NIST admits crypto agility answers aren't clear yet

NIST cybersecurity engineer Bill Newhouse, speaking on the sidelines of the Billington Cybersecurity Summit on September 8, 2026, acknowledged what contractors and federal acquisition officers already feel: the cryptographic agility guidance framework still isn't operational. "We don't have those yet entirely," Newhouse said of the mapping that would connect migration questions to specific agility areas, including hardware, embedded systems, and procurement language.

NIST's National Cybersecurity Center of Excellence finalized CSWP 39, "Considerations for Achieving Crypto Agility: Strategies and Practices," in late 2025. The white paper came out of a multi-year process, collaborators from over 40 organizations, a March 2025 workshop with presentations from 32 groups, and two rounds of public comment. It surveys what crypto agility means across protocols, applications, software, hardware, and firmware. But surveying the landscape is not the same as providing the operational playbook. As Newhouse put it, the next step is framing the right questions: "You can't do unless everybody else does it?"

That gap matters because of EO 14412, signed June 22, 2026. The order makes post-quantum cryptography transition an explicit policy priority and references FIPS-approved PQC algorithms, the set NIST published in August 2024. The timeline is tight and the stakes are high. NSA's Adrian Stanger, on the same panel, called the PQC transition "more comparable to Y2K than any of our previous crypto migrations" and said it needs to be a "boardroom-level topic" with regular progress reports.

Hardware carve-outs and the acquisition question

Newhouse pointed to a concrete problem that doesn't show up in most transition planning documents. "People who are doing stuff with hardware and embedded systems, have they carved out enough room to make this all work?" he asked. That question, he said, "becomes also part of your acquisition question." In other words, agencies and contractors are supposed to be making procurement decisions now that accommodate cryptographic agility, but the guidance telling them what to require isn't here.

TLS 1.3 and the places crypto hides

Stanger noted that moving to TLS 1.3 isn't a minor protocol switch, it often requires architecture changes, which is "another reason why we need to get started working on that today." He also warned the audience that "crypto is used in a lot of places and can show up in code in places you may not expect." Palo Alto Networks' Jim Smid reinforced the agility message: "You need to have crypto agility. You don't know what will be broken in the future."

Newhouse also flagged CISA's role under the executive order, specifically the Cryptographic Bill of Materials (CBOM) guidance due in December. He said CBOM is "the place to put the answers" on discovery and inventory but cautioned that how those answers drive the next process is a "different thing", one that will involve other Bills of Materials including SBOM and HBOM.

None of this is a surprise to practitioners who've been watching the PQC migration unfold since NIST published the algorithms in August 2024. What's new is NIST saying openly that the agility-to-procurement mapping isn't done, while the executive order clock is running.