are aggressively moving to fortify critical infrastructure through compliance mandates.

Broader coverage under NIS2 (EU): The EU’s NIS2 directive expands the scope of regulated sectors compared to its predecessor. It now encompasses a wide range of sectors, including energy, transport, banking, healthcare, public infrastructure, digital infrastructure (such as DNS and data centers), space, and more. It also adds to the manufacturing of critical products. Essentially, many organizations that never had to report security status to a regulator before will now fall under NIS2 if they meet size criteria in these sectors.

Compliance with NIS2 means implementing all the baseline security measures (risk assessments, incident response plan, supply chain security, crypto, access control, etc.), and instituting management accountability and governance oversight of cyber risks. If a power grid operator in the EU fails to patch known vulnerabilities, for instance, they could face significant fines under NIS2 just as they would if they violated safety rules. Moreover, the directive’s personal liability clause for managers is a big stick to ensure cyber is taken seriously at the top.

How can Encryption Consulting help?

Encryption Consulting offers a structured Compliance Advisory Service designed to align your organization with global regulatory frameworks such as GDPR, PCI DSS, HIPAA, NIS2, and DORA. As part of our service, we provide:

  • Current State Assessment: We review your existing encryption, key management, and security policies, assess technical environments, and gather compliance documentation to establish a clear baseline.
  • Gap Analysis : We evaluate policies and controls against industry standards, identify misalignments, and conduct workshops and questionnaires to uncover weaknesses in encryption and compliance practices.
  • Findings and Recommendations: We deliver a detailed report with actionable recommendations, prioritized by risk, compliance impact, and business needs, to strengthen your overall security environment.
  • Roadmap Development: We create a step-by-step strategy mapped to compliance goals, industry standards, and milestones, ensuring sustainable compliance and efficient remediation.
  • Ongoing Advisory: We provide continuous support through periodic reassessments, regulatory updates, team training, and strategic guidance during audits and incident responses.

With this end-to-end approach, we help organizations not only meet compliance requirements but also build resilience, reduce risk, and stay prepared for future regulatory demands.

Tailored Advisory Services

We assess, strategize & implement encryption strategies and solutions customized to your requirements.

Conclusion

The year 2025 marks an inflection point in compliance, where cybersecurity, privacy, and governance obligations reach new heights of rigor and breadth. The trends we’ve explored, from global data privacy expansion and encryption mandates to AI governance, disclosure requirements, ESG integration, supply chain security, zero trust, automation, and industry-specific rules, together paint a picture of a future where organizations must be proactive, transparent, and resilient. Compliance is no longer a static checklist but a living, strategic function that must adapt continuously to emerging risks and rules.

So, how can organizations prepare for the compliance landscape of the next few years?

  • Build a holistic compliance strategy: Silos between privacy compliance, cybersecurity, and corporate governance need to be broken down. An integrated approach (perhaps using a common controls framework and unified GRC platform) will ensure nothing falls through the cracks and reduce redundant efforts. For example, a unified compliance committee or working group can oversee data protection, cyber risk, and ESG disclosures collectively, recognizing their inter dependencies.
  • Stay ahead of regulations: Given the accelerating pace of regulatory change, organizations should invest in horizon scanning capabilities. This could mean dedicating personnel or using regulatory watch services (and AI tools) to monitor proposed laws and emerging standards in all regions you operate. Being involved in industry associations or public comment periods can provide valuable insights and influence. The goal is to avoid surprise if you know, for instance, that an AI Act or a new state law is coming in 18 months, you can start aligning policies now rather than scrambling later.
  • Embrace technology and automation: The complexity of compliance in 2025 and beyond simply cannot be managed manually. Organizations should leverage compliance automation to manage control monitoring, evidence collection, and reporting. Not only does this make compliance more efficient, it also often improves security posture by providing real-time feedback. Additionally, consider how emerging tech like AI can assist, perhaps in automating code reviews for security (helping with software supply chain compliance) or analyzing user behavior for insider threat (tying into zero trust). An important note: technology should augment a skilled compliance team, not replace it. Talented compliance professionals who understand the business and technology will remain indispensable.
  • Cultivate a compliance culture: Regulations can impose requirements, but it’s ultimately people who implement them. Leading organizations foster a culture where employees at all levels understand the importance of compliance and feel personally invested in it. This involves regular training (with engaging content, not just dull checkboxes), leadership messaging about integrity and security, and integrating compliance objectives into performance goals. For instance, making security and compliance a part of everyone’s job description, developers writing code with security in mind, salespeople being careful with customer data, etc., creates an environment where complying is the norm, not an afterthought.
  • Enhance incident readiness and transparency: With mandatory disclosures and fast reporting timelines, companies must be ready to respond to incidents before they occur. This includes having detailed incident response playbooks, communication plans (including draft templates for regulators, customers, and investors notifications), and even media handling strategies. Conduct regular breach simulations that involve not just IT but also legal, PR, and executive leadership so that if the worst happens, the organization can respond in a coordinated, compliant manner. Moreover, given the focus on transparency, it’s wise to assume that significant incidents will become public, so acting with honesty and responsibility during incidents is part of maintaining trust (and regulators do consider cooperation and candor when determining penalties).
  • Measure and report on compliance internally: Boards and executives should receive meaningful metrics about the company’s compliance posture. This might include KPIs such as percentage of staff who completed security training, number of high-risk findings from audits that were remediated, time to patch critical vulnerabilities, or third-party risk ratings. By quantifying and tracking these, leadership can better oversee compliance (which ties to ESG expectations too) and allocate resources where needed. In many industries, regulators now expect board minutes to reflect discussions of cybersecurity and compliance, having regular reports helps fulfill that duty and can be shown as evidence that management is engaged.
  • Plan for future trends: Looking ahead, we can foresee some areas that may become tomorrow’s compliance challenges. For example, quantum computing was discussed organizations that might develop a roadmap for crypto agility now, so they aren’t caught off guard in the 2030s. In essence, organizations should strive to transform compliance from a burdensome cost center into a business enabler and trust builder. Those that manage compliance well gain credibility with customers (who know their data is protected), with partners (who see them as secure links in the chain), and with regulators (who may then grant certifications or faster approvals). For example, demonstrating robust compliance with security standards can open doors to working in sensitive sectors or handling government data, which can be a market differentiator.

Compliance in 2025 and beyond is undoubtedly challenging, the bar is higher than ever. But by taking a strategic, proactive approach and leveraging the trends outlined above, organizations can not only avoid penalties and incidents but truly turn strong compliance into a competitive advantage.

Those who prepare today for the regulations and risks of tomorrow will be the ones best positioned to thrive in an environment where trust and accountability are paramount. As the saying goes, “Compliance is a journey, not a destination”, and that journey is accelerating. Now is the time to tighten your seatbelts, map your route, and drive your compliance program forward confidently into the future.

Post-Quantum Cryptography Migration Plan: Locking Down Your Data

Quantum computers are coming fast, and they could crack the encryption we rely on, like RSA and ECC, which protect your online banking, emails, and sensitive files. With quantum tricks like Shor’s algorithm, your data could be vulnerable to attacks that unravel codes we thought were solid. Post-Quantum Cryptography (PQC) is the new shield to keep your information safe from these future threats.

This blog provides a clear, beginner-friendly plan to switch to PQC, drawing from the Migration Roadmap and NIST’s latest algorithm updates. It uses simple language, detailed steps, and practical tips to make the transition smooth and keep your data secure.

Built on the Migration Roadmap, this blog breaks down PQC migration into an easy-to-follow plan. It guides you through checking your current encryption setup, figuring out what needs fixing first, deciding whether to buy ready-made solutions or build your own, and rolling out changes without disruptions.

Packed with detailed timelines, tool recommendations, and tailored advice for industries like finance, healthcare, telecom, and even small businesses, it helps you stay secure and meet regulations. You’ll also find real-world examples, like how banks can protect transactions or how hospitals can secure patient records, plus tips on avoiding common pitfalls during the switch.

Why PQC Is Critical Now

Quantum computers are expected to hit a major milestone by 2030 to 2035, becoming “cryptographically relevant.” This means they could use Shor’s algorithm to break current encryption, exposing sensitive data. Hackers might be grabbing encrypted data today, like bank records, health files, or government secrets, waiting to decrypt it later with a “Harvest Now, Decrypt Later” attack. This is a huge risk for data that needs to stay safe for years, like financial contracts, medical records, or trade secrets.

Governments are pushing hard: the NSA’s Commercial National Security Algorithm Suite 2.0 (CNSA 2.0) demands PQC for national security systems by 2030, and U.S. federal agencies have until 2035 under National Security Memorandum 10 (NSM-10). The EU and UK are also aiming for 2035 to phase out old, vulnerable algorithms. Switching to PQC can take 10 to 20 years, or longer for complex setups like global corporations, government networks, or critical infrastructure, so starting now is essential to stay ahead and keep your data locked down.

Key Fact: By 2030, RSA, ECC, Diffie-Hellman, ECDSA, and EdDSA (with 128-bit security or higher) will be phased out for U.S. national security systems, with a full stop by 2035.

Challenges of PQC Migration

Switching to PQC is like upgrading a plane’s engines while it’s flying. It’s doable, but it takes careful planning. The Migration Roadmap highlights the main hurdles:

  • Tech Challenges: Encryption is tucked into everything: networks, apps, cloud services, backups, and smart devices like IoT sensors in smart homes or factories. Tracking it all is a huge task. PQC algorithms use bigger keys (for example, ML-KEM needs 800 to 1600 bytes compared to RSA’s 256 bytes) and more computer power, which can slow systems or require new hardware, like upgraded servers or specialized chips. Making old systems work with new PQC setups without breaking apps or services is a big challenge.
  • Long Timeline: Updating encryption across an organization can take 10 to 20 years, especially for legacy systems like old banking mainframes or complex setups like power grid controllers. Some industries, like aerospace or utilities, may need even longer due to strict safety and regulatory requirements.
  • Blind Spots: Many organizations don’t know where all their encryption is, especially in vendor-supplied software, hardware, or supply chains. For example, a hospital might not realize its MRI machines use outdated encryption, or a retailer might miss it in third-party payment systems. This makes spotting risks tricky.
  • Lack of Experts: PQC is a niche field, and skilled pros are rare. A 2024 survey noted that 51% of companies lack a dedicated leader for this transition, which can lead to delays or errors. Finding staff who understand both quantum-safe algorithms and your specific systems is tough.
  • Extra Complications: You need to watch for side-channel attacks, like timing issues in Kyber that could leak data if not coded properly. Some algorithms, like SLH-DSA, produce huge signatures (up to 40 KB), eating up storage and bandwidth, which is a problem for devices like smartwatches or sensors. New regulations, like PCI DSS 4.0 for payment systems, push for quantum-safe practices, adding pressure. Crypto-agility, the ability to swap algorithms quickly, is critical to keep up with new threats or standards without rebuilding everything .

NIST’s PQC Algorithms: Your Security Toolkit

Since 2016, NIST has been developing quantum-safe algorithms to replace vulnerable ones. They finalized three in August 2024 and selected HQC in March 2025 to add diversity and reduce risks if one algorithm has issues. Here’s a detailed look at these tools and their practical uses:

AlgorithmPrimary UseStrengthsChallengesIdeal ApplicationsStandardization Status
ML-KEMKey exchange over public networksFast, small keysSusceptible to timing attacks if not coded carefullyWeb servers, VPNs, e-commerce, cloud servicesFIPS 203 (Finalized)
ML-DSADigital signatures for data verificationStrong security, good performanceNone notedPKI (SSL certificates), banking apps, software updatesFIPS 204 (Finalized)
SLH-DSAHigh-security data verificationHigh securityLarge signatures require more storage and bandwidthGovernment communications, secure firmware updatesFIPS 205 (Finalized)
FN-DSADigital signatures for resource-constrained devicesLow memory and power usageNone notedIoT, smart meters, wearables, automotive systemsDraft FIPS 206 (Expected late 2025)
HQCKey sharing (backup to ML-KEM)Fast key generationLarger keysHigh-speed networks (e.g., 5G)Draft Standard (Expected 2027)

These algorithms resist quantum attacks, unlike RSA and ECC, which rely on math problems quantum computers can solve. NIST SP 800-131A and IR 8457 provide settings for 128-bit, 192-bit, and 256-bit security levels to match different risk needs (e.g., 128-bit for commercial data, 256-bit for classified systems). Testing these in a lab, like a virtual server or test network, is crucial to check how they perform with your systems, from cloud platforms to embedded devices in factories or vehicles.

Your Five-Step PQC Plan

The Migration Roadmap outlines four phases: Preparation, Baseline Understanding, Planning and Execution, and Monitoring and Evaluation. We’ve expanded these into five clear steps to make the process easier, aligned with regulatory timelines and practical for any organization, from startups to global enterprises.

Kick Off with a Plan

Start by figuring out how urgent this is. Check how long your data needs to stay secure (e.g., 10+ years for medical or financial records) and what risks your industry faces (like data breaches in finance or regulatory fines in healthcare). Map your encryption setup by listing sensitive data (e.g., customer info, intellectual property), systems (on-site servers, cloud platforms, SaaS tools like Salesforce), and connections to vendors or partners (like payment processors or IoT suppliers).

Appoint a PQC Migration Lead with strong crypto knowledge and project management skills, backed by a team of IT, security, compliance, and business staff. The roadmap emphasizes that this leader must rally everyone, explain why PQC is critical, and secure buy-in from executives to frontline techies. Set a budget, define roles, and create a governance plan to keep things organized. For example, a bank might budget for new hardware, while a hospital might focus on training staff to secure patient data systems.

RequirementDetails
Crypto Expertise5+ years in cryptography, PKI, or security architecture
Project ManagementPMP, PRINCE2, or Agile certification preferred
Team CoordinationAbility to manage IT, security, and business teams
Vendor SkillsExperience working with technology partners
Risk KnowledgeUnderstanding of enterprise risk assessments
CommunicationCan explain complex ideas to executives and tech staff

Outcome: A solid governance plan, a dedicated team, and an approved budget by Q2 2026.

Find Your Encryption

Hunt down every bit of encryption in your organization, from networks and apps to databases, pipelines, IoT devices, and industrial gear like Supervisory Control and Data Acquisition (SCADA) systems in factories or utilities. Use automated tools to scan for quantum-vulnerable algorithms (like RSA, ECC, or outdated TLS versions) and build a centralized Cryptographic Bill of Materials (CBOM), as the roadmap recommends. Your CBOM should detail what encryption is used, what data it protects (e.g., customer records, trade secrets), how long it needs to stay secure, and what systems or protocols depend on it (e.g., APIs or VPNs).

Choose tools that cover hardware (like routers or HSMs), software (like web apps or ERP systems), and firmware (like embedded chips in medical devices). For example, a retailer might discover ECC in their point-of-sale systems, while a manufacturer might find it in robotic assembly lines. This step helps you spot gaps, like weak keys or old protocols, that need fixing .

Tool TypeBenefitsBest For
Automated ScannersFast, scans large systems quicklyBig organizations with complex networks
Manual AuditingFinds hidden or undocumented encryptionSmall setups or niche systems
Hybrid ApproachesCombines speed and depth for thorough coverageMixed environments with diverse tech
Vendor-Specific ToolsTailored to specific platforms or devicesUniform setups like single-vendor stacks

Outcome: A prioritized CBOM with risk scores for each system by Q4 2026, highlighting what’s most vulnerable.

Assess Risks and Plan

Dive into your CBOM to identify systems using weak encryption and estimate the fallout if quantum attacks hit. For example, a bank could lose millions from stolen transaction data, while a government agency might face national security risks. Map connections to vendors and systems to find roadblocks, like third-party software that’s slow to update or legacy hardware that can’t handle PQC. Prioritize high-risk systems, as the roadmap suggests, such as payment gateways, classified databases, or patient record systems.

Align with regulations like PCI DSS 4.0 for payment data, HIPAA for health records, or GDPR for EU customer data, all of which are starting to emphasize quantum-safe practices. Identify gaps in tools, skills, or budget, and create a detailed plan balancing cost, urgency, and complexity. Use hybrid cryptography, mixing PQC (like ML-KEM) with current methods (like ECDH), to maintain security and compatibility during the transition. For instance, a telecom company might use hybrid setups to secure 5G networks while still supporting older 4G infrastructure.

Outcome: A risk-based migration plan with allocated resources by mid-2027.

Roll It Out

Build teams to handle technical upgrades, ensure business operations keep running, and train staff on PQC. Work closely with vendors to confirm their PQC readiness, checking timelines for updates, software patches (e.g., for web servers or firewalls), or hardware needs (like new processors for faster PQC processing), and how these changes affect system performance (e.g., latency in apps or CPU usage in IoT devices), as the roadmap advises.

Decide whether to buy off-the-shelf solutions for standard systems like cloud services (e.g., AWS, Azure), VPNs, or email encryption, or build custom solutions for legacy systems like old banking platforms, industrial controllers, or proprietary software. For example, a hospital might buy a PQC-ready patient portal from a vendor, while a manufacturer might build custom PQC firmware for factory robots.

OptionBuyBuild
Best ForVendor-supported systems (e.g., cloud, VPNs)Legacy or custom systems (e.g., old mainframes)
ProsQuick setup, less internal effortFull control, tailored to your needs
ConsTied to vendor schedules, integration risksTime-intensive, requires expert staff

Roll out changes carefully, starting with pilot tests on low-risk systems like internal HR apps or test servers. Monitor for issues, like slowdowns or compatibility glitches, ensure old systems stay functional, and document everything for audits or compliance checks (e.g., for ISO 27001, GDPR, or SOC 2). For instance, a government agency might pilot SLH-DSA for internal emails before rolling it out to classified systems.

Outcome: Pilot deployments by mid-2027, with critical systems fully PQC-ready by 2031.

Monitor and Improve

Verify that new PQC systems work smoothly with legacy setups and fully quantum-safe ones, updating your CBOM with details on algorithms, key sizes, and implementation notes (e.g., which servers use ML-KEM or which IoT devices use FN-DSA). Track key metrics, as the roadmap recommends, like the percentage of systems using PQC (e.g., 30% by 2028), the amount of sensitive data protected by quantum-safe encryption (e.g., 80% of customer data), and any issues after the switch (like performance dips or security alerts).

Stay updated on regulations from NIST, NSA, ENISA, and ETSI, which may release new standards or guidance (e.g., updates to FIPS or EU cybersecurity rules). Train your team regularly with workshops or certifications to keep their PQC skills sharp and build crypto-agility into your systems so you can swap algorithms fast if new threats or standards emerge. For example, a bank might switch from ML-KEM to HQC if a vulnerability is found. Keep tabs on quantum computing and cryptanalytic developments through industry reports, conferences (like RSA Conference), or threat intelligence feeds to stay ahead.

Your Timeline and Must-Haves

Here’s the schedule to aim for:

  • 2024 to 2026: Finalize standards, build your CBOM, secure budgets, and train your team. Start with small-scale tests, like PQC for internal apps.
  • 2027 to 2029: Work with vendors to integrate PQC solutions and launch pilot projects in low-risk systems, like employee portals or backup systems.
  • 2030 to 2033: Tackle risks as quantum computers get closer, focusing on critical systems like financial transaction platforms or government networks.
  • 2035: Complete the full switch to quantum-safe encryption across all systems, from cloud servers to IoT devices.

Must-haves for a successful migration, per the Migration Roadmap:

  • A thorough check of all encryptions in your organization, covering software, hardware, and third-party systems.
  • A custom migration plan tailored to your industry and infrastructure, like a bank focusing on transaction security or a hospital prioritizing patient data.
  • Vendor checks to confirm PQC support, timelines, and performance impacts (e.g., latency or storage needs).
  • Hybrid cryptography setups for smooth transitions, ensuring compatibility with existing systems.
  • Lab testing to catch performance or compatibility issues early, like testing ML-KEM on a test server before live deployment.
  • Crypto-agility to quickly update algorithms as new standards or threats emerge, like swapping to HQC if ML-KEM faces issues.
  • Ongoing team training through workshops, certifications, or online courses (e.g., Coursera or SANS Institute) to build PQC expertise.
  • Alignment with regulations like PCI DSS 4.0, HIPAA, GDPR, or CNSA 2.0 to avoid penalties.
  • Audits after implementation to verify security and compliance, using frameworks like NIST 800-53 or ISO 27001.
  • Continuous monitoring to track progress (e.g., percentage of PQC-ready systems) and watch for emerging threats via threat intelligence feeds or industry reports.

Helpful Resources

  • NIST: Check FIPS 203 to 205 for algorithm details (e.g., key sizes, performance metrics) and NCCoE playbooks for industry-specific guidance, like PQC for healthcare or finance.
  • Vendor Tools: Explore PQC-ready solutions from major cloud providers, like AWS Key Management Service (KMS) or Microsoft Azure’s quantum-safe VPNs, which support ML-KEM and ML-DSA.
  • Open-Source Tools: Use OpenQuantumSafe’s liboqs for testing PQC algorithms, OpenSSL 3.2+ for PQC-enabled TLS, or Bouncy Castle for Java-based integrations. These are great for developers building custom solutions.
  • Migration Roadmap: Dive into the Migration Roadmap and inventory workbook for practical templates, like CBOM spreadsheets or vendor questionnaires. Their case studies, like PQC in banking or IoT, offer real-world insights. 

PQC Advisory Services

Prepare for the quantum era with our tailored post-quantum cryptography advisory services!

How Encryption Consulting Can Help

Building a comprehensive cryptographic inventory is a significant undertaking, but you do not have to do it alone. We are a globally recognized leader in applied cryptography, offering Post-Quantum Cryptography (PQC) Advisory Services specifically designed to help organizations navigate the quantum shift.

Our services are built on a structured, end-to-end approach:

  • PQC Assessment: We perform cryptographic discovery and inventory to locate all your keys, certificates, and dependencies. This delivers a clear Quantum Threat Assessment and a Quantum Readiness Gap Analysis that identifies your vulnerabilities and most urgent priorities.
  • PQC Strategy & Roadmap: Based on the inventory data, we help you develop a custom, phased PQC migration strategy aligned with NIST and other industry standards. This includes creating a Cryptographic Agility Framework to ensure you are prepared for future changes.
  • Vendor Evaluation and PoC: We assist in selecting the best PQC solutions by defining evaluation criteria, shortlisting vendors, and executing proof-of-concepts (PoCs) on your critical systems to validate their effectiveness.
  • PQC Implementation: We help you seamlessly integrate PQC algorithms into your PKI and other security ecosystems, including the deployment of hybrid cryptographic models for a secure and disruption-free transition.

With our deep expertise and proven framework, you can build, assess, and optimize your cryptographic infrastructure, ensuring a smooth and secure transition to a post-quantum future.

Conclusion

Switching to PQC is critical to protect your data from future quantum threats, whether you’re securing bank transactions, patient records, or smart city networks. This detailed, easy-to-follow plan, built on the Migration Roadmap, helps you assess your encryption, make a smart plan, and roll out changes while staying compliant with regulations like PCI DSS, HIPAA, or CNSA 2.0. With practical steps, industry-specific tips, and resources to guide you, starting now ensures your data stays locked down for the long haul. Don’t wait for quantum computers to catch up; take the first step today to build a quantum-safe future.

Securing the Future with Cryptographic Inventory 

Cryptographic assets such as encryption keys, digital certificates, and algorithms are the building blocks of digital security. They enable secure logins, verify identities, protect sensitive information, support digital signatures, and maintain trust in online interactions. 

Imagine giving out spare keys of your house for years to family, friends, contractors, but never keeping track of who has them. Some keys are lost, some have been copied without your knowledge, and others are still with people you barely remember. Would you feel safe knowing that anyone, at any time, might still have access to your home? 

That is precisely the situation most organizations are in with their cryptographic inventory today. In the digital world, those “keys” are encryption keys, digital certificates, and cryptographic algorithms. Unlike physical keys, cryptographic assets are constantly multiplying and evolving. Cloud platforms automatically issue short-lived certificates, applications generate new keys on the fly, and APIs or IoT devices often embed cryptography deep within their code.  

What was once a manageable security layer has become a sprawling, fast-moving ecosystem that is increasingly difficult to monitor and control. And it is not just metaphorical: 43% of organizations admit they do not even know what cryptographic assets they own, and this lack of visibility is cited as the biggest hurdle to preparing for post-quantum cryptography (PQC). 

Aging Cryptography and Hidden Vulnerabilities 

Most of today’s cryptographic infrastructure was designed decades ago, long before the cloud, mobile-first applications, or the scale of today’s digital economy. As a result, it is struggling to keep pace with modern demands. Cryptographic keys, certificates, and algorithms are scattered across servers, endpoints, applications, and cloud services, often without proper visibility or governance. Many of these assets are outdated, misconfigured, or simply forgotten. 

The real problem is that these weaknesses often stay hidden until something goes wrong. Certificates may expire quietly and cause unexpected outages, deprecated algorithms such as SHA-1, MD5, RC4, and DES may still be embedded in legacy systems, and organizations may continue to trust obsolete or compromised certificate authorities. These blind spots become easy targets for attackers, who exploit weak or unmanaged cryptography to bypass even the strongest defenses.  

The consequences are serious. A single expired certificate has been known to bring down critical websites and disrupt services for millions of users.  For example, on July 21, 2024, the Bank of England’s CHAPS high-value payment system, which handles thousands of daily transactions, went offline due to an expired SSL/TLS certificate. In fact, a report states that 77% of organizations have experienced outages caused by expired certificates.  

Moreover, outdated or weak algorithms create backdoors that attackers can exploit to steal data, impersonate trusted systems, or corrupt transactions. And it’s not just about security, many organizations fail compliance audits because they lack clear visibility into their cryptographic assets. Yet, despite the risks, many organizations continue to operate without a clear understanding of what cryptographic assets they have, where they are, or whether they are secure or not. 

What is Cryptographic Inventory? 

A cryptographic inventory is a comprehensive record of all cryptographic assets within an organization. Unlike a general IT asset list, a cryptographic inventory focuses only on the components that secure identities, data, and communications. More importantly, it gives you a real-time picture of what’s in use today, not just a static snapshot of what was deployed in the past. 

You can think of it like an up-to-date security ledger. Instead of guessing where keys are stored or which certificates are about to expire, the inventory lays it all out in one place.  

A complete cryptographic inventory typically includes: 

  • Public and private keys with attributes such as algorithms, key lengths, expiration dates, usage context, and ownership. 
  • Cryptographic algorithms, ciphers, and protocols currently in use, including TLS versions, cipher suites, hashing functions, and signature schemes. 
  • Policies and configurations, including key rotation schedules, algorithm restrictions, and cryptographic lifecycle management settings. 

Maintaining this inventory is a dynamic process and not a one-time audit. Modern environments require automated discovery and monitoring across on-premises infrastructure, multi-cloud platforms, applications, networks, and endpoints. This involves scanning file systems for certificates, querying keystores, monitoring containerized workloads, and inspecting live network protocols. The result is a single source of truth that continuously maps all cryptographic assets, their configurations, and their dependencies.  

This visibility helps organizations to: 

  • Identify weak or outdated algorithms before they become liabilities. 
  • Detect misconfigurations or policy violations. 
  • Prevent outages caused by expired or untracked certificates. 
  • Understand how cryptographic assets support critical applications and business processes. 
  • Map cryptographic assets to applications, APIs, and critical business processes, enabling risk-based prioritization. 

Think of cryptographic inventory as a map of all the keys, certificates, and encryption methods protecting your systems. Without it, you’re basically flying blind. 

The Essentials of a Cryptographic Inventory 

A cryptographic inventory is more than just a list of keys and certificates. It captures contextual information about where, why, and how cryptography is used. This context goes beyond technical attributes such as key type, algorithm, and expiry date to also include business criticality and regulatory requirements. With this richer view, raw data becomes actionable insight, helping organizations identify risks, ensure compliance, and prepare for future changes in cryptography. 

A comprehensive inventory should answer six fundamental questions: 

  • What do you have? 
    Identify the cryptographic algorithms, key and certificate types, key lengths, hashing functions, protocols, and standards in use. 
  • Where is it all? 
    Map all the systems, applications, databases, cloud services, and network devices that utilize cryptography. 
  • Why do you use it? 
    Clarify the purpose of the encryption, whether it is for data confidentiality, integrity, authentication, or regulatory compliance. 
  • When are these assets used? 
    Track the lifecycle of each cryptographic asset, including active, expiring, or deprecated items. 
  • Who is responsible? 
    Document the teams or individuals responsible for managing and maintaining each cryptographic asset. 
  • How is it implemented? 
    Capture implementation details, including cryptographic libraries, configurations, and usage patterns. 

Example of a comprehensive inventory in action: 

A comprehensive cryptographic inventory might include an RSA 2048-bit TLS certificate (What do you have?) active on an AWS Load Balancer (Where is it?), used to encrypt user logins and protect sensitive data (Why do you use it?), valid for 90 days before automatic renewal (When are these assets used?), managed by the Security Operations Team (Who is responsible?), and implemented via OpenSSL with automated CI/CD rotation and strict access controls in HSMs (How is it implemented?). It could also list an AES-256 key for database encryption, a SHA-256 hashing function for code signing, and protocols like TLS 1.3 and SSH, providing a complete view of the technical, operational, and business context of all cryptographic assets. 

By addressing these six dimensions, organizations gain full visibility into their cryptographic environment. This visibility makes it easier to spot risks, sail through audits, respond quickly when something goes wrong, and even get ready for big shifts like PQC migration.  

How to Build a Cryptographic Inventory? 

Building a cryptographic inventory requires a structured, automated, and continuous approach. It is not a one-time project, but an ongoing capability that evolves with your infrastructure. Here are the key steps to building and maintaining an effective cryptographic inventory: 

1. Define Scope and Objectives 

Start by defining what you want the inventory to cover. Will it include only TLS certificates, or extend to all encryption keys, algorithms, and protocols? Defining scope helps prioritize effort and select the right tools. Align cryptographic inventory with compliance requirements, risk areas, and business-critical systems. Start small, focusing on high-impact systems, and expand from there. 

2. Discover Cryptographic Assets 

Manual tracking is not feasible. Use automated discovery tools to scan on-prem systems, cloud KMS, HSMs, container workloads, CI/CD pipelines, applications, endpoints, code repositories, and network traffic. Focus on breadth (finding everything) and depth (capturing rich metadata: owner, algorithm, expiry, usage). Discovery should pull from multiple sources, including network scans, API integrations with cloud and key management platforms, secret management vaults, and source code scanning tools, to ensure no cryptographic asset is overlooked. 

3. Centralize and Normalize Data 

Once cryptographic assets are discovered, aggregate them into a central inventory platform. This makes it easier to manage, analyze, and report on your cryptography. Normalize formats (PEM, DER, JKS, PFX), enrich with context (ownership, application mapping), and remove duplicates. Normalizing them into a consistent format ensures all keys and certificates can be tracked, compared, and managed uniformly. This helps detect duplicates, enforce rotation and expiration policies, simplify audits, and maintain a clear, accurate inventory across diverse systems. 

4. Classify and Assess Risk 

Categorize assets by type, criticality, algorithm strength, expiry status, and policy compliance. Highlight weak keys, deprecated ciphers, and high-risk configurations. This step turns raw inventory data into actionable insights that guide risk mitigation. For example, identifying a TLS certificate using SHA-1 on a public-facing payment API immediately flags a high-severity risk, while an expired self-signed certificate on a test server is low risk and can be remediated later. 

5. Integrate with Processes and Policies 

Link the inventory to your certificate lifecycle management, DevOps pipelines, and compliance workflows. Enforce policies for key rotation, algorithm usage, and certificate issuance. Embed cryptographic hygiene into daily operations, not just annual audits. Automate alerts, renewals, and decommissioning processes wherever possible. Continuously monitor for drift, expired assets, or non-compliance. 

6. Continuously Monitor and Update 

Inventory is not a one-time project. To maintain accuracy and reliability, organizations should follow best practices such as continuous scanning, change detection, real-time alerting, periodic inventory reporting, automated alerts for expiring or rotated keys, and regular audits.

Integrate with SIEM or SOAR tools to monitor crypto events and anomalies, and connect the cryptographic inventory to change management systems to track updates across infrastructure. This approach ensures the cryptographic inventory remains current, actionable, and supports risk management, audit readiness, and future cryptographic migrations like post-quantum cryptography.  

In summary, building and maintaining a cryptographic inventory is an essential part of organizational security and compliance. A structured and continuous approach ensures visibility, reduces risk, and supports informed decision-making across all cryptographic assets.  

PQC Advisory Services

Prepare for the quantum era with our tailored post-quantum cryptography advisory services!

Challenges in Creating a Cryptographic Inventory 

Managing cryptographic assets like keys and certificates is critical and increasingly complex. With systems spread across cloud, on-prem, and containers, and new assets created constantly, keeping track of everything is not easy. Here are some of the most common challenges: 

1. Discovery Across Hybrid and Multi-Cloud Environments 
Modern enterprises run a mix of on-premises systems, multiple cloud providers, SaaS platforms, and containerized workloads. Each environment manages cryptography differently, from cloud KMS and service-managed TLS certs to embedded keys in Kubernetes secrets. Finding every cryptographic asset across these environments requires advanced automated scanning and integration with APIs, which many organizations lack. 

2. Shadow IT and Hidden Cryptography 
According to a survey, 59% of organizations see code vulnerabilities as one of the biggest risks to application security. In practice, this often happens when developers hardcode keys into source code, leave credentials embedded in CI/CD pipelines, or set up test environments using self-signed certificates. These “hidden” cryptographic assets often escape official inventories, making them unmanaged, weakly protected, and easy targets for attackers. 

The risks are not theoretical. Hardcoded or exposed secrets have led to significant breaches and data leaks. In 2022, over 3,200 mobile apps leaked Twitter API keys, exposing user data, including direct messages. Symantec found 1,859 apps with AWS tokens, many granting access to private cloud services and millions of files in S3 buckets. Toyota accidentally uploaded keys to GitHub, exposing nearly 300,000 customer records. Even major breaches like Target were fueled by compromised credentials, leading to stolen payment card data, lawsuits, and significant financial damages.  

3. Scale and Ephemeral Assets 
The sheer volume of cryptographic assets is exploding. Large enterprises can have millions of certificates and keys, many of which are short-lived (days or even hours in cloud-native systems). Traditional manual tracking methods like spreadsheets cannot keep up and are prone to errors, omissions, and stale data, making them unreliable for maintaining security at scale. Capturing and continuously updating an inventory that reflects this scale and ephemerality requires real-time, automated discovery.  

4. Ownership and Context Mapping 
Finding a certificate or key is only half the battle. Understanding where it is used, what it protects, and who owns it is far more difficult. Without context, organizations cannot prioritize risks. For example, an expired certificate protecting a test system is not as critical as one securing a public payment API. Mapping ownership and usage dependencies into the inventory is a significant technical challenge. 

5. Integration with Policies and Compliance Frameworks 
A cryptographic inventory is not just a simple list. It must be validated against internal security baselines and external regulations (e.g., PCI DSS, HIPAA, NIST). This means identifying which algorithms are non-compliant, which keys are too weak, or which certificates are nearing expiration. Integrating cryptographic discovery with compliance engines and ensuring continuous validation is both technically complex and resource-intensive. 

Taken together, these challenges explain why so many organizations struggle with visibility and control over their cryptographic assets. The good news is that each of these obstacles can be addressed with the right mix of automation, integration, and policy enforcement.

Effective Ways to Overcome These Challenges 

Overcoming these challenges requires more than patchwork fixes. Organizations need structured, repeatable practices that scale across hybrid environments. Below are proven strategies that help security teams build a resilient and reliable cryptographic inventory: 

1. Automate Discovery Across All Environments 
Deploy automated discovery tools that integrate natively with cloud KMS APIs, container orchestration systems, SaaS platforms, and network scans. This ensures coverage across hybrid environments and eliminates blind spots. 

2. Detect and Eliminate Shadow IT Cryptography 
Integrate secret scanning into DevOps pipelines, CI/CD processes, and code repositories. Enforce policies that prevent the use of self-signed certificates in production and mandate secure vault storage for all keys and secrets. 

3. Manage Scale with Real-Time Monitoring and Automation 
Leverage lifecycle automation tools that detect, catalog, rotate, and retire assets automatically. Avoid spreadsheet-based approaches, which create stale, error-prone inventories that cannot scale with ephemeral assets. 

4. Link Assets to Ownership and Context 
Integrate cryptographic inventories with CMDBs, IAM systems, and application dependency maps. This links assets to owners and business processes, allowing organizations to prioritize remediation based on business impact. 

5. Enforce Continuous Compliance 
Tie your cryptographic inventory with compliance management tools and enforce continuous validation against evolving standards and internal crypto policies. Automate reporting so audits can be passed with minimal manual effort. 

By applying these practices, organizations can turn an overwhelming challenge into a manageable process. The result is stronger security, reduced risk, and a cryptographic environment that is always ready for audits and future transitions like post-quantum cryptography. 

Why Cryptographic Inventory Matters? 

When was the last time you checked what cryptography your organization is actually using? For most organizations, the answer is never, and that’s exactly why a cryptographic inventory matters. In fact, a 2024 survey found that 24% of organizations have little or no confidence in identifying where their data is stored, emphasizing the fundamental need for a comprehensive cryptographic inventory for better data governance and protection. 

Here are five key reasons why every organization needs a cryptographic inventory: 

1. Preventing Service Disruptions 
Expired or untracked certificates have caused some of the world’s most visible outages, from banking apps going offline to halting major cloud services. A complete inventory ensures that organizations can detect certificates approaching expiration and automate renewals, preventing costly downtime and reputational damage. 

2. Reducing Security Risks 
Attackers actively look for weak algorithms, misconfigured keys, or forgotten certificates because they are easy entry points. An up-to-date cryptographic inventory allows organizations to spot outdated algorithms, identify overly permissive configurations, and eliminate hidden attack surfaces before adversaries can exploit them. 

3. Enabling Compliance and Audit Readiness 
Regulators and auditors increasingly expect organizations to prove that cryptography is effectively managed. From PCI DSS to HIPAA and NIST standards, demonstrating control over cryptographic assets is now a compliance requirement. Auditors commonly request evidence such as certificate expiration tracking, key rotation logs, proof of algorithm compliance, and records of access controls. Maintaining a well-organized, centralized cryptographic inventory makes it easier to produce these artifacts quickly and accurately, helping organizations stay audit-ready at all times. 

4. Supporting Crypto-Agility and Future Readiness 
The cryptographic landscape is evolving rapidly, with post-quantum cryptography (PQC) on the horizon. Organizations cannot plan migrations to new algorithms without knowing what algorithms are in use today. An inventory provides the visibility needed to plan, test, and execute transitions with confidence. 

5. Building Digital Trust 
At its core, cryptography underpins trust between businesses and customers, between devices and cloud platforms, and across digital ecosystems. By maintaining a reliable inventory, organizations can prove that their systems are secure, trustworthy, and resilient, strengthening customer confidence and competitive advantage. 

In short, creating and maintaining a cryptographic inventory is not just a technical exercise; it is a foundation for resilience, compliance, and digital trust. Without visibility into cryptographic assets, organizations are effectively flying blind. With it, they gain the ability to manage cryptography as a strategic security function rather than a hidden liability. It reduces operational risks, strengthens defenses, simplifies compliance, and prepares organizations for the cryptographic challenges of tomorrow. 

How can EC help? 

If you’re wondering where and how to get started with securing your cryptographic assets for the post-quantum era, Encryption Consulting is here to support you with its PQC Advisory Services. You can count on us as your trusted partner, and we will guide you through every step with clarity, confidence, and real-world expertise.   

We begin by conducting a thorough discovery and mapping of all your cryptographic inventory, including keys, certificates, algorithms, and their dependencies, giving you a clear picture of what you have and where potential quantum risks lie. This detailed inventory forms the foundation for a prioritized action plan and risk analysis, so you know exactly where to focus. 

From there, we develop a customized, step-by-step migration strategy that fits your business needs and aligns with NIST and NSA guidelines. Our approach includes defining governance and crypto agility frameworks to keep your cryptographic inventory accurate, secure, and adaptable over time. We also assist in evaluating and selecting the best quantum-safe PQC algorithms, key management, and PKI solutions, and run proof-of-concept testing across your critical systems. You also get a detailed vendor comparison report and recommendations to help you choose the best. 

Finally, we help you seamlessly integrate post-quantum algorithms into your existing infrastructure, whether it is your PKI, enterprise applications, or broader security ecosystem. All while keeping your cryptographic inventory continuously updated. We test everything thoroughly before enterprise-wide rollout and offer ongoing monitoring and optimization to keep your cryptographic assets secure and ready for future challenges.  

Reach out to us at [email protected] and let us build a comprehensive cryptographic inventory and customized roadmap that aligns with your organization’s needs and goals.   

Conclusion 

In present times, keeping track of your cryptography is something you can’t skip. An accurate, up-to-date cryptographic inventory helps you find and fix vulnerabilities early and stay prepared for the challenges posed by emerging quantum threats, all while keeping auditors and customers happy. 

The ultimate payoff of a cryptographic inventory is peace of mind and operational strength. With full visibility into your crypto assets, you can prevent outages and breaches before they happen. Whether you’re still figuring out where to start or ready to dive into implementation, the most important thing is to take that first step and keep the momentum going. And if you’re looking for a partner to walk that path with you, we are here.  

At Encryption Consulting, we are ready to help you move forward with clarity, proven expertise, and a plan that fits your goals. Let us get started and make sure your organization is secure, not just for today, but also for the future. 

How Poor Certificate Management Is Putting Your Compliance at Risk?

Digital certificates are central to modern security systems. They authenticate users, secure communications, and ensure compliance across industries. However, in most organizations, certificates are scattered across hybrid environments. They are unmanaged and poorly monitored. This “certificate chaos” not only risks outages but also subtly undermines compliance efforts.

The Shrinking Certificate Lifespan: From 825 Days Down to Just 47

Until a few years ago, TLS certificates could be issued for 825 days (over two years). Industry changes quickly reduced that, first to 398 days, then to 90 days, and now major browser vendors (led by initiatives like Google Chrome’s ACME automation and Apple) are moving toward a 47-day certificate validity.

In real-world terms, this shift means:

  • Much More Frequent Renewals: Teams now need to reissue and redeploy certificates every month and a half, as opposed to 90 days or once every two years.
  • Automation Is No Longer Optional: With such tight timeframes, manual certificate management is no longer feasible. Automated tools and protocols (like ACME) are necessary to keep up.
  • Stricter Compliance Scrutiny: Regulatory frameworks such as PCI DSS, HIPAA, and ISO 27001 demand continuous, interruption-free encryption. Even a single expired certificate can result in a compliance breach that may trigger audits or even financial penalties.

Certificate Management

Prevent certificate outages, streamline IT operations, and achieve agility with our certificate management solution.

The Problem: Shadow Certificates and Inventory Blind Spots

In many companies, different teams request and install certificates without a central system. This step can cause:

  • Duplicate or unused certificates are often left in production, which can be forgotten or misconfigured.
  • Shadow certificates created by developers using free services like Let’s Encrypt, outside the official PKI (public key infrastructure) process.
  • Untracked expiry dates, with certificates silently passing their expiration and breaking compliance.

For example, during a HIPAA audit, if an expired shadow certificate is found on a web-facing server, it’s considered a breach even if that system isn’t critical. Regulators judge compliance based on encryption controls for all systems.

Weak or Misconfigured Certificates: A False Sense of Security

Having a certificate isn’t enough if it’s poorly configured. Risks include:

  • Outdated hashing algorithms (like SHA-1) are now banned in many compliance frameworks.
  • Weak key lengths (e.g., 1024-bit RSA) are not considered “strong cryptography.”
  • Incorrect Extended Key Usage (EKU) values, meaning the certificate can be misused or doesn’t protect as intended.

Regulations like NIST SP 800-131A require specific standards (such as minimum 2048-bit RSA keys). A single weak or badly configured certificate puts the entire audit at risk, making your security look strong on paper but weak in practice.

The ACME Automation Challenge

Automatic certificate renewal with ACME (Automatic Certificate Management Environment) is now critical, as certificates expire more frequently. However, ACME comes with its hurdles:

  • There are complex integrations with many devices. Many enterprise devices, such as load balancers, API gateways, and IoT devices, don’t natively support ACME and require custom solutions to communicate.
  • There exist policy enforcement gaps. ACME can’t always force your company’s rules for naming, certificate providers, or approval chains.
  • There are mixed environments of the certificates. Some certificate types (like client authentication or code signing) still require manual workflows, leading to management inconsistencies.
  • It’s not enough to automate only some certificates. Compliance frameworks like SOX and PCI DSS demand consistent, reliable controls for every certificate. CertSecure Manager solves this with ACME-based automation, multi-CA integration, and uniform lifecycle management. Every certificate, internal or public, is renewed, tracked, and compliant by design.

The Compliance Frameworks at Risk

Let’s examine how certificate chaos leads to compliance failures:

  • PCI DSS 4.0: Payment systems need strong, up-to-date encryption. Expired or weak certificates on point-of-sale APIs are immediate violations.
  • HIPAA: Protected health information (PHI) must be encrypted. Expired certificates can break secure connections, potentially forcing insecure workarounds or service outages
  • SOX: Financial data integrity relies on secure reporting and control systems. A misconfigured certificate on an ERP server can affect financial sign-off and audit approval.
  • ISO 27001: Centralized management of crypto keys and certificates is required. Without inventory, it’s impossible to pass.

The Logging and Audit Gap

Even organizations that renew certificates on time often lack robust logs. For compliance, you must answer:

  • When was this certificate issued?
  • Who approved it?
  • Which system does it protect?

If these answers aren’t instantly available, you fail the audit. Centralized, immutable logging and management are now essential.

The Future of Encryption: PQC & Strong Security

What’s next? Regulations are changing quickly. Post-Quantum Cryptography (PQC) involves new encryption techniques designed to withstand attacks from future quantum computers. Upgrading to these standards will be crucial as older cryptography methods become less secure. So, if you’re managing certificates with crypto agility now, your systems can adapt immediately when new standards are introduced.

How to Escape Certificate Chaos and Protect Compliance?

To regain control and future-proof your compliance:

  • Centralize your certificate inventory. Track every certificate, no matter where it lives.
  • Automate the lifecycle with ACME or enterprise orchestration, so renewals and revocations happen reliably.
  • Enforce policy; this means only use approved cryptography, algorithms, and certificate authorities.
  • Enable audit and logging to track every certificate request, approval, issuance, and deployment, which is best achieved with a robust CLM solution like CertSecure Manager.
  • Simulate expirations and failures to test your processes before an outage or audit exposes a weakness.

Certificate Management

Prevent certificate outages, streamline IT operations, and achieve agility with our certificate management solution.

How CertSecure Manager Helps You Stay Compliant?

CertSecure Manager by Encryption Consulting is a certificate lifecycle management product. It simplifies and automates the entire lifecycle, allowing you to focus on security rather than renewals.

  • Automation for Short-Lived Certificates: With ACME and 90-day/47-day TLS certificates becoming the standard, manual renewal is no longer a practical option. CertSecure Manager automates enrolment, renewal, and deployment to ensure certificates never expire unnoticed.
  • Seamless DevOps & Cloud Integration: Certificates can be provisioned directly into Web Servers and cloud instances, and they integrate with modern logging tools like Datadog, Splunk, ITSM tools like ServiceNow, and DevOps tools such as Terraform and Ansible.
  • Multi-CA Support: Many organizations utilize multiple CAs (internal Microsoft CA, public CAs such as DigiCert and GlobalSign, etc.). CertSecure Manager integrates across these sources, providing a single pane of glass for issuance and lifecycle management.
  • Unified Issuance & Renewal Policies: CertSecure Manager enforces your organization’s key sizes, algorithms, and renewal rules consistently across all certificates, not just automating renewals with multiple CAs, but ensuring every certificate meets your security standards every time.
  • Proactive Monitoring & Renewal Testing: Continuous monitoring, combined with simulated renewal/expiry testing, ensures you identify risks before certificates impact production systems.
  • Centralized Visibility & Compliance: One consolidated dashboard displays all certificates, key lengths, strong and weak algorithms, and their expiry dates. Audit trails and policy enforcement simplify compliance with PCI DSS, HIPAA, and other frameworks.

Conclusion

Certificate management is now about much more than avoiding website errors; it’s about protecting security, passing audits, and adapting to new encryption standards. Allowing certificates to proliferate across teams, systems, or clouds puts every compliance framework at risk.

With certificate lifespans shrinking, volumes rising, and cryptography evolving, manual management can’t keep up. Centralized automation and strong policies are essential to prevent certificate chaos and ensure your business stays secure, compliant, and future-ready. Get Encryption Consulting’s advisory and Certificate Lifecycle Management services to safeguard your organization today. For more information, contact us here.

47 Day Certificates: Why automation is crucial for the transition

SSL/TLS certificate lifespans are getting shorter. After years of Google advocating for shorter lifespans such as 90 days, and Apple setting a 398-day limit in Safari, the industry believed things had settled. Then Google suggested 90-day certificates through their “Moving Forward Together” program. In October 2024, Apple surprised everyone with a GitHub ballot proposing 45-day certificates. The responses were mixed, but the final 47-day certificate ballot passed the CA/B Forum in April 2025 and became official on May 11. By 2029, TLS certificates will last only 47 days, down from over a year today.

How it affects the industry

The change to 47-day certificate lifespans brings major operational challenges that will change how organizations handle their digital infrastructure. Manual processes that used to work well with yearly renewals could now lead to widespread outages. IT teams struggle to keep up with certificates expiring every six to seven weeks. The complexity of integration grows when organizations need to coordinate certificate renewals across many systems and services in such short timeframes. Legacy systems that weren’t built for regular certificate updates cannot keep up with this new reality.

For organizations, automation is now essential because manual certificate management is not only inefficient but also risky. Hence, companies need to invest significantly in automated certificate lifecycle management tools and improve their monitoring infrastructure to ensure that no certificates go unnoticed. The financial impact is significant. Organizations need to quickly invest in new certificate management systems. Certificate authorities must also expand their infrastructure to manage nearly eight times the current issuance volume. Organizations with strong automation practices will gain important advantages. Meanwhile, those that are slow to change may lose customers because of reliability problems.

The Key Solution: Automation

As certificate lifespans shrink to 47 days or even less, managing them manually becomes impractical and risky. Automation is now critical for maintaining security, uptime, and scalability in modern digital infrastructure. Here is how automation will play a significant role in adapting to the change:

Automated systems remove the main risk by renewing certificates well before they expire. This prevents unexpected outages from missed deadlines that could cripple business operations. This proactive method eliminates human error and ensures continuous service availability.

Continuous monitoring capabilities provide real-time tracking of certificate status and health across the entire infrastructure. Teams receive instant alerts when issues arise instead of finding problems after they happen. This enables a quick response to possible security threats.

The benefits of deployment are just as strong. Automation allows for the immediate rollout of new certificates to all relevant endpoints. This removes the manual errors found in traditional certificate management and reduces downtime during certificate updates.

Policy enforcement becomes smooth with automated systems that consistently apply organizational standards and regulatory requirements. This removes the inconsistencies from manual processes and ensures compliance for all certificate deployments.

Automating your PKI infrastructure

End-to-end automation of your PKI infrastructure needs careful thought and planning to achieve smooth implementation without hurting security or operations. Although the transition involves many complex factors, there are key steps that offer a simple base for any organization wanting to update their certificate lifecycle management. These basic steps can be modified and further extended to meet your specific infrastructure needs and security requirements; by taking a structured approach, organizations can set up reliable automated processes that manage the upcoming 47-day certificate challenge while building a strong foundation for future PKI needs.

  1. Use certificate discovery tools to fetch all certificates existing in the infrastructure.
    Deploy discovery tools that can scan your entire network infrastructure, including web servers, load balancers, APIs, and databases, to find all existing certificates. These tools should produce detailed inventory reports that show certificate locations, expiration dates, and issuing authorities. They should also identify any shadow IT certificates that may have been deployed without proper oversight.
  2. Use Certificate Lifecycle Management solutions to centralize issuance, renewal and revocation.
    Implement a centralized CLM platform that acts as the single source of truth for all certificate operations in your organization. This solution should connect with multiple Certificate Authorities, support different certificate types, and offer role-based access controls. It should also keep detailed audit trails for compliance needs.
  3. Set up renewal agents to handle CSR generation, submission to CAs, and automatic renewal for the required endpoints.
    Configure intelligent renewal agents that can automatically create Certificate Signing Requests with the right key strengths. They should submit these requests to the correct Certificate Authorities and manage the entire renewal process without human help.
  4. Use deployment automation tools or renewal agents to push renewed certificates to endpoints and reload dependent services automatically.
    Establish automated deployment pipelines that can securely distribute renewed certificates to all relevant endpoints, including web servers, load balancers, and container platforms. The system should automatically handle service restarts and implement rollback options in case of deployment failures to ensure continuous service availability.
  5. Implement monitoring systems to track certificate health, issue timely alerts for expiring or misconfigured certificates, and maintain audit logs for compliance.
    Deploy monitoring solutions that continuously check certificate chain integrity, verify revocation status, and monitor SSL/TLS configuration health at all endpoints. The system should offer customizable alerting thresholds for different certificate types and keep detailed logs for regulatory compliance and security review.
  6. Use policy enforcement to ensure certificates meet cryptographic standards and apply access controls.
    Establish automated policy enforcement to check all certificates against your security standards. This includes minimum key lengths, approved Certificate Authorities, and necessary cryptographic algorithms. The system should automatically reject certificates that do not meet these standards and offer role-based access controls to manage certificate operations.

Certificate Management

Prevent certificate outages, streamline IT operations, and achieve agility with our certificate management solution.

How can Encryption Consulting help?

CertSecure Manager by Encryption Consulting provides automated certificate renewal for multiple endpoints, including IIS web servers, Apache web servers, F5 load balancers, and many more. CertSecure Manager’s renewal agents fully automate certificate renewal, revocation, and deployment for all of your SSL/TLS endpoints. This automation reduces manual work, prevents configuration errors, and ensures secure certificate deployment across your infrastructure, helping you stay compliant and avoid downtime caused by expired certificates during short renewal cycles.

Beyond certificate lifecycle automation, Encryption Consulting also provides PKI-as-a-Service (PKIaaS) and expert PKI consulting to build, manage, and optimize secure, scalable PKI environments tailored to your needs: on-prem, hybrid, or cloud.

Conclusion

The move to 47-day SSL/TLS certificate lifespans by 2029 represents a key change in managing digital infrastructure. Organizations can no longer rely on manual processes; automation is now vital for survival in this new environment. Although the operational and financial challenges are considerable, early adopters of complete PKI automation will achieve significant competitive advantages.

The message is clear: change now or face widespread outages and security risks. Companies that use automation today will create stronger, more secure systems. Those that wait will have reliability problems and will lose customer trust. The 47-day certificate era is not just a compliance issue; it’s a chance to modernize and prepare your digital operations for the future.

Why Do Organizations Need PQC Assessment in 2025?

Introduction: A Quantum Countdown for Cybersecurity

In 2025, cybersecurity leaders and industries face a turning point. The once-theoretical threat of quantum computing has become an urgent business risk. Breakthroughs by tech giants (e.g., Google’s 2024 “Willow” quantum chip) and government initiatives signal that a post-quantum world is approaching much faster than previously expected. For Chief Information Security Officers (CISOs) in industries like finance and healthcare, this means now is the time to assess and plan for post-quantum cryptography (PQC). Failing to prepare could leave critical systems and sensitive data exposed when quantum computers finally arrive.

This blog post explains why PQC assessments are imperative in 2025, highlighting the quantum threats to current cryptography, the harvest now, decrypt later risk, evolving standards like NIST’s PQC algorithms and NSA’s CNSA 2.0, regulatory drivers in industries like finance and healthcare, and a roadmap for quantum-readiness. The goal is to equip cybersecurity professionals with a strategic and technical overview of PQC readiness that ensures organizational resilience and compliance in the quantum era

The Urgency of Post-Quantum Cryptography in 2025

By 2025, post-quantum cryptography is no longer a far-off concern—it’s a present-day strategic priority. Quantum computing leverages quantum mechanics to perform computations at speeds infeasible for classical computers, meaning tasks that would take modern supercomputers years can be done in minutes or days on a sufficiently powerful quantum computer. While this promises great benefits for science and industry, it also presents a monumental security threat.

Experts warn that a cryptanalytically relevant quantum computer (CRQC) will be capable of breaking essentially all of today’s widely used public-key cryptography. In a 2022 U.S. National Security Memorandum, the White House cautioned: “A quantum computer of sufficient size and sophistication will be capable of breaking much of the public-key cryptography used across the United States and around the world”, jeopardizing everything from military communications to financial transactions and critical infrastructure controls.

Crucially, the timeline is tightening. Many analysts initially thought practical quantum attacks were decades away, but recent advances have shortened those projections. Some experts suggest state adversaries “may have quantum decryption capabilities as early as 2028”. Recognizing this, government agencies and standards bodies have set firm deadlines for transitioning to quantum-safe cryptography. In a landmark move, NIST announced that algorithms like RSA, Diffie-Hellman (DH), elliptic-curve cryptography (ECC/ECDSA), and EdDSA will be deprecated by 2030 and disallowed after 2035.

This aligns with U.S. National Security Memo-10, which targets 2035 for federal systems to be quantum-resistant. In other words, the world has a 10-year (or less) runway to replace vulnerable encryption—an extremely short window given the complexity of upgrading cryptographic infrastructure. The countdown to PQC is on, and organizations must act with urgency.

Quantum Computing Threats to Current Cryptography

Why is quantum computing such a game-changer for security? The answer lies in algorithms like Shor’s algorithm, which allows a quantum computer to factor large numbers and compute discrete logarithms exponentially faster than any classical method. This directly threatens the security of RSA (which relies on the difficulty of factoring) and ECC (which relies on discrete log problems) – the very foundations of digital security for everything from bank websites to medical device firmware. Once sufficiently powerful quantum computers exist, “traditional asymmetric cryptographic methods for key exchange and digital signatures will be broken”, as one industry source bluntly states.

With Shor’s algorithm, a quantum computer could, for example, break RSA-2048 encryption in a matter of hours. No feasible increase in key size will help; no reasonable key size would suffice to keep data secure against a quantum attacker. Similarly, elliptic-curve-based schemes (ECDH, ECDSA) would be defeated, undermining the authentication and key exchange mechanisms that secure internet traffic, financial transactions, and healthcare communications. NIST itself has noted that current public-key algorithms defined in standards like FIPS 186-4 (Digital Signature Standard) and SP 800-56A/B (key establishment) “are vulnerable to attacks from large-scale quantum computers”.

It’s important to note that symmetric cryptography (e.g., AES) and hash functions are less vulnerable; a quantum algorithm called Grover’s algorithm can speed up brute force attacks, but only by squaring the effort (effectively halving the security bit strength). Thus, an AES-256 key still provides ~128-bit security against quantum attacks, which is considered acceptable. Current hash functions like SHA-256/SHA-3 are also believed to remain secure against known quantum techniques.

The real crisis is with public-key (asymmetric) cryptography: RSA, ECC, Diffie-Hellman, DSA, all fall to Shor’s algorithm. These algorithms pervade our security architecture from TLS certificates, VPNs, and blockchain signatures to the secure boot process of medical devices. Thus, a quantum computer attack would shatter digital trust, allowing attackers to impersonate servers, decrypt confidential data, forge signatures, and generally undermine the foundations of cybersecurity in finance, healthcare, and beyond.

“Harvest Now, Decrypt Later”: Today’s Threat, Not Tomorrow’s

One might be tempted to think: if large-scale quantum computers (so-called CRQCs) are not here yet in 2025, can’t we wait a bit longer? The answer from security experts is a “No”, largely due to the “harvest now, decrypt later” threat model. Also called “catch now, break later,” this refers to adversaries stealing encrypted data today and storing it, knowing that in the future they will have the quantum tools to decrypt it.

In other words, even if a hacker or nation-state cannot read certain sensitive records now, they may be stockpiling your encrypted bank records, customers’ personal data, or patients’ health information with the intention of unlocking it once quantum decryption is feasible. Intelligence agencies are likely already doing this against high-value targets. Indeed, a recent industry report notes that malicious actors are “already said to be collecting encrypted data and storing it for the time when future quantum computers will be capable of breaking our current encryption methods”.

This means the risk is present today; any data that needs to remain confidential for years or decades (e.g., financial transactions logs, PII, health records, intellectual property, state secrets) is at risk of future exposure if intercepted now.

Cybersecurity authorities warn that early planning is critical because of this delayed-impact threat. The U.S. CISA, NSA, and NIST jointly stated in 2023 that “cyber threat actors could be targeting data today that would still require protection in the future, using a catch now, break later or harvest now, decrypt later operation”. For industries like healthcare, where patient records may retain value for a lifetime, or financial services, where certain transactions and communications must stay secure for many years, quantum risk is essentially a “time bomb”.

Additionally, many organizations have long technology refresh cycles, for example, critical banking systems or medical devices might be in service for 10-20 years. If those are built with only classical encryption, they could become security liabilities in their operational lifetime. As the NSA succinctly put it, given foreign pursuits in quantum computing, now is the time to plan, prepare, and budget for a transition to quantum-resistant algorithms. Waiting until a CRQC is publicly announced will be far too late; the sensitive data you secure today must be protected against the capabilities of tomorrow.

Standards and Frameworks: Guiding the PQC Transition

Fortunately, the cybersecurity community isn’t starting from scratch; standards bodies and government agencies have been preparing for the quantum era. As of 2025, organizations can look at several authoritative frameworks for guidance on which post-quantum cryptography algorithms to adopt and how to transition.

NIST’s Post-Quantum Cryptography Program

The U.S. National Institute of Standards and Technology (NIST) has led a multi-year global effort to standardize PQC algorithms. After evaluating dozens of candidates in an open competition, NIST announced its first selections, a key-establishment mechanism CRYSTALS-Kyber and three digital signature schemes CRYSTALS-Dilithium, FALCON, and SPHINCS+. These algorithms were chosen for their strong security against both classical and quantum attacks, as well as their acceptable performance. NIST wasted no time moving forward. By August 2023, it had already released draft standards for three of the new algorithms. In August 2024, NIST published FIPS 203, 204, and 205, which formally standardized:

  • Module-Lattice-Based Key Encapsulation Mechanism (ML-KEM) – based on CRYSTALS-Kyber.
  • Module-Lattice-Based Digital Signature (ML-DSA) – based on CRYSTALS-Dilithium.
  • Stateless Hash-Based Digital Signature (SLH-DSA) – based on SPHINCS+ (a stateless hash-based signature).

This was a historic milestone: for the first time, we have official standards for quantum-resistant encryption and signatures, providing a clear path for vendors and organizations to implement PQC. NIST is continuing its work, running a 4th round to standardize additional algorithms (e.g., a code-based KEM called HQC was selected in 2025). NIST’s timeline is driven in part by White House directives; a recent NIST report noted that the transition must support “NSM-10’s goal of transition of USG systems to PQC by 2035”.

In practical terms, NIST’s guidance means enterprises should align their crypto strategy with these vetted algorithms. The new PQC standards are intended to protect sensitive government information well into the foreseeable future, including after the advent of quantum computers, and what protects the government will likewise protect industry. Many security products will likely incorporate NIST-approved PQC in the coming years, if they haven’t already.

NSA’s CNSA 2.0 Suite

Another key framework comes from the U.S. National Security Agency. In September 2022, NSA announced the Commercial National Security Algorithm Suite 2.0 (CNSA 2.0) – its blueprint for cryptography to protect classified and national security systems in the quantum era. Notably, CNSA 2.0 for the first time includes post-quantum algorithms, reflecting NSA’s confidence in the NIST selections. The suite specifies using CRYSTALS-Kyber for key exchange and CRYSTALS-Dilithium for digital signatures, as well as certain hash-based signature schemes (XMSS and LMS) for specific use cases. NSA chose these algorithms because they have been analyzed and deemed secure against both classical and quantum attacks.

CNSA 2.0 comes with a timeline, National Security Systems (NSS) operators are expected to fully transition to these quantum-resistant algorithms by 2033, with some high-priority cases as early as 2030. Until the new standards are fully in place, NSA advises continuing to use CNSA 1.0 (the current Suite) but to pay attention to NIST selections and to the future requirements outlined in CNSA 2.0. NSA’s message is clear: if you handle sensitive government data, start testing and integrating PQC as soon as possible.

They explicitly encourage testing in operational systems as soon as available, even as NIST finalizes standards. However, NSA also cautions not to deploy unvetted algorithms in production until NIST and the National Information Assurance Partnership (NIAP) have validated them, underscoring the need to strike a balance between urgency and carefulness. For industry CISOs, NSA’s stance is a trendsetter. If the agency responsible for securing the nation’s most sensitive communications is mandating a crypto transition now, private sector firms (especially in critical industries) should take note.

International and Industry Standards

Beyond NIST and NSA, there is global momentum on PQC standards. ISO/IEC, the international standards body, has begun incorporating quantum-safe cryptography into its standards portfolio. For example, ISO approved stateful hash-based signatures (like XMSS and LMS) are acknowledged in the standard ISO/IEC 14888-4:2024 as viable quantum-resistant signature methods. We can expect ISO/IEC to follow NIST by standardizing lattice-based schemes as well, providing internationally recognized specs that align with NIST’s algorithms.

The European Union has also stepped up: in April 2024, the European Commission issued a Recommendation (EU 2024/1101) outlining a coordinated roadmap for member states to transition to PQC for protecting critical digital infrastructures. In June 2025, the EU rolled out a plan targeting 2030 for widespread PQC adoption in Europe’s public and private sectors. This mirrors the U.S. timeline and signals that regulators globally expect quantum-safe encryption by the early 2030s.

Industry groups are likewise proactive. The G7 Cyber Expert Group, for instance, issued a “call to action” in 2023 urging the financial sector worldwide to monitor quantum computing risks and begin planning for PQC. In the tech community, standards for implementing PQC in internet protocols are underway (e.g., the IETF is working on hybrid TLS and VPN standards that combine classical and PQC algorithms for a transition period). ETSI (European Telecommunications Standards Institute) has a working group publishing guidelines on quantum-safe cryptography for networks.

All these efforts build a consensus: cryptographic agility and quantum-resistant algorithms must become the norm. The key takeaway for organizations is that authoritative guidance and standards are available now; you should leverage these in your crypto assessments rather than reinventing the wheel. By aligning with NIST’s chosen algorithms and following frameworks like NIST, CNSA 2.0 or ISO’s recommendations, you’ll be on a vetted, consensus-backed path to security.

Official deadlines for phasing out quantum-vulnerable encryption: NIST plans to deprecate RSA, ECC, and related algorithms by 2030 and disallow them by 2035. Finance and government leaders worldwide have set similar targets, making 2030 a pivotal deadline for quantum safety.

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Regulatory Drivers in Finance and Healthcare

For CISOs in the financial and healthcare sectors, the push for PQC readiness isn’t just coming from technology risk assessments; it’s increasingly driven by regulatory expectations and compliance trends. Financial regulators and industry bodies are sounding alarms about quantum threats, while healthcare authorities are embedding crypto-agility into cybersecurity requirements. Let’s look at each sector:

Financial Services: Protecting the Integrity of Finance

Financial institutions have long been guardians of data confidentiality and transaction integrity. With quantum computing on the horizon, regulators and industry consortia are urging finance to lead the charge on PQC adoption. A notable example is the Financial Services Information Sharing and Analysis Center (FS-ISAC), which in late 2024 released a whitepaper on Building Cryptographic Agility in the Financial Sector. The guidance bluntly states that, the move to crypto agility must begin immediately because quantum computing is likely to make a commonly used class of cryptography algorithms insecure in the next few years.

In other words, FS-ISAC warns its member banks that RSA/ECC could be broken within this decade, potentially exposing sensitive financial data and disrupting the trust that underpins banking. The whitepaper, authored by experts from major global banks, frames crypto-agility (the ability to rapidly swap out cryptographic algorithms) as a business continuity and trust issue.

It asserts that the financial sector must treat PQC migration not as a one-off tech upgrade, but as part of a long-term strategy to ensure the safety of business operations in today’s complex, ever-evolving computing environment. Global financial regulators are echoing these concerns. In early 2023, the G7 (Group of Seven) issued a public call encouraging financial firms to prepare for quantum risks and work with governments on a smooth transition. In Europe, law enforcement and banking overseers have been proactive.

In February 2025, Europol’s Quantum Safe Financial Forum (QSFF), a coalition of financial crime authorities and banks, issued an “urgent call to action” for the financial sector to coordinate a transition to PQC together. The QSFF highlighted that banks might be tempted to delay PQC migration due to more immediate issues (like ransomware, AI threats, or new regulations like Europe’s DORA and NIS2), but stressed that “the long-term risk of quantum computing cannot be ignored”.

The forum’s report warned that failure to start now could lead to a rushed and costly transition later, with higher operational risks. Among the challenges noted were the interdependency of financial networks (no bank can go it alone without partners) and the need for a common, coordinated approach to avoid fragmentation or inconsistent standards. One of the QSFF’s key recommendations is to use hybrid cryptography, combining classical and quantum-safe algorithms as a stepping stone, allowing gradual migration while maintaining interoperability.

U.S. regulators have also begun quietly integrating quantum readiness into their oversight. A July 2025 report from the U.S. Office of the Comptroller of the Currency (OCC) advised banks that while broad quantum computing implementation is “unlikely to be available in the near term,” they should be aware of the risk implications and consider how to effectively monitor developments in quantum computing as they manage future infrastructure investments. In practice, this means bank examiners expect institutions to include quantum risk in their strategic technology planning for instance, ensuring new systems are crypto-agile and setting aside budget for PQC upgrades.

Even the U.S. Treasury has pointed out this concern; the Treasury’s Cyber Expert Group (within the G7 context) emphasized monitoring quantum developments and starting planning efforts now. In sum, the finance sector is under growing pressure to treat quantum preparedness as part of operational resilience. Forward-looking banks are already inventorying their cryptography and running proof-of-concepts with PQC. Waiting until regulations mandate a switch could be perilous, given the lengthy timelines involved in replacing cryptographic systems across global financial networks.

Healthcare: Safeguarding Patient Data and Devices

The healthcare sector, from hospitals to medical device manufacturers, faces a unique dual imperative, protecting highly sensitive personal data and ensuring the safety and efficacy of life-critical devices. Both are at stake in the context of quantum threats, and regulators are beginning to respond. A stark example came in 2023 when the U.S. Food and Drug Administration (FDA) updated its medical device cybersecurity guidance. The FDA’s 2023 Premarket Cybersecurity Guidance explicitly requires manufacturers to ensure crypto agility throughout the product’s use and provides reasonable assurance that devices can be kept secure over their lifecycle.

Under Section 524B of the FD&C Act (as amended by recent legislation), the FDA can even refuse approvals for new medical devices that don’t meet cybersecurity expectations, specifically citing the use of deprecated cryptographic algorithms or lack of a forward-looking upgrade plan as grounds for rejection. In practice, this means if a medical device today is built solely on RSA or ECC with no path to PQC, the FDA might not allow it on the market.

Indeed, industry insiders report that some device submissions have already been flagged or delayed due to cryptographic deficiencies, such as using outdated algorithms or not documenting key management and update processes. Healthcare CISOs and product security leaders should take note: crypto agility and PQC planning are no longer optional from a compliance perspective, they’re becoming an expected part of due diligence.

Healthcare data privacy laws also implicitly drive PQC considerations. HIPAA, for example, mandates protection of electronic health information; while it doesn’t specify encryption algorithms, it effectively requires that any ePHI that is encrypted stays confidential. If quantum computing threatens encryption protecting years’ worth of stored patient records, healthcare entities could face compliance and liability issues for breaches if they don’t transition to stronger cryptography in time.

The long retention periods of medical records (often decades or a lifetime) mean healthcare data stolen now could still be sensitive when quantum attacks emerge, raising the specter of future privacy violations via harvest-now/decrypt-later tactics. Recognizing these risks, the U.S. Department of Health and Human Services (HHS) has echoed CISA/NSA’s advice for critical infrastructure. A 2023 joint factsheet (targeted at all critical sectors, including Healthcare & Public Health) urged organizations to begin preparing now by creating quantum-readiness roadmaps, conducting cryptographic inventories, and engaging vendors about PQC support.

Additionally, healthcare industry groups are raising awareness. The Health-ISAC (Health Information Sharing & Analysis Center) published insights describing quantum computing as a “coming healthcare cyberattack crisis”, noting that the technology “has the potential to break through legacy encryption technologies used to prevent healthcare industry cyberattacks. Their guidance suggests steps for healthcare professionals to avoid quantum-computing-powered cyberattacks, such as updating cryptographic systems and investing in new skills and technologies. Medical device makers, in particular, are advised to act early.

As one medical cybersecurity firm put it, “With NIST committing to deprecate non-quantum-resistant cryptography by 2030, [device manufacturers] need to act now to avoid product delays, expensive redesigns, or long-term risk exposure.” Leading manufacturers are implementing Cryptographic Bills of Materials (CBOMs), essentially an inventory of all crypto components in a device, including readiness for PQC, to streamline regulatory approval and internal upgrades. The bottom line is that healthcare regulators and stakeholders are increasingly viewing quantum resilience as part of patient safety and data protection. Just as one would patch a critical software vulnerability, one must remediate the “quantum vulnerability” in encryption before it can be exploited.

Roadmap for PQC Readiness: A Strategic Approach

Facing the quantum threat can seem daunting, but CISOs can tackle it with a structured, strategic approach. A PQC readiness assessment in 2025 should lead into a multi-year roadmap for migration. Below is a framework that cybersecurity leaders in finance, healthcare, and other sectors can follow:

  1. Build Awareness and Executive Support

    Begin by educating stakeholders and senior management about the quantum risk and why action is needed now, not later. Present the credible timelines (e.g., NIST’s 2030/2035 deadlines, NSA’s 2033 mandate, analysts predicting possible Q-day within ~5-10 years) and the concept of “harvest now, decrypt later” to illustrate the current exposure. Quantum risk should be framed as an operational resilience issue on par with other enterprise risks. Gaining leadership buy-in ensures you’ll have the necessary resources and urgency across the organization.

  2. Cryptographic Inventory (“Know What You Have”)

    You can’t fix what you can’t see. Form a project team to identify all systems, applications, and devices that rely on quantum-vulnerable cryptography. This includes any use of RSA, Diffie-Hellman, ECC (ECDH/ECDSA), DSA, or other asymmetric algorithms in your environment. Don’t forget less obvious places like VPN appliances, partner network connections, code signing certificates, client-side applications, IoT devices, medical equipment, etc.

    Also, inventory data stores, what encrypted data are you holding, and how long must it remain secure? NIST, CISA, and NSA emphasize creating this inventory as a first step, noting that organizations are often unaware of the breadth of their cryptography dependencies. Consider developing a Cryptographic Bill of Materials (CBOM) for critical systems, documenting each cryptographic component, key length, and its PQC readiness status. This inventory will be the foundation for risk assessment and migration planning.

  3. Assess Risk and Prioritize

    Not all crypto exposure is equal. Analyze the inventory to identify which systems and data are most critical to address first. Key factors include, the sensitivity and required secrecy lifetime of data (e.g., confidential patient data needed for decades, or financial transactional data subject to long-term secrecy laws), the criticality of the system’s function (e.g., a system supporting real-time payments or life support devices has near-zero tolerance for security failure), and the feasibility and impact of upgrading that system. This risk-based view helps prioritize what needs to transition to PQC first.

    For example, a financial firm might prioritize securing inter-bank communication links and confidential client data archives, whereas a hospital might focus on electronic health record databases and pacemaker communication protocols. Also consider third-party risks: engage with vendors and partners to understand their crypto roadmaps (are they offering PQC-enabled versions or upgrades?). Regulators recommend such engagement; organizations should “include engagements with supply chain vendors” as part of quantum readiness planning.

  4. Develop a Quantum-Readiness Roadmap

    With priorities set, create a formal migration roadmap. This should include timelines, milestones, and resource plans for deploying PQC solutions. Many agencies suggest establishing a cross-functional project team (crypto experts, IT architects, risk managers, compliance officers) to govern this effort. The roadmap may span several phases, including testing (e.g., pilot a PQC-enabled VPN or email encryption in 2025-26), dual-use and interoperability (running quantum-safe algorithms in parallel or in hybrid mode with classical ones), and full transition by the target dates (e.g., well before 2030 for high-value assets).

    Don’t wait for a perfect solution, plan to iterate. For instance, you might deploy hybrid cryptography (classical + PQC) in the interim if pure PQC support is not yet available in all products. Include contingency for updates as standards evolve (e.g., if NIST adds new algorithms or as performance of PQC improves). The plan should align with any external mandates, for example, if you operate in the US public sector, align with the 2035 deadline; in the EU, note the 2030 target for critical infrastructure.

  5. Invest in Cryptographic Agility

    A key principle throughout your roadmap should be crypto agility by design. This means building systems and applications in a way that algorithms can be changed with minimal disruption. Use modular cryptographic libraries and APIs that abstract the algorithm (so you can swap RSA for Kyber, for instance, without overhauling the entire system). If you have in-house developed software, update it to use modern crypto frameworks that support PQC algorithms or can be extended to do so. Ensure that key management systems and Hardware Security Modules (HSMs) are compatible with larger keys and different algorithm types. Some legacy HSMs may require upgrades or replacements to support PQC.

    Crypto agility also involves operational processes, make sure you can distribute new keys and certificates at scale when the time comes (certificate management will be critical as algorithms change). According to FS-ISAC, treating crypto-agility as an ongoing capability is the only way to enable business continuity when existing cryptography is compromised or weakened, essentially future-proofing your infrastructure against not just quantum, but any crypto flaw.

  6. Implement and Test PQC Solutions

    Begin rolling out quantum-safe solutions in a phased manner. Start with non-production or low-risk environments to test integration, performance, and interoperability. For example, a bank might deploy a PQC-enabled TLS cipher suite in a test environment between two internal applications, measuring the impact on latency and throughput. A hospital IT team could test a prototype of a PQC-secured telemetry link for medical IoT devices. Testing should address known challenges of PQC, such as larger key sizes and heavier computational load. (Many PQC algorithms, especially lattice-based ones, use bigger keys and signatures than RSA/ECC, which could affect network bandwidth and device storage.) Identify any bottlenecks early.

    It’s also wise to test fallback mechanisms: for instance, if a partner system isn’t PQC-ready, can your communication fall back to classical encryption securely, or use a hybrid mode? Continue to iterate on deployments – perhaps start by securing new systems or applications with PQC by default (so-called “crypto diversity”), while gradually retrofitting existing systems in priority order.

  7. Monitor Standards and Update Compliance Posture

    The PQC landscape will evolve through the 2020s. Assign someone (or a team) to track developments in standards, regulations, and threats. This means following NIST’s updates (e.g., new FIPS standards, NIST Special Publications on PQC migration), watching for ISO/IEC or ETSI standards you may need to comply with (especially if you operate internationally), and listening to sector-specific regulators. For finance, this could include bodies like the SEC, FFIEC, or central banks if they issue guidance on quantum readiness. For healthcare, monitor FDA updates, HHS/OCR guidance, or even changes to HIPAA/HITRUST requirements regarding encryption.

    Also keep an eye on threat intelligence: are there signs that adversaries are ramping up quantum research or that a smaller quantum computer was able to break a RSA-1024 key in a lab? Being aware will allow you to adjust your timeline, for example, accelerating certain migrations if quantum appears closer than expected. Regulators are likely to tighten requirements as we approach 2030; staying ahead of them not only ensures compliance but could be a competitive differentiator (demonstrating to clients/patients that you’re on the cutting edge of security).

  8. Collaborate and Share Knowledge

    Finally, recognize that PQC transition is an ecosystem problem. Engage in industry forums (like FS-ISAC for finance or Health-ISAC for healthcare) to share experiences and solutions. Collaboration helps avoid a fragmented approach where everyone solves the same problems in silos. Public-private partnerships are emerging to tackle quantum transition; for example, the U.S. DHS and NIST have initiatives via the National Cybersecurity Center of Excellence (NCCoE) to produce migration playbooks and tools.

    The Europol QSFF recommended a voluntary framework between regulators and the private sector to coordinate efforts rather than waiting for strict mandates. Take advantage of these resources. By working together, financial institutions can ensure, say, that payment networks and banks migrate in sync, and healthcare organizations can push vendors (EHR systems, device manufacturers) to deliver quantum-safe solutions on a reasonable timetable. Everyone benefits from a more secure cryptographic ecosystem.

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How can EC support PQC transition?

If you are wondering where and how to begin your post-quantum journey, Encryption Consulting is here to support you. You can count on us as your trusted partner, and we will guide you through every step with clarity, confidence, and real-world expertise.  

Cryptographic Discovery and Inventory

This is the foundational phase where we build visibility into your existing cryptographic infrastructure. We identify which systems are at risk from quantum threats and assess how ready your current setup is, including your PKI, HSMs, and applications. The goal is to identify what cryptographic assets exist, where they are used, and how critical they are. Comprehensive scanning of certificates, cryptographic keys, algorithms, libraries, and protocols across your IT environment, including endpoints, applications, APIs, network devices, databases, and embedded systems.

Identification of all systems (on-prem, cloud, hybrid) utilizing cryptography, such as authentication servers, HSMs, load balancers, VPNs, and more. Gathering key metadata like algorithm types, key sizes, expiration dates, issuance sources, and certificate chains. Building a detailed inventory database of all cryptographic components to serve as the baseline for risk assessment and planning.

PQC Assessment

Once visibility is established, we conduct interviews with key stakeholders to assess the cryptographic landscape for quantum vulnerability and evaluate how prepared your environment is for PQC transition. Analyzing cryptographic elements for exposure to quantum threats, particularly those relying on RSA, ECC, and other soon-to-be-broken algorithms. Reviewing how Public Key Infrastructure and Hardware Security Modules are configured, and whether they support post-quantum algorithm integration. Analyzing applications for hardcoded cryptographic dependencies and identifying those requiring refactoring. Delivering a detailed report with an inventory of vulnerable cryptographic assets, risk severity ratings, and prioritization for migration.

PQC Strategy & Roadmap

With risks identified, we work with you to develop a custom, phased migration strategy that aligns with your business, technical, and regulatory requirements. Creating a tailored PQC adoption strategy that reflects your risk appetite, industry best practices, and future-proofing needs. Designing systems and workflows to support easy switching of cryptographic algorithms as standards evolve. Updating security policies, key management procedures, and internal compliance rules to align with NIST and NSA (CNSA 2.0) recommendations. Crafting a step-by-step migration roadmap with short-, medium-, and long-term goals, broken down into manageable phases such as pilot, hybrid deployment, and full implementation.

Vendor Evaluation & Proof of Concept

At this stage, we help you identify and test the right tools, technologies, and partners that can support your post-quantum goals. Helping you define technical and business requirements for RFIs/RFPs, including algorithm support, integration compatibility, performance, and vendor maturity. Identifying top vendors offering PQC-capable PKI, key management, and cryptographic solutions. Running PoC tests in isolated environments to evaluate performance, ease of integration, and overall fit for your use cases. Delivering a vendor comparison matrix and recommendation report based on real-world PoC findings.

Pilot Testing & Scaling

Before full implementation, we validate everything through controlled pilots to ensure real-world viability and minimize business disruption. Testing the new cryptographic models in a sandbox or non-production environment, typically for one or two applications. Validating interoperability with existing systems, third-party dependencies, and legacy components. Gathering feedback from IT teams, security architects, and business units to fine-tune the plan. Once everything is tested successfully, we support a smooth, scalable rollout, replacing legacy cryptographic algorithms step by step, minimizing disruption, and ensuring systems remain secure and compliant. We continue to monitor performance and provide ongoing optimization to keep your quantum defense strong, efficient, and future-ready.

PQC Implementation

Once the plan is in place, it is time to put it into action. This is the final stage where we execute the full-scale migration, integrating PQC into your live environment while ensuring compliance and continuity. Implementing hybrid models that combine classical and quantum-safe algorithms to maintain backward compatibility during transition. Rolling out PQC support across your PKI, applications, infrastructure, cloud services, and APIs. Providing hands-on training for your teams along with detailed technical documentation for ongoing maintenance. Setting up monitoring systems and lifecycle management processes to track cryptographic health, detect anomalies, and support future upgrades.

Transitioning to quantum-safe cryptography is a big step, but you do not have to take it alone. With Encryption Consulting by your side, you will have the right guidance and expertise needed to build resilient, future-ready security posture.  Reach out to us at [email protected]and let us build a customized roadmap that aligns with your organization’s specific needs.  

Conclusion: Ensuring Future-Ready Security Now

In the cybersecurity field, professionals are often balancing immediate threats (malware, ransomware, zero-day exploits) against long-term strategic risks. Quantum computing may be the ultimate strategic risk; it’s a looming paradigm shift that will redefine what “secure” means. The year 2025 marks a pivotal moment: we have enough information and tools to begin acting (with NIST standards, proven PQC algorithms, and clear government roadmaps), but we also have a finite timeline before the risk materializes.

For CISOs and security leaders, especially in finance and healthcare, post-quantum readiness has to become a priority alongside today’s threats. As one industry executive noted, “quantum risk is an operational resilience issue, not a distant problem just as ransomware and AI-driven threats demand immediate action, so does quantum readiness”.

Organizations that start their PQC assessment and migration now will be far better positioned to avoid chaos and high costs down the road. By 2030, regulators will likely expect compliance with quantum-safe standards, early movers will meet those expectations smoothly, while laggards scramble. Moreover, customers and partners are beginning to ask about crypto-agility and quantum plans as part of due diligence. Demonstrating that your bank or healthcare system has a credible quantum-safe crypto roadmap can enhance trust and reputational assurance. On the other hand, ignoring the issue could mean that data you thought was secure (your clients’ financial records, your patients’ health information) might be decrypted by adversaries in a decade, with disastrous consequences for privacy and trust.

In summary, organizations need PQC assessment in 2025 because the quantum threat is no longer hypothetical, and the defensive solutions are at hand. The risk to current cryptography is existential, but with prudent planning – guided by standards, nudged by regulations, and executed with strategic focus, we can achieve crypto-agility and quantum-resistant security before it’s too late.

The transition to post-quantum cryptography is a complex journey, but it is also an opportunity: an opportunity to strengthen our cryptographic foundations, modernize systems, and ensure that the critical data of our financial and healthcare systems remain secure not just today, but for the decades to come. As the saying goes, “the best time to plant a tree was 20 years ago; the second best time is now.” The same goes for planting the seeds of quantum-safe security; the time to act is now, in 2025, to safeguard our organizations for the quantum future.

A Cryptographic Inventory Checklist for the Post-Quantum Era

Digital transformation has pushed cryptography into the spotlight as the unseen foundation of business security. Yet, for many organizations, this critical layer is a vast, unmapped territory. As we stand at the precipice of the quantum era, this lack of visibility is no longer a manageable risk, but it’s an existential threat. A comprehensive cryptographic inventory is not just a checklist, it’s the blueprint that will guide your organization’s journey to post-quantum readiness.

While the strategic importance of this inventory is clear, the real challenge lies in the execution. This detailed checklist goes beyond the “why” and provides a practical “what” and “how” to ensure your inventory is thorough, actionable, and robust enough to stand against the challenges ahead.

Understanding Key Inventory Principles

Before you begin collecting data, establish a clear framework. This isn’t a one-time task; it’s an ongoing process that requires continuous improvement and visibility. Your approach should be guided by these core principles:

  • The Six W’s of Crypto: Every cryptographic asset in your organization must be documented with these six key details:
    1. What is the cryptographic component? This includes specific keys, digital certificates, software libraries, hardware security modules (HSMs), etc.
    2. Where is it located? This identifies its placement, whether in a specific application, on a server in a data center, within a cloud vault like Azure Key Vault, etc.
    3. When was it created, and when will it expire or be rotated? This is crucial for identifying long-lived keys that are prime targets for “harvesting.”
    4. Who is the owner or party responsible for its management and lifecycle?
    5. Why is it being used? This defines its purpose, such as protecting sensitive data for regulatory compliance like GDPR, authenticating a user, ensuring transactional integrity, and more.
    6. How is it being used? This specifies the technical details, including the specific algorithm, key length, protocol version configured, and more.
  • Acknowledge Your Scope: Clearly define what’s under your direct control (your own keys, hardware, and applications) versus what’s managed by a third-party vendor. For third-party services, you must document them as “black boxes,” and your responsibility is to get a risk statement, a detailed remediation plan, and a PQC roadmap from the provider.
  • Standardize and Simplify: Use consistent business processes and deployment methods wherever possible. This is the essence of crypto agility. By standardizing your approach, you simplify not only the inventory process but also future updates, patching, and new deployments.
  • Be Comprehensive: Your inventory must reflect all components that could be negatively impacted by PQC advances, from legacy systems to cutting-edge technologies. No system is too small or too old to ignore.

Building Your Inventory

A single scanning tool or method won’t give you the full picture. A truly comprehensive inventory requires a multi-layered approach that combines various techniques to eliminate blind spots.

Public Key Infrastructure (PKI)

Your PKI is the digital identity system for your organization, enabling secure communication and authentication. It’s a critical area for inventory because it relies on asymmetric encryption, which is highly vulnerable to quantum attacks.

  • Crypto Asset List: Create a meticulous inventory that lists all applications and communications channels that use asymmetric cryptography. This includes TLS/SSL certificates for web servers, code-signing certificates, and keys used for digital signatures and authentication.
  • Key Management Audit: Verify and document your entire PKI process, including how keys are generated, stored, and rotated. Your most critical keys, such as root signing keys, should be stored in a trusted Hardware Security Module (HSM), which provides a higher level of security. Examining HSM logs can be a powerful method for discovering which applications are making cryptographic calls.
  • Certificate Lifecycle Management: Document the validity periods of all your certificates. This is particularly crucial for identifying long-lived certificates (e.g., 25 years or longer), as these are prime targets for “harvesting” attacks. Just as important as validity periods is the key size and algorithm used. Even with shorter lifecycles, certificates that rely on RSA (2048/3072/4096-bit) or ECC (P-256, P-384) are still vulnerable to quantum attacks, since Shor’s algorithm can break them regardless of key length. To mitigate this, create a process not only to regularly review and re-issue certificates with shorter lifecycles but also to catalog the algorithms and key sizes in use. This visibility will help prioritize which certificates pose the greatest quantum risk and should be transitioned first to quantum-resistant or hybrid cryptographic models.

Application Development (AppSec)

Cryptography is often embedded deep within applications, making it hard to find and manage. To build an effective inventory, you’ll need to leverage multiple discovery methods:

  • Self-Identification: A simple and effective starting point is to expand your existing application inventory. Require application owners to explicitly record whether their application uses encryption, what type it is, and a brief description of its usage. This first-line data provides a crucial starting point for more technical discovery.
  • Static Scanning: Integrate static code analysis tools into your CI/CD pipelines. These tools can scan code to find cryptographic function calls. While they may not be perfectly precise (e.g., they might show all available algorithms in a library, not just those in use), they are an excellent way to quickly identify which applications are calling algorithms that are no longer considered PQC-safe, like RSA and ECDSA.
  • Dynamic Analysis: For a more accurate, run-time view, use Interactive Application Security Testing (IAST) tools. These tools have visibility into the cryptographic functions that are actually being used by an application, including calls from third-party libraries and framework components. This approach complements static scanning by showing “what’s really happening.”
  • Software Bill of Materials (SBOM): As SBOMs become more widespread, they will provide a valuable “list of ingredients” for software components. You can use this to map cryptographic libraries and identify known vulnerabilities.
  • File System Discovery: Use file system scans with tools like Tanium or Varonis to find cryptographic components like keys, key stores, and certificates. Be aware that this method can produce a lot of noise, so it’s best used in conjunction with other methods to confirm what’s actually in use.

Other Critical Considerations

Cryptography isn’t limited to traditional servers and applications. Your inventory must also account for these specialized asset classes:

  • SaaS Providers: Don’t assume your data is safe just because it’s in the cloud. Document the encryption algorithms used by your SaaS providers. Understand their key management model: is it SaaS-managed, Bring Your Own Key (BYOK), or do they allow for customer-managed keys? Ask for their PQC plan and timeline, especially if they use older algorithms.
  • Hardware Security Modules (HSMs): HSMs contain an organization’s most important keys. They must be included in your inventory. Beyond simply listing the HSMs, you should examine their logs to identify which applications are making calls to perform cryptographic functions, providing a more detailed view of usage.
  • APIs, IoT, and Blockchain: These are separate asset classes that each present unique PQC risks. For APIs, document their use of encryption and ensure their connection ciphers are strong. For IoT, catalog all devices and their embedded crypto, as updating firmware can be a challenge. For blockchain, you must understand its usage of public-key cryptography, which is vulnerable to PQC risks.

The Journey of Continuous Improvement

Building and maintaining this inventory is a journey, not a destination. It requires continuous effort and a well-defined process to remain accurate and relevant.

  • Start with a CBOM: Use your initial inventory to create a Cryptographic Bill of Materials (CBOM), which provides a comprehensive, structured view of your crypto usage.
  • Frequency of Scans: Determine the appropriate frequency of scans based on risk and change activity. More critical areas should be scanned more often.
  • Address Blind Spots: Acknowledge that some keys may be offline or in inaccessible locations. Develop alternative methods to find them or make assumptions where validation isn’t possible.
  • Develop Awareness: Provide training to your development and security teams to embed crypto agility into your culture and processes.
  • Monitor and React: Create a process for handling exceptions and alerts triggered by monitoring (e.g., an algorithm being deprecated or a key expiring).

PQC Advisory Services

Prepare for the quantum era with our tailored post-quantum cryptography advisory services!

How Encryption Consulting Can Help

Building a comprehensive cryptographic inventory is a huge undertaking, but you don’t have to do it alone. We are a globally recognized leader in applied cryptography, offering Post-Quantum Cryptography (PQC) Advisory Services specifically designed to help organizations like yours navigate the quantum shift.

Our services are built on a structured, end-to-end approach:

  • PQC Assessment: We perform cryptographic discovery and inventory to locate all your keys, certificates, and dependencies. This delivers a clear Quantum Threat Assessment and a Quantum Readiness Gap Analysis that identifies your vulnerabilities and most urgent priorities.
  • PQC Strategy & Roadmap: Based on the inventory data, we help you develop a custom, phased PQC migration strategy aligned with NIST and other industry standards. This includes creating a Cryptographic Agility Framework to ensure you’re prepared for future changes.
  • Vendor Evaluation and PoC: We assist in selecting the best PQC solutions by defining evaluation criteria, shortlisting vendors, and executing proof-of-concepts (PoCs) on your critical systems to validate their effectiveness.
  • PQC Implementation: We help you seamlessly integrate PQC algorithms into your PKI and other security ecosystems, including the deployment of hybrid cryptographic models for a secure and disruption-free transition.

With our deep expertise and proven framework, you can build, assess, and optimize your cryptographic infrastructure, ensuring a smooth and secure transition to a post-quantum future.

Conclusion

The quantum era will not wait for organizations to catch up. A comprehensive cryptographic inventory is the cornerstone of true post-quantum readiness, giving you the visibility and control needed to protect your most critical assets. By moving beyond theory to a structured, actionable checklist, you can uncover hidden risks, strengthen crypto agility, and prepare your infrastructure for the inevitable transition.

With the right approach, and the right partners, you can turn today’s uncertainty into tomorrow’s resilience. Start building your cryptographic inventory now to ensure your organization is not just quantum-aware, but quantum-ready.