The payments system runs on signatures.
Every payment your institution touches is a chain of asymmetric cryptography: TLS between institutions, message signing in instant payment systems, certificate hierarchies rooted in HSMs, customer and machine authentication. That is the layer a cryptographically relevant quantum computer breaks. The industry frames this as an encryption problem, secrets getting read. The more expensive failure is signatures getting forged.
The public record is already explicit. The Federal Reserve's September 2025 research on harvest-now-decrypt-later concluded that data recorded under today's cryptography cannot be retroactively protected. The Citi Institute's January 2026 analysis put the indirect cost of a one-day quantum-enabled disruption to a major bank's Fedwire access in the trillions. NIST finalized the replacement algorithms in August 2024 and has published the deprecation trajectory. None of this is vendor marketing. All of it is citeable.
The three questions examiners ask first.
Do you have a cryptographic inventory. Who owns this. What is your timeline.
The same sequence preceded cyber-resilience expectations a decade ago, and institutions that waited for the formal guidance spent the next five years remediating findings.
QCI-QS1 is built so that all three questions have evidence-backed answers: a QASI inventory with named owners, an accountable executive with board cadence, and a roadmap anchored to NIST IR 8547 and CNSA 2.0 dates rather than invented ones.
The exposure your inventory is missing.
Scanning tools find algorithms in code. They do not find credentials in operations: the certificate estates, service accounts, API keys, and machine identities that authenticate everything your institution does automatically.
That population is growing faster than any other identity class and appears in almost no inventory. QCI-QS1 v2.3 makes it a required field group, because an inventory that misses where payments exposure actually sits is theater.
Running the same migration twice.
If your institution is rolling out passkeys or FIDO2 while separately planning PQC migration, you are scheduled to re-issue the same credentials twice and reconcile the inventories never.
The standard now requires one re-issuance plan, one shared inventory, and one named owner for the seam. Whether the programs merge is your call. Whether they coordinate is not.
For community institutions.
A $500 million institution does not need the full program this year. It needs a named owner, an inventory of critical systems only, a data-lifetime map, vendor roadmap requests in the mail, and one board briefing.
That is a 90-day sequence, it is in the standard for free, and most of it is work your team can do without us. If you want the score and the evidence trail behind it, that is the engagement.
Mapped to the supervisory frameworks your examiners already use.
The QCI-QS1 financial-services supplement and NCUA crosswalk translate each control into the language a bank examiner or credit union supervisor speaks.
FFIEC alignment
The QCI-QS1 Financial Institutions Supplement (S1) maps asset inventory, vendor oversight, and cryptographic agility controls to the FFIEC IT Examination Handbook — including the Information Security and Outsourcing booklets.
NCUA crosswalk
The NCUA Regulatory Crosswalk (v1.2) maps QCI-QS1 controls to NCUA cyber expectations and third-party risk guidance — giving credit-union CROs and ISO officers an audit-ready translation layer.
MiCA — Markets in Crypto-Assets Regulation
MiCA has been fully applicable across the EU since December 2024, binding crypto-asset service providers (CASPs), stablecoin issuers, and crypto-asset issuers. It is not a quantum regulation — and it does not need to be. Every entity in scope relies on elliptic-curve cryptography for wallet key management, transaction signing, and custody. Those are exactly the primitives Shor's algorithm breaks, which puts MiCA squarely on the Payment and Identity exposure surfaces this page already maps.
The hooks are Article 70 (operational resilience and ICT security) and Article 73 (crypto-asset custody). Read alongside DORA, the same cryptographic-agility and vendor-oversight controls get examined twice — once under MiCA's custody and ICT obligations, and again under DORA's ICT risk regime. CASPs and stablecoin issuers should treat MiCA as an in-scope quantum exposure today, not a future amendment.
Every claim on this page is publicly citable.
We do not sell urgency. We point you to the primary sources and measure your posture against the published standard.
Federal Reserve — The Quantum Threat and the Financial System (Sept 2025)
FEDS research concluding that data recorded under today's cryptography cannot be retroactively protected.
Citi Institute — The Quantum and Cryptography Revolution (Jan 2026)
Indirect cost of a one-day quantum-enabled disruption to a major bank's Fedwire access estimated in the trillions.
FFIEC IT Examination Handbook — Information Security
Asset identification, cryptographic controls, and third-party oversight expectations.
NCUA — Cybersecurity Resources
Credit-union supervisory expectations on emerging cryptographic risk.