Deadline tracker
Four obligations, four dates. Find the clocks you are on, then plan against the earliest.
A single 2035 countdown treats four different obligations as one problem. National security systems, federal civilian agencies, covered contractors and commercial buyers each answer to a different document, a different population and a different date.
Executive departments and agencies, excluding NSS
Agency PQC migration plans due to OMB and ONCDOct 22, 2026
Final: Phase 5, full migration of remaining systemsDec 31, 2035
Contractors and, through flow-down, their suppliers
Proposed FAR PQC rule due from the FAR CouncilDec 19, 2026
Final: Covered contractors compliant with NIST PQC FIPSDec 31, 2030
Private sector, critical infrastructure, international
NIST FIPS 206 (FN-DSA) signature standard expected finalDec 31, 2026
Final: RSA and ECC disallowed under NIST IR 8547Dec 31, 2035
NSS owners, DoD components and their integrators
New NSS acquisitions expected to support CNSA 2.0Jan 1, 2027
Final: CNSA 2.0 exclusive across NSSDec 31, 2033
EO 14412 sets the legal mandate and M-26-15 is the operational playbook: a five-phase schedule from 2026 to 2035, key establishment migrated by 2030 and signatures by 2031 for high-impact systems and High Value Assets.
Who it binds: Executive departments and agencies, excluding NSS
Governing documentSecuring the Nation Against Advanced Cryptographic Attacks directs the federal PQC transition, sets key establishment by 2030 and signatures by 2031 for prioritized systems, and starts the FAR rulemaking clocks.
SourceExecution of the Migration to Post-Quantum Cryptography. Five-phase schedule from 2026 to 2035, agency plans due in 120 days, detailed guidance on algorithm selection, hybrid key exchange, crypto-agility and zero trust.
SourceM-26-15 gives GSA 60 days to establish an interagency working group on modernizing Federal Identity, Credential and Access Management for PQC.
SourceFederal civilian agencies must stop counting FIPS 140-2 validated modules toward compliance and track replacements in their migration plans.
Source120 days from M-26-15. Plans must include risk-based prioritization, phased timelines, automated inventory methodology, a crypto-agility architecture plan, third-party coordination, funding estimates and governance roles.
SourceEO 14412 gives CISA and NIST 270 days to define the minimum elements of a cryptographic bill of materials, the input every automated inventory program depends on.
SourceEO 14412 and M-26-15 Phase 3: key establishment migrated to PQC across High Value Assets, high-impact systems and systems holding highly sensitive data. TLS 1.3 or successor also required by January 2, 2030.
SourceM-26-15 Phase 4 aligns with the EO function-based split: key establishment by 2030, digital signatures by 2031.
SourceEO 14412 started a 180-day clock for a proposed FAR rule requiring covered contractors to meet NIST FIPS, including FIPS 203, 204 and 205, by the end of 2030. A second rule adds cryptographic vulnerability disclosure.
Who it binds: Contractors and, through flow-down, their suppliers
Governing document180 days from EO 14412. The proposed rule would require covered contractors to comply with NIST FIPS, including FIPS 203, 204 and 205, by December 31, 2030.
Source270 days from EO 14412. Contractor vulnerability disclosure policies would have to accept reports of cryptographic weaknesses, including missing encryption and non-FIPS-approved algorithms.
SourceThe proposed rule sets December 31, 2030 as the date covered contractors must meet NIST post-quantum FIPS standards.
SourceNo statute forces commercial migration, but NIST IR 8547 sets the transition schedule the market follows: 112-bit classical public-key cryptography deprecated after 2030 and disallowed after 2035.
Who it binds: Private sector, critical infrastructure, international
Governing documentNIST opens the public competition to standardize quantum-resistant public-key algorithms.
SourceNSA publishes Commercial National Security Algorithm Suite 2.0, setting PQC transition timelines for national security systems.
SourceUS federal agencies directed to inventory cryptographic systems and plan migration.
ML-KEM, ML-DSA and SLH-DSA become final US federal standards.
SourceDraft guidance deprecating RSA and ECC by 2030 and disallowing them after 2035.
A code-based alternative is chosen to hedge against a structural break in lattice assumptions.
NSA requirement milestone for national security systems.
All FIPS 140-2 validated modules move to the CMVP historical list. Agencies and contractors can no longer rely on them for new procurements, and auditors will flag them in inventories.
SourceEU Member States commit to starting migration of critical infrastructure.
Falcon-based signature standard expected to be finalized.
112-bit classical public-key cryptography deprecated for federal use.
All national security systems expected to be exclusively quantum-resistant.
NIST IR 8547 disallows 112-bit classical public-key cryptography after 2035. M-26-15 Phase 5 puts the same year on the record for full federal migration of remaining systems.
SourceCNSA 2.0 sets the algorithm suite for national security systems, which is the clock most of DoD sits on. Software and firmware signing moved first, networking and general NSS follow, and CNSA 1.0 algorithms are retired well before the civilian dates. DoD systems that are not NSS follow the federal civilian dates under EO 14412 and M-26-15.
Who it binds: NSS owners, DoD components and their integrators
Governing documentNational security systems entering acquisition are expected to support and prefer CNSA 2.0 algorithms, with CNSA 1.0 retired on the NSS timeline rather than the civilian one.
SourceNSS complete the transition to the CNSA 2.0 suite, ahead of the civilian 2035 endpoint.
Source