Global Post-Quantum Mandates and Deadlines: US, EU, UK, Canada, Australia

The answer, up front

The United States, European Union, United Kingdom, Canada, and Australia all publish post-quantum migration timelines. Most converge on 2035 for full migration. The earliest hard dates still ahead are Jan. 1, 2027 for new U.S. National Security Systems acquisitions and Dec. 31, 2030 for U.S. civilian key establishment. The EU sets 2030 for high-risk use cases, and Australia recommends ending traditional asymmetric cryptography by the end of 2030 1, 4, 6, 9.

Status labels used below: Binding means an order or policy compels the named entities. Guidance means the document recommends or sets indicative dates.

Comparison table (as of Sep. 29, 2026)

United States

Civilian agencies. Executive Order 14412, signed Jun. 22, 2026, directs OMB, within 90 days, to require agencies to review their high-value asset and high-impact system inventories, move those systems to PQC key establishment by Dec. 31, 2030, and to PQC digital signatures by Dec. 31, 2031 1. Each agency head also names a PQC migration lead within 30 days 1. OMB issued M-26-15 on Jun. 24, 2026 and set five phases: strategy and discovery in 2026 to 2027, pilots in 2027 to 2028, prioritized key-establishment migration in 2028 to 2030, signature migration in 2031, and full migration by 2035 2. Agencies must submit a PQC migration plan to OMB and ONCD within 120 days of the memo, which falls on Oct. 22, 2026 2. Appendix A of the memo sets a Jan. 2, 2030 deadline for TLS 1.3 support 2.

Other order deadlines. Under Sec. 4(c), NIST must start a PQC pilot on its own systems within 180 days and finish by Dec. 31, 2027. Under Sec. 5(d), CISA, in coordination with NIST, must publish minimum elements for a cryptographic bill of materials within 270 days. Under Sec. 6(c), the FAR Council must propose a rule within 180 days requiring covered contractors to comply with PQC-incorporating FIPS by Dec. 31, 2030 1.

National Security Systems. The order and the OMB memo exclude NSS. NSA's CNSA 2.0 governs them. NSA expects the transition to quantum-resistant algorithms for NSS to finish by 2035 and expects legacy equipment and custom applications to be updated or replaced by 2033 3. Its FAQ says CNSSP 15 requires new NSS acquisitions to be CNSA 2.0 compliant by Jan. 1, 2027, equipment that cannot support CNSA 2.0 to be phased out by Dec. 31, 2030, and CNSA 2.0 algorithms to be mandated by Dec. 31, 2031, unless otherwise noted 4.

NIST IR 8547. The report describes NIST's expected approach for moving off quantum-vulnerable algorithms. NIST's own page lists only the initial public draft from Nov. 12, 2024, and comments closed on Jan. 10, 2025 5. The draft's tables mark 112-bit-strength algorithms as deprecated after 2030 and the listed quantum-vulnerable signature and key-establishment algorithms as disallowed after 2035 5. OMB tells agencies to align their plans with IR 8547 "or successor document" 2.

European Union

The NIS Cooperation Group published the roadmap on Jun. 23, 2025, following the Commission's April 2024 recommendation 6. It recommends that Member States implement first steps and set initial national roadmaps by the end of 2026, complete the transition for high-risk use cases by the end of 2030, and complete medium-risk use cases by the end of 2035, with low-risk use cases done as far as feasible 6. The roadmap is a set of recommendations, not an EU regulation.

United Kingdom

The NCSC published its timelines on Mar. 20, 2025 7. By 2028, organizations define goals, finish discovery, and build an initial plan. By 2031, they complete highest-priority migration and refine the plan. By 2035, they complete migration of all systems, services, and products 7. The NCSC expects that some rarely used technologies may need longer than 2035 7.

Canada

The Cyber Centre's roadmap took effect on Jun. 23, 2025 and covers federal non-classified IT 8. Departments develop an initial plan in April 2026, report progress annually, finish high-priority systems by the end of 2031, and finish everything else by the end of 2035 8. TBS's Security Policy Implementation Notice, effective Oct. 9, 2025, sets mandatory direction for departments and agencies, including the April 1, 2026 plan and procurement-clause date, and repeats the 2031 and 2035 completion dates 10. The Cyber Centre states that "completion" means quantum-vulnerable algorithms are disabled, isolated, or tunnelled, not merely that PQC is supported 8.

Australia

ASD's guidance recommends that organizations cease using traditional asymmetric cryptography by the end of 2030 9. It sets milestones of a refined transition plan by the end of 2026 and a started transition for critical systems by the end of 2028 9. The Information Security Manual states that RSA, DH, ECDH and ECDSA will not be approved beyond 2030 and includes a control requiring a PQC transition plan (ISM-2073) 11. ASD does not recommend, but does not prohibit, hybrid schemes, and it expects organizations to move to purely post-quantum algorithms eventually 9.

What the dates mean for a company that is not a government

None of these documents binds a private company directly, with two exceptions: federal contractors, once the FAR rule takes effect, and vendors selling into National Security Systems. The dates still set the market. Your customers, auditors, and cyber insurers will read these documents and ask for your plan.

Practical reading: Treat 2028 as your discovery deadline (the UK timeline points there, ASD expects critical-system migration to have started by then, and the U.S. agency discovery phase ends in 2027), 2030 as your key-establishment deadline for sensitive systems, and 2035 as the outer boundary.

What this means for executives and the board

Read the table as a set of clocks, not a single deadline. Each clock starts from a different authority, and each has a different status. Your general counsel should sort your exposure into three groups.

• Binding on you. This applies only if you are a federal agency, a covered federal contractor once the FAR rule takes effect, or a vendor selling into National Security Systems 1, 3.
• Binding on your customers. Agencies and NSS owners must pass requirements down through contracts and acquisitions. You may see these terms in procurement questionnaires before you see them in regulation.
• Guidance you should still follow. The EU, UK, Canada and Australia publish guidance 6, 7, 8, 9. Auditors, insurers and large customers often treat guidance as the expected standard of care.

Your board holds oversight duties, and your CEO owns the outcome. Your CISO owns the inventory and the plan. Your CFO owns the multi-year budget line. Your GC owns contract language and regulatory tracking. Assign these owners by name. A post-quantum program with no named owner will slip.

Notice also how the dates differ in kind. Some are dates for a plan. Others are dates for finished migration. The Canadian roadmap defines completion as quantum-vulnerable algorithms that are disabled, isolated, or tunnelled, not merely that PQC is supported 8. Ask your team which definition each date uses before you commit to it.

Decisions leadership must make in the next 90 days

ArcQubit guidance. These are our recommendations, not requirements from any cited document.

1. Name one accountable executive. Pick a single owner for the program, and give that person authority across security, IT and procurement.
2. Approve a cryptographic discovery effort. The UK timeline asks organizations to finish discovery and build an initial plan by 2028 7. The U.S. agency phases begin with strategy and discovery in 2026 to 2027 2. You cannot plan a migration for systems you have not found.
3. Choose your reference calendar. Our recommendation follows the practical reading above: 2028 for discovery, 2030 for key establishment on sensitive systems, 2035 as the outer boundary.
4. Set a supplier expectation. Decide what you will ask your vendors to commit to in writing, and add it to renewals and new contracts.
5. Set the reporting rhythm. Ask for a short quarterly update to the board or its risk committee.

Questions to ask your team this week

1. Which of our systems protect data that must stay confidential for many years?
2. Do we have a current inventory of where we use public-key cryptography, including in vendor products?
3. Which of these jurisdictions apply to us through customers, contracts or operations?
4. Do we sell to federal agencies or to National Security Systems, and which contract terms could change?
5. Which suppliers can state a PQC roadmap today, and which cannot?
6. Who owns each of the dates in our reference calendar?
7. When we say a system is "migrated," do we mean it supports PQC, or that the vulnerable algorithms are off?
8. What would we need to show an auditor or insurer if they asked for our plan next quarter?

What it costs to wait

We do not put numbers on this, because the cited documents give none. The costs are still real, and they are qualitative.

• Lead time. Discovery, pilots, vendor upgrades and testing all take time. OMB's own phasing spreads work across 2026 to 2035 2. Starting late compresses that work into a shorter window.
• Supplier dependence. You often cannot fix cryptography yourself. You wait for a vendor to ship support. NSA's FAQ sets Jan. 1, 2027 as the date when new NSS acquisitions must support CNSA 2.0 4, so vendors in that market are already moving. Vendors that do not move may not be able to serve those buyers.
• Audit and customer exposure. Customers, auditors and cyber insurers will read these documents and ask for your plan. An organization with no inventory has no credible answer.
• Data already collected. Information that adversaries capture today may stay sensitive for years. Waiting does not shrink that exposure.

Common mistakes and how to avoid them

• Treating 2035 as the only date. The earliest hard dates are Jan. 1, 2027 for new NSS acquisitions and 2030 for U.S. civilian key establishment, with the EU and ASD also pointing at 2030 1, 4, 6, 9. Plan against the earlier clocks for your most sensitive systems.
• Reading draft guidance as final. NIST IR 8547 is an initial public draft 5. Track it, and expect a successor document.
• Assuming the rules skip you. Private companies face no direct mandate in most cases. Contract flow-down and market expectations still reach you.
• Confusing support with completion. Turning on PQC in one place does not retire the old algorithms 8.
• Buying tools before finding assets. Start with discovery. It tells you what to buy.
• Treating one jurisdiction as global. These instruments differ in scope, status and date. Check each one before you rely on it, and confirm current status with the issuing body.

Owner and timeline table

ArcQubit guidance. Owners and timing are our recommendation, drawn from the phases in the cited documents.