Agencies facing three PQC obstacles before Q-Day
OMB set migration deadlines, but agencies don't yet know where all their encryption lives, and the standards themselves create implementation and overhead problems that planning documents alone won't solve.
TL;DR
OMB's June 2026 memo told agencies to name a post-quantum cryptography lead by July and submit migration plans by October. Pilots for high-value systems are expected over the next two years. But agencies are struggling with three structural obstacles: locating every instance of encryption across legacy codebases, the risk of improperly implementing otherwise-sound PQC standards, and significantly larger key sizes that create computational overhead. Rick Muller, chief scientist at IonQ Federal, said most cryptographic breaches trace to implementation failures rather than bad standards, "there is only one way to get these things right, and there are a million ways to get them wrong."
OMB's June memo set a sequence of deadlines (name a PQC lead by July, submit migration plans by October) and agencies are now expected to pilot migrations on high-value systems over the next two years. The clock is running toward a Q-day that most estimates place in the late 2020s or early 2030s, though some private-sector firms are preparing for 2029.
Rick Muller, senior VP and chief scientist at IonQ Federal, laid out three challenges during a Carahsoft-sponsored discussion. The first is simply finding the encryption. Agencies don't know everywhere encryption is used across their systems, and that inventory problem is fundamental, you can't replace what you can't locate. The second is implementation risk: most cryptographic breaches, Muller noted, come from sound standards applied incorrectly. PQC standards are no exception, and the surface area for mistakes is vast.
The third challenge is mechanical. PQC keys are substantially longer than RSA or elliptic curve keys, which means greater computational overhead and harder integration into existing communications infrastructure. That's not a planning-document problem, it's a hardware and performance problem, and it compounds the first two.
What's in motion
NIST finalized its post-quantum cryptographic standards in August 2024 and published transitional guidance (NISTIR 8547) in October 2026, laying out deprecation timelines for quantum-vulnerable algorithms. An informal CISO working group has formed to help agencies identify gaps in their migration processes, according to Bill Newhouse, cybersecurity engineer and PQC project lead at NIST's National Cybersecurity Center of Excellence. Meanwhile, DARPA's Quantum Benchmarking Initiative is running IonQ and other firms through a staged verification process to determine whether any quantum computing approach can reach utility-scale operation, Stage C runs through 2031.
The June 2026 executive order accelerated the governmentwide timeline, and OMB's memo operationalized it with concrete deliverables. But the distance between a submitted migration plan and a deployed, properly implemented PQC environment is large, and Muller's three obstacles suggest the planning phase is only the first of several hard gates.
Published ·Deep Fathom