Implementation

    PQC migration roadmap, milestones and decision records

    A PQC migration roadmap is the governed plan for moving critical systems and data flows from vulnerable cryptography to approved profiles. Under QCI-QS1 v2.3 it must be resourced and dependency-aware, with accountable owners, effort, capacity, start and completion milestones, acceptance criteria and required decisions. Planning, procurement, pilot, production acceptance and retirement must be separately identifiable, so progress is not overstated.

    New to this? Read Crypto agility: definition and practical demonstration first. After this, continue with What migrates first and why.

    In one sentence: A roadmap ties each migration decision to an owner, a dependency, a milestone type and the evidence that will close it.

    Why it matters

    Migration spans many systems, suppliers and years. Without a roadmap that separates plans from accepted production changes, an organization can report activity that has not reduced exposure.

    QCI-QS1 requires resource shortfalls to be recorded as delivery risks rather than hidden by later dates (QCI-4.1-02).

    Illustrative example: a roadmap shows a payment gateway as "migrated" because the vendor shipped a release supporting ML-KEM. Under QCI-QS1 that is supplier availability, not completion, until the change is accepted in production and legacy paths are removed or excepted.

    What each roadmap entry records

    • The inventory basis: the linked QASI records for the system or flow, with horizons and exposure flags (QCI-5.3-01).
    • The decision factors: confidentiality and verification horizons, present capture exposure, consequences, supplier and trust dependencies, lead time, operational constraints, end-of-support and applicable deadlines (QCI-4.2-02).
    • Owner, estimated effort or cost, committed capacity, and start and completion milestones (QCI-4.1-02).
    • The milestone type: planning, procurement, pilot, production acceptance or retirement (QCI-4.2-02).
    • Supplier inputs: Annex C responses, adequacy decisions and any exceptions (QCI-7.2-03, QCI-7.3-01).
    • Test and acceptance criteria under Clause 4.7 (QCI-4.7-01, QCI-4.7-02).
    • Decisions required, including any governed decision to wait.

    Illustrative roadmap extract

    The table shows structure only. Systems, owners and quarters are invented and are not a recommended schedule.

    Illustrative roadmap extract (hypothetical)
    ItemMilestone typeDepends onOwnerClosing evidence
    External TLS terminationProduction acceptanceLoad-balancer supplier attestation; approved hybrid profilePlatform engineering leadClause 4.7 results, service-owner acceptance, legacy path disposition
    Code-signing rootProcurementHSM firmware support; signing-tool upgradePKI ownerAdequate supplier response and attestation
    Archive encryption keysPlanningHorizon analysis; rewrap or re-encrypt decisionData ownerDocumented decision and residual exposure (QCI-4.6-03)
    Partner file exchangeDecision recordPartner readiness unknownQuantum Risk OwnerOwner, rationale, interim treatment, review date and triggers

    Reporting progress

    Migration completion is measured over critical systems or flows identified as requiring transition. Deferring an item does not remove it from the denominator, and a plan, pilot, supplier availability or accepted risk does not count as completion (QCI-6.2-02). Roadmap status reaches the governing body through the quarterly insert (QCI-4.1-02).

    What organizations should do

    1. Build roadmap entries only from validated inventory records with horizons and exposure flags.
    2. Label every milestone by type so planning and production acceptance are never combined.
    3. Record committed capacity and log shortfalls as delivery risks (QCI-4.1-02).
    4. Attach the supplier evidence each entry depends on.
    5. Define acceptance criteria before work starts (QCI-4.7-01).
    6. Record each decision to wait with owner, rationale, interim treatment, review date and triggers.

    Evidence an auditor should expect

    Rows marked "QCI requirement" come from the standard. Rows marked "Editorial suggestion" are QCI's practical advice and are not requirements.

    Expected evidence
    ArtifactScopeOwnerCurrencyVerificationBasis
    Resourced, dependency-aware roadmapAll critical systems and flows requiring transitionExecutive sponsorReviewed at least quarterlyTrace entries to QASI records and committed capacityQCI requirement (QCI-4.1-02)
    Roadmap decision factorsEach roadmap decisionQuantum Risk OwnerAt each decisionCheck horizons, dependencies, lead time and deadlines are recordedQCI requirement (QCI-4.2-02)
    Migration completion metric with baselineItems requiring transitionQuantum Risk OwnerEach assessmentConfirm deferred items remain in the denominatorQCI requirement (QCI-6.2-02)
    Decision records for deferred itemsEach deferralAccountable ownerBefore review dateCheck rationale, interim treatment and triggersEditorial suggestion

    How NIST or other primary authorities address it

    NIST publishes the algorithm standards that roadmaps migrate to, such as FIPS 203 (final, August 13, 2024). NIST IR 8547, which describes a transition trajectory, remains an initial public draft; QCI-QS1 treats it as informative and states that it does not replace earlier applicable policy or contract dates.

    Binding dates come from the law, regulation, contract or policy that applies to the organization. QCI-QS1 requires these to be held in an applicability register that distinguishes binding obligations from recommendations and drafts (QCI-2.2-01).

    How QCI-QS1 addresses it

    QCI-QS1 requires a dependency-aware migration roadmap as a governance artifact (QCI-4.2-01). QCI-M1, which is methodology and not required for conformance, organizes roadmap work into six stages per cryptographic domain.

    QCI-QS1 v2.3 mappings
    RequirementClauseRelationshipPillarGate
    QCI-4.1-024.1explicit requirementP1—
    QCI-4.2-014.2explicit requirementP1—
    QCI-4.2-024.2explicit requirementP4—
    QCI-6.2-026.2explicit requirementP4—
    QCI-2.2-012.2supporting evidenceP1—

    Common mistakes

    • Counting a vendor release or pilot as a completed migration (QCI-6.2-02).
    • Moving dates later to hide a capacity shortfall instead of recording a delivery risk (QCI-4.1-02).
    • Postponing all signature and hardware work until key exchange is finished (QCI-4.2-02).
    • Removing deferred items from the completion denominator.

    Questions for the board

    • Which roadmap items are in production acceptance, and which are still planning or procurement?
    • Where is committed capacity below what the roadmap needs?

    Questions

    Is a roadmap the same as a delivery schedule?

    No. Under QCI-QS1 it is a governed record of dependencies, owners, capacity, milestone types and decisions. Dates are commitments with owners, and shortfalls are recorded as delivery risks (QCI-4.1-02).

    Must key exchange be migrated before signatures?

    No. QCI-QS1 says there is no mandatory sequence that postpones all signature or hardware work until key-exchange work is complete (QCI-4.2-02).

    Does a deferred item still count toward migration completion?

    Yes. Deferring an item does not remove it from the denominator (QCI-6.2-02).

    Sources

    1. QCI-QS1 Quantum Readiness and Post-Quantum Cryptography Governance Standard, Quantum Core Institute, Version 2.3, September 23, 2026, Clauses 4.1–4.2. Supports: Roadmap content and decision factors.
    2. QCI-QS1 Quantum Readiness and Post-Quantum Cryptography Governance Standard, Quantum Core Institute, Version 2.3, September 23, 2026, Clause 6.2. Supports: Completion measurement.
    3. QCI-QS1 Quantum Readiness and Post-Quantum Cryptography Governance Standard, Quantum Core Institute, Version 2.3, September 23, 2026, Clause 2.2. Supports: Applicability register.
    4. QCI-M1 Migration Governance Method, Quantum Core Institute, V2.0, September 23, 2026 (methodology; not required for conformance), Sections 2–3. Supports: Stages and principles.
    5. FIPS 203, Module-Lattice-Based Key-Encapsulation Mechanism Standard, NIST, Final, August 13, 2024. Supports: ML-KEM specification and final status.
    6. IR 8547 (Initial Public Draft), Transition to Post-Quantum Cryptography Standards, NIST, Initial public draft, November 12, 2024. Supports: Draft transition guidance; not final.

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    Page history

    Published
    Not yet recorded
    Standard edition
    QCI-QS1 v2.3 (September 23, 2026)

    Cite this page

    Quantum Core Institute. (n.d.). PQC migration roadmap, milestones and decision records. https://quantumcoreinstitute.com/learn/migration/pqc-migration-roadmap

    Link: https://quantumcoreinstitute.com/learn/migration/pqc-migration-roadmap