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QTS-09.6: Post-Quantum Cryptography (PQC) Key Management

QTS 7 — High Protect

Mechanisms exist to manage cryptographic keys and certificates in a manner that supports Post-Quantum Cryptography (PQC) transition by: (1) Shortening validity periods for quantum-vulnerable certificates to reduce exposure; (2) Preparing Public Key Infrastructure (PKI) for PQC roots of trust or dual-root hybrid trust models; and (3) Ensuring key generation uses quantum-safe entropy sources.

Control Question: Does the organization manage cryptographic keys and certificates in a manner that supports Post-Quantum Cryptography (PQC) transition by: (1) Shortening validity periods for quantum-vulnerable certificates to reduce exposure; (2) Preparing Public Key Infrastructure (PKI) for PQC roots of trust or dual-root hybrid trust models; and (3) Ensuring key generation uses quantum-safe entropy sources?

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 manage cryptographic keys and certificates in a manner that supports Post-Quantum Cryptography (PQC) transition by: (1) Shortening validity periods for quantum-vulnerable certificates to reduce exposure; (2) Preparing Public Key Infrastructure (PKI) for PQC roots of trust or dual-root hybrid trust models; and (3) Ensuring key generation uses quantum-safe entropy sources.

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-09.6_A01 cryptographic keys and certificates are managed in a manner that supports Post-Quantum Cryptography (PQC) transition.
  2. QTS-09.6_A02 validity periods for quantum-vulnerable certificates are shortened to reduce exposure.
  3. QTS-09.6_A03 Public Key Infrastructure (PKI) is prepared for PQC roots of trust or dual-root hybrid trust models.
  4. QTS-09.6_A04 key generation uses quantum-safe entropy sources.

Technology Recommendations

Micro/Small

  • Shorten TLS certificate validity periods (e.g., 90-day certificates)
  • Let's Encrypt for automated short-lived certificate management (https://letsencrypt.org)

Small

  • 90-day certificate validity enforcement
  • Automated certificate lifecycle management
  • Let's Encrypt or ACME protocol (https://letsencrypt.org)

Medium

  • Shortened certificate validity periods per PQC guidance
  • Certificate lifecycle management platform
  • PKI preparation for PQC roots of trust

Large

  • Enterprise certificate lifecycle management with shortened validity periods
  • PKI infrastructure preparation for PQC transition
  • HSM-backed key generation with quantum-safe entropy

Enterprise

  • Enterprise PKI with PQC-ready architecture
  • Automated certificate lifecycle management (e.g., Venafi, Keyfactor)
  • HSM infrastructure with quantum-safe entropy sources
  • Dual-root hybrid trust model support

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