Compliance
Post-Quantum Compliance in 2026: PCI DSS 4.0, DORA, NIS2 & CNSA 2.0 Deadlines You Can't Ignore
PCI DSS 4.0 Req 12.3.3, DORA, NIS2 and CNSA 2.0 all demand a cryptographic inventory first. See the 2025-2033 deadlines and how to start free.
Post Quantum Compliance in 2026: PCI DSS 4.0, DORA, NIS2 & CNSA 2.0 Deadlines You Can't Ignore If you lead compliance or security in a regulated sector, the post quantum transition stopped being a future research topic and became a present day regulatory obligation. PCI DSS 4.0's cryptographic controls became enforceable on March 31, 2025, DORA went into effect on January 17, 2025, and the NSA's CNSA 2.0 timeline already expects you to prefer quantum resistant algorithms in several categories by 2025 and 2026. The striking part is what nearly every one of these mandates asks for first: not a finished migration, but a documented cryptographic inventory — a list of where and how you use encryption. Most organizations don't have one yet. Why these regulations are converging now The standards bodies have already done their part. On August 13, 2024, NIST finalized the first post quantum cryptography standards — FIPS 203 (ML KEM) for key encapsulation, FIPS 204 (ML DSA) for digital signatures, and FIPS 205 (SLH DSA) for hash based signatures. (FIPS 206, the FN DSA / Falcon standard, is still in progress in 2026, and HQC was selected in March 2025 as a backup key encapsulation mechanism with finalization ongoing.) Once approved algorithms exist, regulators can reasonably start asking whether you have a plan to adopt them — and they have. The driving threat is "harvest now, decrypt later" (HNDL) : adversaries collect long lived encrypted data today, intending to decrypt it once a cryptographically relevant quantum computer (CRQC) exists. Guidance from DHS, the UK's NCSC, ENISA, and Australia's ACSC is built on this premise. The Global Risk Institute's 2025 quantum threat timeline, led by Michele Mosca, puts the median expert estimate for a CRQC at roughly 2029–2032, with about a 34% probability by 2030. Mosca's theorem makes the regulatory logic concrete: if your migration time (X) plus your data's security shelf life (Y) exceeds the time until a CRQC arrives (Z), your data is already at risk today. For a payment processor or a financial entity holding records that must stay confidential for a decade, that inequality is uncomfortable right now. The readiness gap is the reason regulators feel the need to be explicit. A 2025 DigiCert study found that only about 5% of enterprises have quantum safe encryption in place, even though roughly 69% recognize the risk. ISACA's 2025 research found a similar picture: only about 5% of organizations have a defined quantum strategy and roughly 95% lack a roadmap. Other 2025 surveys reported that around 81% say their crypto libraries and HSMs aren't prepared and about 91% have no formal migration roadmap. The mandates below exist to close that gap. The four mandates, side by side Here is the compressed view — what each framework targets, what it actually requires, and the first concrete action it forces. Note how consistently "inventory" appears in the final column. | Mandate | Who it applies to | Key date(s) | What it requires | First action it forces | | | | | | | | PCI DSS 4.0 — Req. 12.3.3 | Any entity that stores, processes, or transmits cardholder data | Future dated cryptographic controls effective March 31, 2025 | A documented cryptographic inventory plus a migration plan for deprecated/weak algorithms | Build and maintain a cryptographic inventory | | DORA | EU financial entities and their critical ICT providers | In effect January 17, 2025 | ICT risk management that explicitly includes crypto agility