A U.S. Government Accountability Office audit found that none of 24 federal agencies had fully implemented all three preparatory practices for post-quantum cryptography (PQC): cryptographic inventories, migration funding assessments, and testing, according to PostQuantum’s account of the findings. Only one agency had completed an inventory of priority systems, none of six sampled agencies fully substantiated inventory accuracy, and no agency had tested PQC in its own environment by the audit’s conclusion. GAO attributed the gaps to shortages of cryptographic expertise, documented processes, and discovery tools. Incomplete funding assessments also weakened the basis for the government’s approximately $7.1 billion migration estimate.
Subsequent federal policy requires migration plans by October 22, 2026, with PQC adoption for specified critical systems due by the end of 2030 for key establishment and 2031 for digital signatures. CISA has separately published a resource identifying product categories for technologies that use PQC standards, supporting migration planning. PostQuantum’s analysis emphasizes that a completed inventory does not necessarily establish verified cryptographic coverage and recommends independently reconciling assets, sampling evidence, and documenting discovery gaps. It also questions the Social Security Administration’s assertion that its systems use no vulnerable algorithms, underscoring the need to validate claims of quantum readiness before relying on them for migration decisions.

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GAO released report GAO-27-108740, finding that none of 24 agencies had fully implemented all three assessed practices: cryptographic inventories, migration funding assessments, and PQC testing. Only one agency had a complete inventory of priority systems, none of six sampled agencies fully substantiated inventory accuracy, and no agency had tested PQC in its own environment by the audit's conclusion.
OMB issued Memorandum M-26-15, requiring agencies to submit PQC migration plans by October 22, 2026, identifying inventory methods, automated tools, funding needs, and personnel requirements. The memorandum called for continuously updated inventories of all cryptographic assets, automated discovery wherever possible, and a central cryptographic bill of materials.
Executive Order 14412 was signed, directing OMB to require PQC key establishment by December 31, 2030, and PQC digital signatures by December 31, 2031, for high value assets and high-impact systems outside national security systems. It also directed DHS, through CISA and in coordination with NIST, to publish minimum cryptographic bill of materials elements.
CISA published categories of technologies with widely available PQC-capable products and advised organizations to acquire only PQC-capable products within those categories.
SSA stated that it had updated cryptographic-information collection through its governance, risk, and compliance tool and found no vulnerable algorithms in its systems. It said it would develop transition plans when quantum-resistant algorithms became widely available.
GAO issued a sensitive report containing 89 recommendations to CISA and 23 audited agencies. Of those agencies, 12 agreed fully, two partially, seven neither agreed nor disagreed, one disputed three of four recommendations, and the Department of the Interior did not respond.
Craig Gidney published a preprint estimating that RSA-2048 could be factored in under a week using fewer than one million noisy physical qubits under specified hardware assumptions. This contrasted with the approximately ten-million-physical-qubit estimate cited by GAO.
A Global Risk Institute survey found that 21 of 32 experts assigned at least a 50 percent probability to a cryptographically relevant quantum computer by 2040. GAO later cited the survey in its threat assessment.
NIST published its first three PQC standards, establishing standardized algorithms for post-quantum adoption.
OMB published an ONCD-developed rough estimate of $7.1 billion in 2024 dollars to migrate prioritized non-national-security systems during 2025–2035. The estimate relied on agency funding assessments that GAO subsequently found were incomplete and acknowledged to contain inaccuracies.
GAO began an audit requested by Senator Maggie Hassan covering 24 Chief Financial Officers Act agencies, including every cabinet department. The audit ran through September 2025 and assessed cryptographic inventories, migration funding assessments, and PQC testing.
Memorandum M-23-02 required agencies to inventory prioritized systems using quantum-vulnerable public-key cryptography and submit annual inventories to ONCD and CISA. It also required migration funding assessments within 30 days of each inventory.
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