PQC Migration Project Plan Template
An editable post-quantum cryptography migration plan built on the five phases in OMB M-26-15, with tasks, Responsible and Accountable owners, deliverables, exit criteria and indicative durations. Track status and target dates and export the plan.
Template & sample only — a structured starting point with sample content for a fictional organisation, not legal, audit or compliance advice.
Plan preview: phases, owners and deliverables
The window column is the OMB M-26-15 timeline for US federal HVAs and high impact systems; other organisations plan to the NIST IR 8547 window (deprecated after 2030, disallowed after 2035). Durations are indicative, not a benchmark. The full template adds tasks with Responsible and Accountable owners, status and target dates.
| Phase | OMB M-26-15 window (federal) | Indicative duration (months) | Phase owner | Deliverables | Exit criterion |
|---|---|---|---|---|---|
| Phase 1: Strategy, Planning and Discovery | 2026–2027 | 12 | PQC migration lead | Named PQC migration lead; scope and priority rules; cryptographic inventory as a central CBOM (CycloneDX 1.7); secrecy-lifetime estimate per data set; replace or decommission list; PQC migration plan aligned to NIST IR 8547. | Every in-scope system is in the CBOM with an owner and a priority; the migration plan and the replace or decommission list are approved by the executive sponsor. |
| Phase 2: Pilots and Early Migration | 2027–2028 | 12 | Enterprise architecture | TLS 1.3 support report and plan; hybrid key-exchange pilot (X25519MLKEM768) report; ML-DSA test PKI; library, HSM and vendor support matrix; crypto-agility design standard; updated CBOM. | Pilot results reviewed; a standard migration pattern for key establishment is approved; vendors without a PQC roadmap are on the replace list. |
| Phase 3: Prioritized Migration (key establishment) | 2028–2030 (federal HVAs and high impact systems: key establishment by 31 Dec 2030; TLS 1.3 by 2 Jan 2030) | 24 | PQC migration lead | Priority systems on ML-KEM (ML-KEM-768 default) or hybrid key establishment; TLS 1.3 everywhere it is required; VPN and SSH key exchange migrated; stored data keys re-wrapped; systems that cannot support PQC replaced or decommissioned. | No priority system uses quantum-vulnerable key establishment on its own; the CBOM shows the remaining exceptions with an owner and a date. |
| Phase 4: Signature Migration | 2031 (federal HVAs and high impact systems: signatures by 31 Dec 2031) | 12 | PKI / certificate owner | PQC certificate hierarchy (ML-DSA); code-signing migration (ML-DSA, or LMS / XMSS for software and firmware signing); token and document signing migrated; signature verification plan for legacy data. | Priority systems sign with a PQC algorithm; code and firmware signing keys are PQC; legacy classical signatures are kept for verification only. |
| Phase 5: Full Migration | 2035 (NSM-10 goal; NIST IR 8547: disallowed after 2035) | 36 | CISO | Remaining lower-risk systems migrated; hybrid configurations reviewed for a move to PQC only; classical-only configurations retired; final CBOM; lessons learned. | The CBOM shows no quantum-vulnerable public-key algorithm in active use; anything left is for legacy use only (decrypting or verifying already protected data). |
Customise it with your organisation’s details and download it as Word, PDF, Markdown or CSV with Pro.
An editable migration plan built on the five phases in OMB M-26-15: Strategy, Planning and Discovery; Pilots and Early Migration; Prioritized Migration (key establishment); Signature Migration; Full Migration. Each phase has tasks with Responsible and Accountable roles, deliverables, an exit criterion and an indicative duration. The 2030 and 2031 dates bind US federal HVAs and high impact systems; other organisations plan to the NIST IR 8547 window (deprecated after 2030, disallowed after 2035). The sample is a fictional insurer.
Your context
Assumptions and constraints
Phases
One row per OMB M-26-15 phase. The window column is the federal timeline; durations are indicative.
Tasks
Tasks per phase with the Responsible and Accountable roles (see the PQC RACI template). Add target dates for your organisation.
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TL;DRWhat this template gives you
5 points
- Five phases from OMB M-26-15: Strategy, Planning and Discovery (2026–2027); Pilots and Early Migration (2027–2028); Prioritized Migration for key establishment (2028–2030); Signature Migration (2031); Full Migration (2035).
- The federal dates (PQC key establishment by 31 Dec 2030, signatures by 31 Dec 2031, TLS 1.3 by 2 Jan 2030) bind US federal HVAs and high impact systems. Everyone else plans to the NIST IR 8547 window: deprecated after 2030, disallowed after 2035.
- Deliverables include the CBOM, the migration plan, the replace or decommission list, TLS 1.3 support, a hybrid X25519MLKEM768 pilot and the code-signing migration.
- Every task has a Responsible and an Accountable role, matching the PQC RACI template. Every phase has an exit criterion.
- Durations are indicative, not a benchmark. The summary adds them up, gives an indicative finish date and warns if it lands after 2035.
Frequently asked questions
Do the 2030 and 2031 deadlines apply to my company?
Only if you run US federal civilian high value assets or high impact systems. EO 14412 and OMB M-26-15 set PQC key establishment by 31 December 2030 and digital signatures by 31 December 2031 for those systems. They do not cover the private sector or national security systems. For everyone else the reference is NIST IR 8547 (final, October 2026): quantum-vulnerable public-key algorithms are deprecated after 2030 and disallowed after 2035. Check your sector and national rules too.
Why start with discovery and a CBOM?
You cannot migrate what you have not found. OMB M-26-15 calls a continuously updated inventory of cryptographic assets the foundation of the migration plan, built from SBOM analysis, code scanning and network scanning and held in a central cryptographic bill of materials (CBOM).
Why is key establishment migrated before signatures?
Harvest now, decrypt later. Traffic recorded today can be decrypted once a quantum computer exists, so key exchange protecting long-lived secrets comes first. Signatures are not exposed to that attack, but NIST IR 8547 still calls their transition urgent because it takes longer and is more complex.
Should we use hybrid key exchange?
Often, as a step. Hybrid groups such as X25519MLKEM768 (RFC 10024) combine ML-KEM with classical ECDH. NIST IR 8547 expects hybrids to be temporary, leading to a second move to PQC only, and OMB M-26-15 asks agencies to weigh the trade-offs carefully. The plan has a pilot and a decision record for this.
How long will the migration take?
It depends on how much cryptography you find, how many vendors you depend on and how agile your systems are. The sample phases add up to 96 months if run one after another; overlap shortens that. Treat the durations as a starting estimate, not a benchmark.
Is this a finished document I can rely on?
No. It is a template with sample content for a fictional organisation. It gives you a structured, editable starting point, but it is not legal, audit, compliance or professional advice. Check every date and requirement against the primary source for your sector before you rely on it.
Who can use it?
The page and sample are public. Customising the template is Pro; a free account gets 3 runs in total, shared across every Pro tool, and the generated document is free to view on the page. Download is Pro: downloading or copying the document (Word, PDF, Markdown, CSV) is never part of the free runs. Pro is $5/month or $40/year. Your work is saved in your own browser.
PQC toolkit
The other tools in the post-quantum cryptography program.
- PQC practice pathThe whole program in order: learn, inventory, plan, practise.
- PQC deadline calculatorWhich dates apply to you, by jurisdiction, plus Mosca’s inequality.
- CBOM generatorBuild a CycloneDX 1.7 cryptographic bill of materials.
- CBOM analyzerCheck a CBOM for quantum-vulnerable algorithms.
- PQC migration labMake the migration calls in a scenario and see the trade-offs.
- PQC exam practiceQuestions on NIST IR 8547, FIPS 203–205 and the federal deadlines.
- PQC RACI templateWho does what in the migration, one Accountable per activity.
- Crypto inventory registerOne row per cryptographic use, mapped to M-23-02 and CycloneDX.
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