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QTS-06: Post-Quantum Cryptography Agility Plan (PQCAP)

QTS 7 — High Protect

Mechanisms exist to develop a risk-prioritized Post-Quantum Cryptography Agility Plan (PQCAP) that: (1) Enables cryptographic agility; (2) Aligns with evolving security standards; and (3) Defines the approach for selecting and implementing PQC algorithms.

Control Question: Does the organization develop a risk-prioritized Post-Quantum Cryptography Agility Plan (PQCAP) that: (1) Enables cryptographic agility; (2) Aligns with evolving security standards; and (3) Defines the approach for selecting and implementing PQC algorithms?

General (1)
Framework Mapping Values
NIST CSWP 39 3.0 5.0 5.3 6.0
EMEA (1)
Framework Mapping Values
EMEA Germany C5 2026 CRY-01.01AC CRY-01.02AC CRY-01.03AC
APAC (3)
Framework Mapping Values
APAC Australia CCM 2026 PRO-17
APAC Australia ISM June 2026 ISM-1917 ISM-2073
APAC New Zealand NZISM 3.9 2.4.13.C.01 2.4.13.C.03 2.4.13.C.04 2.4.13.C.05 2.4.13.C.07

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

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 — Planned & Tracked

SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

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 develop a risk-prioritized Post-Quantum Cryptography Agility Plan (PQCAP) that: (1) Enables cryptographic agility; (2) Aligns with evolving security standards; and (3) Defines the approach for selecting and implementing PQC algorithms.

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-06_A01 a risk-prioritized Post-Quantum Cryptography Agility Plan (PQCAP) is developed.
  2. QTS-06_A02 the PQCAP enables cryptographic agility.
  3. QTS-06_A03 the PQCAP aligns with evolving security standards.
  4. QTS-06_A04 the PQCAP defines the approach for selecting and implementing PQC algorithms.

Evidence Requirements

E-QTS-14 Post-Quantum Cryptography Agility Plan (PQCAP)

Documented evidence of a Post-Quantum Cryptography Agility Plan (PQCAP), including data shelf-life classification and crypto-agility architecture.

Quantum Security

Technology Recommendations

Micro/Small

  • Simple PQC plan: rely on vendors (browsers, cloud, VPN) enabling PQC; track vendor announcements

Small

  • Basic PQC transition roadmap aligned to NIST PQC standards
  • NIST PQCAP guidance (https://csrc.nist.gov/pqc)

Medium

  • Documented PQCAP aligned to NIST standards
  • Risk-prioritized migration roadmap
  • Integration with enterprise risk management

Large

  • Formal PQCAP with executive sponsorship
  • Risk-prioritized migration with milestones
  • NIST PQC and NSA CNSA 2.0 alignment
  • Annual plan refresh

Enterprise

  • Enterprise PQCAP with board visibility
  • Dedicated PQC program office
  • NIST, NSA CNSA 2.0, and CISA PQC guidance alignment
  • Integration with enterprise architecture and GRC

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