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QTS-06.1: Post-Quantum Cryptography (PQC) Transition Planning & Hybrid Mode Support

QTS 7 — High Protect

Mechanisms exist to allocate resources to: (1) Transition legacy Technology Assets, Applications and/or Services (TAAS) to Post-Quantum Cryptography (PQC) algorithms; and (2) Support hybrid cryptography during a defined transition period.

Control Question: Does the organization allocate resources to: (1) Transition legacy Technology Assets, Applications and/or Services (TAAS) to Post-Quantum Cryptography (PQC) algorithms; and (2) Support hybrid cryptography during a defined transition period?

EMEA (1)
Framework Mapping Values
EMEA Germany C5 2026 CRY-01.02AC.4

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 allocate resources to: (1) Transition legacy Technology Assets, Applications and/or Services (TAAS) to Post-Quantum Cryptography (PQC) algorithms; and (2) Support hybrid cryptography during a defined transition period.

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-06.1_A01 sufficient resources are allocated to transition legacy Technology Assets, Applications and/or Services (TAAS) to Post-Quantum Cryptography (PQC) algorithms.
  2. QTS-06.1_A02 hybrid cryptography is supported during a defined transition period, if applicable.

Evidence Requirements

E-QTS-13 Post-Quantum Cryptography (PQC)-Specific Vendor Roadmaps

Documented evidence of a vendor-related Post-Quantum Cryptography (PQC) roadmaps, contract clauses, and attestations.

Quantum Security

Technology Recommendations

Micro/Small

  • Keep TLS/VPN/software current so vendor-provided PQC/hybrid modes are adopted automatically

Small

  • Monitor TLS library vendor support for PQC/hybrid modes
  • Plan transition for highest-risk systems first

Medium

  • PQC algorithm support assessment for key systems
  • Hybrid cryptography pilot for critical services
  • Vendor roadmap review for PQC support

Large

  • Hybrid cryptography deployment for critical services
  • TLS 1.3 with hybrid PQC key exchange pilot
  • Legacy system migration planning and resource allocation

Enterprise

  • Enterprise hybrid cryptography deployment program
  • FIPS 140-3 validated PQC module adoption
  • Hybrid mode support across all external-facing services
  • Automated legacy system discovery and migration tracking

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