The Certification Bottleneck: How the U.S. Government Is Slowing Its Own Post-Quantum Migration
In June 2026, the Trump administration issued an executive order aimed at accelerating the migration of federal information systems to post-quantum cryptography (PQC). The order was issued amidst ongoing government efforts to migrate these systems from older cryptographic security standards to those approved in 2019 under the first Trump administration. The National Institute of Standards and Technology (NIST)’s Cryptographic Module Validation Program (CMVP) will guide this transition, assessing any encryption modules that federal agencies and contractors might purchase for their own information systems.
This creates a significant bottleneck in the transition process, particularly in light of the administration’s ambitious deadlines. For example, agencies must submit their transition plans to the Office of Management and Budget (OMB) by Oct. 22, 2026, in order for all “high-value” federal assets and systems to transition to PQC-hardened authentication by 2030. While the administration has set a pace for migration that is proportionate to the threat, the certification process cannot deliver solutions at speed.
Between a Deadline and a Hard Place
To appreciate the challenges associated with federal PQC migration requires an understanding of the certification pipeline cryptographic solutions must navigate before becoming available to agencies. The CMVP validation process works as follows: Any vendor that desires to participate in the federal procurement marketplace must first submit its cryptographic module for assessment by a laboratory. These labs must then submit a report of their findings to CMVP, which performs a secondary analysis of the module to ensure that it adheres to federal information system standards (FIPS-140-3). From there, the program issues its final approval for the module’s inclusion in the pool of validated cryptographic modules from which agencies and contractors may select.
But this arrangement works only if CMVP’s final review keeps pace with what the labs send. The program itself is relatively small—NIST’s website lists only 35 staff as part of its Cryptographic Technology Group tasked with carrying out the CMVP duties. A recent NIST presentation notes a significant decrease in staffing over the past three years. Combined with an increased volume of submitted modules, this has led to a significant backlog of 203 modules in process, with an average validation period of 348 days as of January 2026. Indeed, resource constraints at CMVP recently led staff to pause new applications for its laboratory accreditation program. While the NIST presentation notes its intention to request additional resources from Congress, this is unlikely to happen at a pace that would help agencies meet their PQC migration deadlines.
The executive branch has set clear direction on PQC migration that takes into account the threat of a cryptographically relevant quantum computer with an appropriate sense of urgency; however, the bottleneck posed by the CMVP process creates significant complications. The recent sunsetting of all FIPS 140-2 certificates has compounded these complications by essentially collapsing the marketplace of compliant cryptographic products available to the government across the board—not just in the PQC arena. Agencies must now navigate the adoption of 140-3 products in their validation baselines while simultaneously navigating PQC migration, exacerbating a resource squeeze that was already happening prior to migration mandates from the administration.
With only 16 PQC implementations carrying FIPS 140-3 certification as of September 2026, the government is forced to select from a very small pool of eight or nine vendors. This could leave contracting officers with only two or three options during the acquisition process, putting agencies at risk of issues like vendor lock-in or suppressed competition at best and total failure to migrate due to a lack of bids at worst. The problem is even more dire for defense and intelligence agencies, as the Commercial National Security Algorithm 2.0 requires National Information Assurance Partnership validation from the National Security Agency in addition to FIPS 140-3 certification. Consequently, the PQC migration process for National Security Systems faces not one, but two separate restricted certification pipelines.
As R Street’s June 2026 study on PQC migration found, hardening government cryptographic infrastructure is a present-day imperative, not a future contingency. The harvest-now-decrypt-later threat is already active, with adversaries collecting encrypted government data expecting it to be decrypted once mature quantum capabilities emerge. Data with long classification horizons is already at risk, and every month that the CMVP backlog delays migration extends the window of exposure. The government has recognized the imperative to migrate to PQC, but the certification infrastructure intended to ensure quality has become a constraint to migration and a threat to national security.
Enabling Third-Party Validation
The government itself created the CMVP bottleneck, which means government can also eliminate the obstacle. Although the current system treats CMVP as the sole arbiter of cryptographic quality, federal validation is not the only way to ensure module security. A variety of voluntary mechanisms—including vendor warranties and independent certification from third-party evaluators—can provide a similar level of assurance as the CMVP certification process.
Product warranties are a classic solution wherein the buyer cannot easily ascertain the quality of a good or a service. This approach is effective because the seller is demonstrating confidence that their product can at least meet the terms set out in the contract by offering to refund the price of a particular product should it fail to provide the service expected by the buyer. Warranties are traditionally used to cover physical products; however, a growing number of firms have begun offering cyber warranties on security software or monitoring services. Limitations of quality assurance by way of warranty include the fact that the warranty is only as valuable as the seller’s ability to pay and that its terms may not be enough to cover the full loss to users of faulty cryptography.
Admittedly, researchers have noted that cyber warranties tend to offer narrow coverage and create solvency risks to the firms offering them. To address this limitation, some vendors have turned to insurance to help manage solvency risks, adding insurers’ capital to their own resources. Insurers could perform a similar function by underwriting warranties offered by security module firms, thereby strengthening the assurance provided to end users.
In addition to having their own capital at risk, insurers are incentivized to verify the claims made by module providers. While some cyber insurers might possess the internal expertise needed to adjudicate these claims, verification could be contracted out to laboratories or other third-party evaluators able to test the effectiveness of different cryptographic modules. Underwriters Laboratories in particular has provided insurer-backed safety standard certification for a wide range of products, now including cybersecurity solutions, since 1894. This longevity proves that third-party evaluation is not a novel or untested concept.
The fact that an ecosystem for third-party evaluation of cryptographic modules already exists raises questions about the necessity of CMVP review. In this model, insurers who would bear the loss if a module failed would have every reason to vet the laboratories they rely on and could contract with them for the same testing required for CMVP approval. This could open a validation pathway without a secondary federal queue, making additional PQC providers available to federal agencies despite CMVP’s pause on new applications.
Expanding Pipeline Capacity
Congress and the Department of Commerce should create an alternative to CMVP validation for eligible federal procurements. Implementing certification from insurance companies that have independently evaluated and approved lab testing and security standards would reduce the backlog of CMVP approvals while simultaneously growing the underlying PQC ecosystem. Such an alternative should allow government final control over cryptographic product approval standards while introducing competition for testing services to verify compliance with said standards. For example, when a vendor of cryptographic products submits its module to a lab for testing, an insurer could evaluate the lab, review its findings, assess the risks, and ultimately choose whether to provide coverage-backed certification for the module. Government purchasers of eligible procurements could then accept the insurer’s certification instead of the traditional CMVP certification.
This system’s advantage is that insurers underwriting a cryptographic module have a financial incentive to scrutinize testing, monitor vendor behavior, and require ongoing security commitments. Continuous insurance coverage could require vendors to disclose and address security flaws prior to a retest. If they fail to address significant security issues, then their certification could be revoked. The government would retain control over technical requirements and procurement eligibility, while insurers would bear a portion of the financial risk associated with their certification decisions.
A pilot program would allow the government to compare an alternative PQC validation method to conventional validation on multiple criteria including time and cost savings, laboratory participation, and overall security outcomes. If the pilot shows that alternative PQC validation results in acceptable PQC implementation without compromising security or assurance, then the migration to PQC compliance would become faster and more likely to meet the administration’s timetable. If agencies were able to treat an insurer’s willingness to underwrite a module as evidence of its security, then insurers would have a financial reason to build the verification capacity currently lacking in the market. The end goal is to expand the supply of validated PQC solutions without sacrificing security, ultimately ensuring that the government’s own certification process does not become the main obstacle to the migration it is actively trying to accelerate.
Conclusion
The quantum threat to government data will not wait for a validation queue to clear. The CMVP bottleneck is a self-imposed barrier that the government is fully able to remove. CMVP presently lacks the resources to keep up with the demands placed on it, and the government is not required to serve as the validator of last resort when it comes to module security. An alternative approach that leverages insured warranties offered by security firms backed by insurance companies can provide comparable assurances of performance without relying upon government agencies to provide a secondary approval. As a proof of concept, OMB and NIST should approve a pilot program that accepts insurer-backed assurances and module certification as an alternative to CMVP validation. If the pilot is a success, then this alternative approach should become the permanent solution to the validation backlog problem.
Nicholas Thielman is a Resident Fellow in Technology and Innovation at the R Street Institute.
Billy Ludwick is a Research Assistant and Independent Contractor of the R Street Institute.
Mark Dalton is Senior Director of Technology and Innovation policy at the R Street Institute.