Germany wants a cryptographic inventory and post-quantum migration plan by the end of 2026

The German government wants organisations in the country to have completed their cryptographic inventory and finished planning the migration to post-quantum cryptography (PQC) by the end of 2026. That is the message of joint guidance from the Federal Office for Information Security (BSI) and the Federal Ministries of the Interior (BMI) and of Digital Transformation and Government Modernisation (BMDS), which the BSI presented on 12 October.

The guidance transposes to Germany the coordinated roadmap that the Member States published in June 2025, with the support of the European Commission, and adopts its deadlines. It is addressed to federal, regional and local administrations, and to organisations and companies, particularly operators of critical infrastructure.

The deadlines

• End of 2026. The initial preparation and planning phase completed, the first migration steps under way and the first cryptographic inventory done.
• End of 2030. High-risk use cases protected with quantum-resistant cryptography.
• End of 2035. Medium-risk use cases, and full migration for almost all systems.

The risk of each use case, high, medium or low, depends on three factors: how vulnerable the cryptography it uses is, the damage a loss of confidentiality would cause, and the time and effort it would take to migrate. For the method, the guidance refers to the EU roadmap and to the PQC Migration Handbook by the Dutch AIVD, CWI and TNO.

For now, the deadlines are “urgent recommendations”. The guidance asks the IT-Planungsrat, the body that coordinates IT between the federal government and the Länder, and UP KRITIS, the public-private partnership for critical infrastructure, to adopt them before the end of 2026 with the greatest possible binding force. Only for classified information are there already mandatory deadlines: the BSI has set them so that products approved for that use migrate before 2030.

What it asks of organisations

• Someone in charge. At the very least, a unit responsible for the migration, with sufficient staff and budget.
• The inventory. A record of cryptographic components and their dependencies, which can draw on inventory tools and cryptographic bills of materials (CBOM), for example using the CycloneDX standard.
• Hybrid schemes. The BSI recommends combining classical and post-quantum algorithms.
• Quantum risk, in risk management, with deadlines for mitigating it.
• The supply chain, from the outset. Suppliers can be contractually required to deliver a CBOM; new developments should use only quantum-resistant cryptography, and procurement should require by default the PQC and crypto-agility requirements of the BSI technical guideline TR-02102.

The guidance also points out that the BSI Act requires “important” and “particularly important” entities, the categories of the NIS2 Directive, to apply the state of the art in cryptography in line with their risk management. And it justifies the urgency with the BSI’s 2025 study, according to which a quantum computer capable of breaking today’s cryptography is likely to be feasible within 15 years at most, that is, by 2040 or earlier.

What changes for decision-makers

For a company with customers or subsidiaries in Germany, the practical deadline is no longer 2030 but the end of 2026: that is when its German customers, especially critical operators and public administrations, should have their inventory and their plan, and when they may start asking suppliers for a CBOM and contractual guarantees of crypto-agility. The deadlines are the same as those of the EU roadmap, which also applies in Spain, where a report by the Spanish Parliament called in March for a faster migration.