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QTS-07.2: Post-Quantum Cryptography Exposure

QTS 7 — High Protect

Mechanisms exist to maintain a current inventory of Technology Assets, Applications and/or Services (TAAS) with Post-Quantum Cryptography (PQC) exposure, including: (1) Public key algorithms vulnerable to Cryptographically Relevant Quantum Computers (CRQCs); (2) Long-lived keys and certificates (e.g., CA roots and firmware signing keys); and (3) TAAS that cannot easily adopt PQC upgrades (e.g., embedded and RTOS).

Control Question: Does the organization maintain a current inventory of Technology Assets, Applications and/or Services (TAAS) with Post-Quantum Cryptography (PQC) exposure, including: (1) Public key algorithms vulnerable to Cryptographically Relevant Quantum Computers (CRQCs); (2) Long-lived keys and certificates (e.g., CA roots and firmware signing keys); and (3) TAAS that cannot easily adopt PQC upgrades (e.g., embedded and RTOS)?

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

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. ▪ 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 maintain a current inventory of Technology Assets, Applications and/or Services (TAAS) with Post-Quantum Cryptography (PQC) exposure, including: (1) Public key algorithms vulnerable to Cryptographically Relevant Quantum Computers (CRQCs); (2) Long-lived keys and certificates (e.g., CA roots and firmware signing keys); and (3) TAAS that cannot easily adopt PQC upgrades (e.g., embedded and RTOS).

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-07.2_A01 a current inventory of Technology Assets, Applications and/or Services (TAAS) with Post-Quantum Cryptography (PQC) exposure is maintained.
  2. QTS-07.2_A02 the inventory includes public key algorithms vulnerable to Cryptographically Relevant Quantum Computers (CRQCs).
  3. QTS-07.2_A03 the inventory includes long-lived keys and certificates (e.g., CA roots, firmware signing keys, etc.).
  4. QTS-07.2_A04 the inventory includes TAAS that cannot easily adopt PQC upgrades (e.g., embedded, RTOS, etc.).

Evidence Requirements

E-QTS-04 Cryptographic Asset Inventory

Documented evidence of a cryptographic asset inventory.

Quantum Security
E-QTS-10 Cryptographic Telemetry

Documented evidence of situational awareness dashboards for cryptographic telemetry (e.g., SIEM/XDR dashboards).

Quantum Security

Technology Recommendations

Micro/Small

  • Identify internet-facing services and VPN using RSA/ECC certificates (quantum-vulnerable)

Small

  • Identify systems using quantum-vulnerable public key algorithms (RSA, ECDSA, DH)
  • Prioritize based on data sensitivity

Medium

  • Inventory of systems with PQC exposure
  • Risk-based prioritization of exposed systems
  • Integration with vulnerability management

Large

  • Formal PQC exposure inventory
  • Automated scanning for quantum-vulnerable algorithm use
  • Risk-prioritized remediation planning

Enterprise

  • Continuous PQC exposure monitoring
  • Enterprise scanning for quantum-vulnerable implementations
  • Automated risk prioritization and remediation tracking
  • Board-level PQC exposure reporting

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