Somewhere right now, encrypted European data may be sitting in an attacker's archive, waiting for a quantum computer powerful enough to open it. This "harvest now, decrypt later" threat is why Brussels has put post-quantum cryptography (PQC) on the NIS2 agenda. If you build software or services for EU customers, here is what the 2026 proposal says, what it does not say, and what to do before the year ends.
What the 2026 EU Proposal Actually Says
On 20 January 2026, the European Commission published COM(2026) 13, a proposal to amend the NIS2 Directive alongside a revised Cybersecurity Act (COM(2026) 11). The PQC change is a new point (k) in Article 7(2): Member States must adopt policies, within their national cybersecurity strategies, for the transition to post-quantum cryptography, taking into account the timelines set in applicable EU law and policy.
Two points matter for developers. First, it is still a proposal. It is moving through the ordinary legislative procedure as 2026/0012(COD), and as of early October 2026 neither the European Parliament nor the Council had adopted a position. Second, it addresses Member States, not companies directly. Your existing duty sits in Article 21, which already requires policies and procedures on the use of cryptography and encryption. If the amendment is adopted, Member States would have 12 months to transpose it.
The EU PQC Roadmap: Three Dates to Know
The proposal leans on the Coordinated Implementation Roadmap for the transition to PQC, released in June 2025 by the NIS Cooperation Group in response to Commission Recommendation (EU) 2024/1101. Its milestones:
- 31 December 2026: Member States have implemented the first steps, drawn up initial national roadmaps and started pilots for high- and medium-risk use cases.
- 31 December 2030: high-risk use cases are migrated, and quantum-vulnerable public-key mechanisms are no longer used stand-alone for them.
- 31 December 2035: medium-risk use cases are migrated, and low-risk ones as far as feasible.
The roadmap is a recommendation, not binding law, and the 2026 milestone is addressed to Member States. Even so, the NIS Cooperation Group's April 2026 FAQ says entities in scope of NIS2 should, at a minimum, build a cryptographic inventory and dependency maps, involve their supply chain and run a quantum risk analysis. Expect audit and procurement questions to follow.
A Developer's PQC Checklist for 2026
1. Build a cryptographic inventory. Find every use of RSA, ECDSA, ECDH and Diffie-Hellman across your code, dependencies, certificates, HSMs and firmware, and record it in a standard format such as a CycloneDX CBOM. According to the NIS Cooperation Group, you do not need a finished inventory before you start planning.
2. Prioritise by data lifetime. The roadmap treats data that must stay confidential for 10 years or more, and systems that would take over 8 years to migrate where compromise would have high impact (software-update signing is the example), as high risk.
3. Design for crypto-agility. Put algorithms behind interfaces, avoid hard-coded key sizes and make algorithm choice configurable, so swapping primitives becomes a configuration change rather than a rewrite.
4. Learn the NIST standards. FIPS 203 (ML-KEM) covers key establishment; FIPS 204 (ML-DSA) and FIPS 205 (SLH-DSA) cover signatures. All three were finalised on 13 August 2024. FN-DSA (FIPS 206) is still a draft, and NIST selected HQC in March 2025 as a backup KEM. ML-KEM-768 and ML-DSA-65 are common starting points for civilian systems.
5. Plan for size and hybrids. Hybrid key exchange, pairing a classical algorithm with ML-KEM, is a widely used bridge. ML-DSA signatures run from roughly 2.4 to 4.6 KB, so test certificate chains, token limits, packet sizes and HSM support early.
6. Question your suppliers. Ask vendors and library maintainers for PQC roadmaps. The Cyber Resilience Act's main obligations apply from 11 December 2027, and the EU roadmap recommends that products with a lifetime beyond 2030 be upgradable to PQC, with post-quantum signatures protecting update mechanisms.
7. Test what you ship. New cryptography brings new bugs: misconfigured hybrids, downgrade paths and side channels. Include PQC changes in your penetration testing and vulnerability assessments, ideally with a CREST-accredited provider.
A practical way to begin: pick one high-value service this quarter, such as your API gateway or code-signing pipeline, map its cryptography and run a pilot with hybrid key exchange in a test environment. A small, well-documented pilot gives you evidence for auditors, realistic performance numbers for architects and a template for every service that follows.
Why This Matters for NIS2 Compliance
NIS2 penalties are substantial: maximum fines of at least €10 million or 2% of worldwide annual turnover for essential entities, and at least €7 million or 1.4% for important entities, whichever is higher. Management bodies can also be held liable for failing to comply. PQC readiness belongs inside your wider NIS2 compliance programme, alongside risk analysis, incident handling and supply chain security, not in a side project. A vendor-neutral cybersecurity consultancy such as VISTA InfoSec can support gap analysis and risk assessment, so developers and compliance teams work from the same plan.
Frequently Asked Questions
Is NIS2 post-quantum cryptography mandatory today?
Not as a standalone obligation on companies. The amendment is only a proposal and targets Member States. However, Article 21 already requires cryptography policies, and Member States are expected to have national PQC roadmaps by the end of 2026.
Which post-quantum algorithms should developers start with?
Start testing ML-KEM for key establishment and ML-DSA for signatures, ideally in a hybrid setup, and keep your code crypto-agile so FN-DSA and HQC can follow once finalised.
Start Now, Not on 31 December
The 31 December 2026 date is a Member State milestone, not a developer deadline, but it is the clearest signal yet that Europe expects organisations to know where their cryptography lives. Start with an inventory, rank your risks and build agility into every release. For an expert second opinion on your cryptographic risk, talk to the VISTA InfoSec team about cybersecurity and compliance support.
References
EU Coordinated Implementation Roadmap for the Transition to PQC
Recommendation (EU) 2024/1101
COM(2026) 13, proposal amending NIS2
Directive (EU) 2022/2555 (NIS2)
European Parliament Legislative Observatory, 2026/0012(COD)
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