PQC Migration Lab: Plan for the NIST IR 8547 Deadlines
NIST IR 8547 went final on 27 October 2026, and federal high impact systems now have 2030 and 2031 deadlines. Rehearse the first year of a post-quantum migration on a fictional firm: what to inventory, what to move first, and what to tell the board. For what changed, read our NIST IR 8547 final news post; to work out your own dates, use the PQC deadline calculator.
You are Sam Rivera, the new crypto-agility lead at Example Harbor Financial, a fictional mid-size US financial-services firm. Example Harbor Financial also runs one system for a federal agency, which the agency classes as high impact. NIST IR 8547 went final on 27 October 2026. Morgan Patel, the CISO, wants a plan. Across 8 decisions you set the inventory scope, decide what to move first, sort out which deadlines apply, choose a TLS key exchange, deal with an appliance that cannot do post-quantum cryptography, plan code signing, clean up SHA-1 and 112-bit symmetric crypto, and brief the board. The firm, its systems and its vendors are made up. Every date, algorithm and quote comes from the primary sources listed in the debrief; where an answer is judgement, the feedback says so.
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TL;DRWhat this lab is
5 points
- A scenario lab: you are the new crypto-agility lead at a fictional US financial-services firm that also runs one system a federal agency classes as high impact.
- You make 8 scored decisions: what to inventory first, what to move first, which deadlines apply, hybrid or pure ML-KEM for TLS, an appliance that cannot do PQC, the code-signing roadmap, SHA-1 and 112-bit symmetric clean-up, and the board update.
- Dates, algorithms and quotes come from NIST IR 8547 (final, October 2026), EO 14412, OMB M-26-15, FIPS 203 and 204, SP 800-208, RFC 10024 and CISA. The firm and its systems are made up. Where an answer is judgement, the feedback says so.
- A final score and grade, a shareable scorecard and next-step links. A downloadable debrief is available with a paid plan.
- Training, not legal or contract advice: check your own contracts and the current sources before you plan.
Frequently asked questions
What did the final NIST IR 8547 change?
NIST IR 8547 went final on 27 October 2026. It deprecates RSA, ECDSA, EdDSA, finite-field and elliptic-curve Diffie-Hellman and MQV after 2030 and disallows them under NIST standards and guidelines after 2035, at every strength. The November 2024 draft had split them by strength; the final does not. It also says this window does not alter the earlier deadlines for federal high value assets and high impact systems.
Do the 2030 and 2031 federal PQC deadlines apply to private companies?
EO 14412 (22 June 2026) and OMB M-26-15 (24 June 2026) require federal high value assets and high impact systems to use PQC for key establishment by 31 December 2030 and for digital signatures by 31 December 2031. They bind federal agencies, not the private sector, and M-26-15 does not apply to national security systems. If you run a high impact system for an agency, expect the agency to hold it to those dates. EO 14412 also ordered a FAR proposed rule requiring covered contractors to comply with FIPS, including PQC, by 31 December 2030; as of November 2026 it has not been published.
Should TLS use hybrid X25519MLKEM768 or pure ML-KEM?
RFC 10024 (August 2026) defines X25519MLKEM768 for TLS 1.3, IANA codepoint 0x11EC, marked Recommended. NIST IR 8547 allows hybrid key establishment in FIPS 140 validation when at least one input comes from an approved scheme, and expects hybrids to be temporary measures before a second move to PQC-only. OMB M-26-15 calls hybrid a resource-intensive stopgap and asks for an evaluation of the trade-offs. ML-KEM-768 is NIST's recommended default parameter set.
What should a cryptographic inventory (CBOM) cover first?
OMB M-26-15 describes a continuously updated inventory built from software composition analysis of SBOMs, SAST and DAST to find cryptographic functions in code, and network scanners for protocols and cipher suites, feeding a central Cryptographic Bill of Materials. CycloneDX 1.7 records algorithms, certificates, protocols and keys as cryptographic-asset components. Start with high impact systems and data that must stay secret for years.
Does AES need to be replaced for post-quantum security?
No. NIST IR 8547 says approved symmetric primitives with at least 128 bits of classical security are believed to meet at least Category 1. AES-128 is Category 1 and AES-256 Category 5. What does need to go: NIST's 112-bit symmetric standards, which will be disallowed in 2030, and SHA-1, which is deprecated and will be disallowed in FIPS-validated modules after 2030.
Can I download my debrief?
The debrief is shown on the page. Downloading it as Word, PDF or Markdown needs a paid plan.
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