PQC Migration RACI Template
Who is Responsible, Accountable, Consulted and Informed for the move to post-quantum cryptography, from naming a migration lead and building the CBOM to migrating key exchange, certificates and code signing. 10 roles, 36 activities with guidance, org-size presets, role workload and a check that every activity has exactly one Accountable role.
Template & sample only — a structured starting point with sample content for a fictional organisation, not legal, audit or compliance advice.
RACI preview: governance, discovery and planning
R = Responsible, A = Accountable, C = Consulted, I = Informed. The full template has 36 activities across 8 phases, with guidance, role holders, workload and checks.
| Phase | Activity | Exec | CISO | Lead | EA | PKI | Apps | Net | Proc | Risk | Audit |
|---|---|---|---|---|---|---|---|---|---|---|---|
| Governance and strategy | Name the PQC migration lead and give them authority | A | R | I | - | - | - | - | - | C | I |
| Governance and strategy | Approve PQC migration scope and objectives | A | C | R | C | - | - | - | - | C | I |
| Governance and strategy | Decide which deadlines apply to the organisation | I | A | C | - | - | - | - | C | R | I |
| Governance and strategy | Set the cryptography policy and approved-algorithm standard | - | A | C | R | C | I | I | - | C | - |
| Governance and strategy | Fund the programme and approve the budget | A | C | R | - | - | - | - | C | I | - |
| Discovery and inventory | Run cryptographic discovery: SBOM analysis, code scanning and network scanning | - | I | A | R | - | C | C | - | - | - |
| Discovery and inventory | Maintain the central CBOM (CycloneDX 1.7) | - | I | A | R | C | C | C | - | - | I |
| Discovery and inventory | Record per-system inventory fields for each application | - | - | C | C | - | A/R | - | - | I | - |
| Discovery and inventory | Inventory certificates, keys, HSMs and code-signing keys | - | I | A | - | R | C | C | - | - | - |
| Discovery and inventory | Inventory network protocols: TLS versions, VPN, SSH | - | I | A | C | - | - | R | - | - | - |
| Discovery and inventory | Collect PQC roadmaps from critical vendors | - | I | A | C | - | C | - | R | I | - |
| Prioritise and plan | Rate data secrecy lifetime and harvest-now-decrypt-later exposure | - | I | C | C | - | R | - | - | A | - |
24 more rows in the full template. Customise it with your organisation’s details and download it as Word, PDF, Markdown or CSV with Pro.
A RACI matrix for migrating to post-quantum cryptography, organised along OMB M-26-15's phases: governance, discovery and CBOM, prioritisation and planning, pilots, key establishment migration, signature migration, full migration and assurance. Ten roles from the board to internal audit, org-size presets, role workload and automatic checks that each activity has exactly one Accountable role and someone Responsible. The sample is a fictional insurer.
The document carries the full matrix, role holders, per-activity guidance, workload and open checks for the 10 roles currently in your matrix.
Organisation size
Smaller organisations do not have every role. A preset keeps the roles that exist at that size and merges each missing role into the nearest one, so its work lands on a real person.
Every role in the matrix is a distinct person or function.
Click a cell to cycle R, A, A/R, C, I; or focus it and press a r b (both) c i -, arrows to move. Open the chevron on a row for what it means, evidence, frequency and pitfalls. R = Responsible (does the work). A = Accountable (owns the outcome and signs it off; exactly one per activity). A/R = accountable and does the work. C = Consulted before the decision (two-way). I = Informed after it (one-way). "-" = not involved.
| Activity | Exec | CISO | Lead | EA | PKI | Apps | Net | Proc | Risk | Audit | Owner (A) |
|---|---|---|---|---|---|---|---|---|---|---|---|
Governance and strategy5 activities Name the owners, set scope and decide which deadlines apply. | |||||||||||
Name the PQC migration lead and give them authority | Exec | ||||||||||
Approve PQC migration scope and objectives | Exec | ||||||||||
Decide which deadlines apply to the organisation | CISO | ||||||||||
Set the cryptography policy and approved-algorithm standard | CISO | ||||||||||
Fund the programme and approve the budget | Exec | ||||||||||
Discovery and inventory6 activities Find every use of cryptography and record it in one CBOM (M-26-15 phase 1). | |||||||||||
Run cryptographic discovery: SBOM analysis, code scanning and network scanning | Lead | ||||||||||
Maintain the central CBOM (CycloneDX 1.7) | Lead | ||||||||||
Record per-system inventory fields for each application | Apps | ||||||||||
Inventory certificates, keys, HSMs and code-signing keys | Lead | ||||||||||
Inventory network protocols: TLS versions, VPN, SSH | Lead | ||||||||||
Collect PQC roadmaps from critical vendors | Lead | ||||||||||
Prioritise and plan5 activities Rank systems by exposure and write the migration plan (M-26-15 phase 1). | |||||||||||
Rate data secrecy lifetime and harvest-now-decrypt-later exposure | Risk | ||||||||||
Prioritise systems for migration | Lead | ||||||||||
Identify systems that cannot support PQC and decide replace or decommission | Exec | ||||||||||
Write and approve the PQC migration plan | Exec | ||||||||||
Add PQC requirements to procurement and contracts | CISO | ||||||||||
Pilots and early migration5 activities Test PQC and hybrid options before rolling them out (M-26-15 phase 2). | |||||||||||
Pilot hybrid TLS key exchange (X25519MLKEM768, RFC 10024) | EA | ||||||||||
Decide where hybrid mode is used and for how long | CISO | ||||||||||
Build and test a PQC test PKI (ML-DSA) | EA | ||||||||||
Set the crypto-agility design standard | CISO | ||||||||||
Plan TLS 1.3 support across the estate | Lead | ||||||||||
Key establishment migration5 activities Move key exchange to ML-KEM or hybrid on priority systems first (M-26-15 phase 3). | |||||||||||
Migrate key establishment on priority applications to ML-KEM or hybrid | Apps | ||||||||||
Migrate TLS termination, VPN and SSH key exchange | Lead | ||||||||||
Re-wrap stored data keys protected by RSA or ECDH key transport | Apps | ||||||||||
Replace or decommission systems that cannot support PQC | Exec | ||||||||||
Track exceptions and residual quantum risk | CISO | ||||||||||
Signature migration4 activities Move certificates, code signing and token signing to PQC (M-26-15 phase 4). | |||||||||||
Build the PQC certificate hierarchy | CISO | ||||||||||
Migrate code and firmware signing | CISO | ||||||||||
Migrate token and document signing | Apps | ||||||||||
Plan verification of legacy classical signatures | Lead | ||||||||||
Full migration and legacy3 activities Finish the remaining systems before the IR 8547 "disallowed after 2035" line (M-26-15 phase 5). | |||||||||||
Migrate the remaining lower-risk systems | Lead | ||||||||||
Move hybrid configurations to PQC only where planned | CISO | ||||||||||
Retire classical-only configurations | Lead | ||||||||||
Assurance and review3 activities Independent checks, management review and keeping this RACI current. | |||||||||||
Independently check that the CBOM matches what runs in production | Audit | ||||||||||
Report migration progress to the board | Exec | ||||||||||
Review this RACI and the role holders | CISO | ||||||||||
Loading…
TL;DRWhat this template gives you
5 points
- A RACI answers one question per activity: who does it, who owns the outcome, who is asked first and who is told after.
- 10 roles: board / executive sponsor, CISO, PQC migration lead, enterprise architecture, PKI / certificate owner, application owners, network / infrastructure, procurement / vendor management, risk / compliance and internal audit.
- 36 activities across 8 phases that follow OMB M-26-15: discovery and CBOM, prioritisation, pilots, key establishment, signatures and full migration, with governance first and assurance last.
- Every activity carries what it means, the evidence to keep, how often it recurs and the pitfall that usually breaks it.
- Exactly one Accountable per row. The checks flag rows with no A or more than one, rows with no R, too many Consulted roles and internal audit owning work it should audit.
Frequently asked questions
Do we have to name a PQC migration lead?
US federal agencies do: EO 14412 (June 2026) requires a PQC migration lead within 30 days, and OMB M-23-02 already asked for a cryptographic inventory and migration lead. Nobody else is required to, but a migration with no single owner tends to stall between the security, architecture and application teams.
Why exactly one Accountable per activity?
If two roles are accountable, neither is. One Accountable role owns the outcome and signs it off; any number of roles can be Responsible for doing the work. Use A/R where the accountable role also does the work, as application owners do for migrating their own systems.
Who should be accountable for the PQC migration overall?
In the sample the executive sponsor is accountable for scope, budget, the plan and replace-or-decommission decisions; the CISO for policy, the PKI and signatures; the migration lead for discovery, the CBOM and network migration; and application owners for their own systems. Change it to match how your organisation decides.
Where does procurement fit?
Procurement is Responsible for collecting vendor PQC roadmaps and for the contract clause. CISA's product categories list (January 2026) says that where PQC-capable products are widely available in a category, organisations should plan to buy only PQC-capable products from it.
Why is internal audit almost never Responsible?
Internal audit has to stay independent of the work it checks. In the sample it owns only the independent check that the CBOM matches what runs in production; everywhere else it is Consulted or Informed, and the checks flag any other A or R.
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 migration project planFive phases with tasks, owners, deliverables and exit criteria.
- Crypto inventory registerOne row per cryptographic use, mapped to M-23-02 and CycloneDX.
More security tools
The tools people use most on PlayCISO.
Catch injected instructions hiding in content your AI agent should only read.
Score your readiness against the first international standard for AI security threats.
Critical CVEs across 21 major vendors, month by month — and what the 2026 surge means.
Build an ordered ruleset, replay labelled packets and catch shadowed and any-to-any rules.
Self-assess all six Functions, from Govern to Recover, and see your weakest one.
Search 172 threat actors across Microsoft, CrowdStrike, Mandiant and community names.