Reference
Every deadline that matters, with sources.
Policy timelines are usually summarized without citations, which makes them impossible to act on. Each milestone below links to the primary document, and we label anything still in draft.
Milestones
From standards to obligations.
Chronological. Filter by the body that owns each deadline.
- August 13, 2024 NIST 809 days ago
First post-quantum standards published
NIST publishes FIPS 203 (ML-KEM) for key establishment, FIPS 204 (ML-DSA) for signatures, and FIPS 205 (SLH-DSA) for stateless hash-based signatures. These are production standards, not research proposals.
NIST FIPS 203 - December 2024 NSA 699 days ago
CNSA 2.0 finalized
NSA publishes version 2.1 of the Commercial National Security Algorithm Suite. It approves ML-KEM and ML-DSA, requires LMS or XMSS for software and firmware signing, and does not approve SLH-DSA for national security systems.
NSA, CNSA 2.0 - June 22, 2026 Federal 131 days ago
Executive Order 14412 signed
Securing the Nation Against Advanced Cryptographic Attacks directs agencies to inventory high-value assets and high-impact systems, migrate key establishment to PQC, and submit migration plans.
Federal Register - September 21, 2026 NIST 40 days ago
FIPS 140-2 validation regime sunsets
Remaining active FIPS 140-2 certificates move to the CMVP Historical list. They may keep operating, but federal agencies should not include historical modules in new procurements — which puts PQC modules in the same FIPS 140-3 queue.
NIST CMVP - January 1, 2027 NSA in 62 days
CNSA 2.0 becomes the acquisition default
New National Security System acquisitions are expected to be CNSA 2.0-compliant by default. Suppliers that cannot evidence compliance face exclusion, not a downgraded score.
NSA, CNSA 2.0 - March 19, 2027 Federal in 139 days
Minimum CBOM elements due from CISA and NIST
The executive order requires CISA, with NIST, to publish public guidance on the minimum elements of a cryptographic bill of materials within 270 days of June 22, 2026 — enabling automated assessment of cryptographic assets in hardware and software.
EO 14412, sec. 5(d) - December 31, 2027 NIST in 426 days
NIST completes its own PQC migration pilot
The Secretary of Commerce, through NIST, is directed to run a PQC migration pilot on a subset of NIST information systems, providing a public reference for agency execution.
EO 14412, sec. 4(c) - December 31, 2030 Federal in 1,522 days
PQC key establishment on high-value and high-impact systems
Agencies must transition high-value assets and high-impact systems to PQC for key establishment. A concurrent FAR rule requires covered contractors to comply with FIPS incorporating PQC algorithms by the same date.
EO 14412, sec. 4(b) - December 31, 2030 NSA in 1,522 days
Non-CNSA 2.0 equipment phased out
Equipment and services that cannot support the CNSA 2.0 suite must be phased out of national security systems.
NSA, CNSA 2.0 - 2030 NIST Draft in 1,522 days
NIST deprecation of classical public-key algorithms
NIST IR 8547 proposes deprecating RSA, ECDSA, EdDSA, and finite-field and elliptic-curve Diffie-Hellman at the 112-bit security level after 2030. The document remains an initial public draft; treat the date as a planning signal, not settled regulation.
NIST IR 8547 (draft) - December 31, 2031 Federal in 1,887 days
PQC digital signatures on high-value and high-impact systems
Agencies must transition to PQC for digital signatures. For software and firmware, this is the hardest date: signatures are long-lived and embedded in fielded systems.
EO 14412, sec. 4(b) - December 31, 2031 NSA in 1,887 days
CNSA 2.0 algorithms mandated
CNSA 2.0 algorithms are mandated across national security systems. By this point, migration is a compliance baseline rather than a differentiator.
NSA, CNSA 2.0 - 2035 NIST Draft in 3,348 days
NIST disallowance of classical public-key algorithms
NIST IR 8547 proposes disallowing RSA, ECDSA, EdDSA, and classical Diffie-Hellman after 2035. Systems still depending on them at that point will be non-compliant by default.
NIST IR 8547 (draft)
What to do when
Three phases, three different jobs.
Treating this as one migration is the most common planning mistake. The work changes character every few years.
Build the baseline
Inventory high-value assets, name an owner, and produce a CBOM you can defend. The 270-day CBOM guidance and the January 2027 acquisition bar both assume this exists.
Start discovery now
Migrate key establishment
Hybrid TLS, PQC certificate issuance, and HSM refresh aligned to the FIPS 140-3 queue. This is where most of the engineering effort lands.
Plan the migration waves
Prove and sustain
Signatures, supplier posture, and continuous evidence. The work becomes an operating capability with reporting on a fixed cadence.
Build operations, not a project
The nearest deadline
The CBOM requirement is closer than it looks.
Executive Order 14412 directs CISA, with NIST, to publish minimum elements for a cryptographic bill of materials within 270 days of June 22, 2026 — around March 2027.
When that guidance lands, the question stops being whether a CBOM is useful and becomes whether yours exists in a form an assessor can read. The organizations that start now will be adapting a working artifact. The ones that wait will be building one under a deadline.
Planning
Which of these dates actually applies to you?
Most organizations are in scope for fewer deadlines than they fear and more than they have planned for. The assessment narrows it down.