GAO

GAO Finds None of 24 Agencies Ready for Post-Quantum Encryption, and 16 Say It Is Too Early to Test

GAO reported on 6 October that none of the 24 largest federal agencies has fully done the groundwork OMB set for moving to post-quantum encryption, and 23 haven’t tested it at all.

The report, GAO-27-108740 (reissued with revisions on 14 October), is the public version of a sensitive audit GAO sent to agencies in September 2025. It took a year to clear the redactions. In that year the White House raised the stakes: an executive order in June set hard dates for the switch, and OMB followed with a migration memo. The public report shows agencies starting that clock from far behind.

Three tasks, almost none finished

The threat is a future “cryptographically relevant quantum computer”, one strong enough to break the public-key encryption that protects federal logins and stored data. None exists today. GAO says most experts expect one is possible, perhaps as soon as the 2030s. The near-term danger is collection: an adversary can copy encrypted federal traffic now and decrypt it later.

GAO built its test from OMB’s own guidance. Agencies were to do three things: keep an annually updated, prioritised inventory of systems that use vulnerable cryptography; work out the funding needed to move priority systems to post-quantum algorithms; and test those algorithms in their own networks.

The scores are poor. On the inventory, one of 24 agencies fully met all the steps that applied. On funding, none did; 21 produced partial estimates and three produced none. On testing, one agency had done the market research step. The other 23 had done neither step.

Staffing explains part of it. Eighteen agencies told GAO they lack cryptography expertise. Only six had taken steps to train staff.

The vendor excuse

The sharpest finding is about testing. Sixteen agencies told GAO it was too early to pick testing candidates or try post-quantum cryptography in their networks, because vendors were still building the new algorithms into their products.

GAO didn’t accept that. OMB’s guidance asking agencies to prepare dates from November 2022, before NIST finalised the core post-quantum standards in August 2024. Open-source tools for trying the algorithms have been around for at least four years. Agencies could have tested without waiting for a vendor release.

CISA appears in the report as part of the slow loop. One agency said it was waiting for a CISA discovery tool. CISA told GAO it never asked agencies to wait. OMB’s guidance had tasked CISA with working with vendors to find candidate products for testing.

The money question is just as loose. OMB gave congressional committees a governmentwide estimate of about $7.1 billion to move priority systems to post-quantum cryptography or replace legacy systems that can’t support it. OMB said much of that reflects old systems. With 21 agencies submitting only partial cost estimates and three none, the figure rests on incomplete inputs.

2030, 2031 and 2035

The deadlines are now set by the White House instead of guidance. Executive Order 14412, signed on 22 June, orders high-value assets and high-impact systems to use post-quantum key establishment by 31 December 2030 and post-quantum digital signatures by the end of 2031. OMB memo M-26-15, issued on 24 June, gives agencies 120 days to file migration plans with OMB and the Office of the National Cyber Director, which lands this week, about 22 October. The memo puts full migration of remaining systems in 2035.

That date isn’t new. OMB’s 2022 memo M-23-02 already told agencies to flag data that would still be sensitive if decrypted by a quantum computer in 2035. GAO found some agencies left that data out of their inventories.

The order also reaches contractors. It tells the FAR Council to propose a rule within 180 days making covered contractors to meet federal cryptography standards, including the post-quantum algorithms, by the end of 2030. CISA has 270 days to publish guidance on a cryptographic bill of materials, a list of the cryptography inside a product.

What GAO asked for

The sensitive report made 89 recommendations to 23 agencies, mostly to set up inventory processes and identify funding. Twelve agencies agreed, two partly agreed, seven neither agreed nor disagreed, and one disagreed with three of its four. Interior didn’t respond. GAO made no new recommendations in the public version.

The pattern matches GAO’s work on legacy federal IT: old systems that can’t take new cryptography are the costliest part of the bill. It also lands on a CISA that is smaller and without a confirmed director.

The 2030 deadline is four years away. Most agencies haven’t run a single test.