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QTS-02: Quantum Risk Governance

QTS 7 — High Protect

Mechanisms exist to establish an executive-sponsored quantum risk governance structure that institutionalizes quantum risk in the same manner as other enterprise risks by: (1) Assigning a named migration lead with defined authority; and (2) Treating quantum risk as a standing agenda item in Board of Directors and/or executive leadership meetings.

Control Question: Does the organization establish an executive-sponsored quantum risk governance structure that institutionalizes quantum risk in the same manner as other enterprise risks by: (1) Assigning a named migration lead with defined authority; and (2) Treating quantum risk as a standing agenda item in Board of Directors and/or executive leadership meetings?

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

Quantum Security (QTS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with QTS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 — Planned & Tracked

Quantum Security (QTS) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with QTS domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are documented and maintained by process owners. ▪ Quantum security risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with QTS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The IT department establishes, maintains and updates an inventory that contains a listing of all organizational-owned TAASD, at a minimum covering common devices (e.g., laptops, workstations and servers). Encryption inventories are limited. ▪ Inventories may be manual (e.g., spreadsheets) or automated.

Level 3 — Well Defined

Quantum Security (QTS) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with QTS domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are well-documented and kept current by process owners. ▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain QTS domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with QTS domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to establish an executive-sponsored quantum risk governance structure that institutionalizes quantum risk in the same manner as other enterprise risks by: (1) Assigning a named migration lead with defined authority; and (2) Treating quantum risk as a standing agenda item in Board of Directors and/or executive leadership meetings.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. QTS-02_A01 an executive-sponsored quantum risk governance structure is established that institutionalizes quantum risk in the same manner as other enterprise risks.
  2. QTS-02_A02 a named migration lead with defined authority is assigned.
  3. QTS-02_A03 quantum risk is treated as a standing agenda item in Board of Directors and/or executive leadership meetings.

Evidence Requirements

E-QTS-01 Quantum Risk Governance Charter

Documented evidence of a quantum risk governance charter with named lead and steering committee.

Quantum Security
E-QTS-02 Post-Quantum Cryptography (PQC)-Specific Status Reporting

Documented evidence of a Post-Quantum Cryptography (PQC)-specific board / risk committee reporting pack (e.g., status, metrics/analytics, exceptions, etc.).

Quantum Security

Technology Recommendations

Micro/Small

  • Awareness of NIST PQC standards (https://csrc.nist.gov/pqc)
  • Note: Formal quantum risk governance may not be cost-effective at this size; monitor NIST guidance

Small

  • Designate a named lead responsible for tracking PQC developments
  • NIST Post-Quantum Cryptography standards awareness (https://csrc.nist.gov/pqc)

Medium

  • Designated quantum migration lead within CISO function
  • NIST PQC standards alignment
  • Include quantum risk in enterprise risk register

Large

  • Executive-sponsored quantum risk governance structure
  • Named migration lead with defined authority
  • NIST PQC and NSA CNSA 2.0 alignment
  • Quantum risk as standing agenda item in executive meetings

Enterprise

  • Board-level quantum risk governance structure
  • NIST PQC standards and NSA CNSA 2.0 alignment
  • Dedicated PQC migration program team
  • Quantum risk integrated into enterprise risk management

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