CISA PQC product categories list: what it means for OT

The CISA PQC product categories list is a US government reference document. It names the categories of hardware and software in which products using post-quantum cryptography (PQC) standards are already widely available, and the categories where vendors are still making the transition. It is not an approved-product list. It tells buyers in which categories they should no longer accept quantum-vulnerable products.

For organizations that run operational technology (OT) and critical infrastructure, the list matters for what it covers and also for what it leaves out. This article explains where the list came from, how it fits with Executive Order 14412 and the OMB memoranda on cryptographic inventories, and how operators can use it when they buy equipment that protects connections between sites, cloud environments and remote users.

What is the CISA list of product categories that support post-quantum cryptography?

It is a two-part list published by the CISA Post-Quantum Cryptography Initiative. One table covers categories where PQC-capable products are widely available. The other covers categories that are still transitioning to PQC.

When CISA announced the list, it described it as a resource that identifies hardware and software categories that currently support or are expected to support-post quantum cryptography (PQC) standards. In alignment with the Executive Order, CISA developed this list, complete with example product types, in close collaboration with National Security Agency (NSA). The scope is narrow: The lists focus on categories of available products, typically acquired by the federal government, that utilize cryptographic algorithms.

The list measures PQC support against two cryptographic functions: key establishment and digital signatures. These map to the NIST standards FIPS 203 (ML-KEM) for key establishment, and FIPS 204 (ML-DSA), FIPS 205 (SLH-DSA) and NIST SP 800-208 for signatures.

The four widely available categories are cloud services (PaaS, IaaS), collaboration software (chat and messaging), web software (browsers, web servers) and endpoint security (data-at-rest and full disk encryption). Even these come with a caveat. CISA notes that most of these categories have implemented PQC for key encapsulation and key agreement but have not yet widely implemented PQC for digital signatures and authentication.

What does Executive Order 14306 require for post-quantum cryptography?

Executive Order 14306 made the product categories list mandatory. It required DHS, acting through CISA and in consultation with NSA, to publish the list by 1 December 2025 and to update it regularly.

The order, signed on 6 June 2025, amended Executive Orders 13694 and 14144. In CISA’s words, President Trump issued Executive Order 14306 that directed DHS, acting through CISA, to publish a list of product categories of widely available products that support post-quantum cryptography (PQC). The amended text also kept a requirement for federal agencies to support TLS 1.3 or a successor protocol by 2 January 2030. That is a transport-layer prerequisite, because hybrid post-quantum key exchange in TLS depends on TLS 1.3.

Federal PQC policy did not stop there. Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks (June 22, 2026) sets firmer timelines. NIST’s NCCoE summarizes it this way: EO-14412 mandates an accelerated, government-wide migration to PQC for federal systems, establishing binding deadlines for high-value assets and directing the Federal Acquisition Regulatory Council to require contractor compliance with NIST PQC standards. According to a public analysis of the text, Section 4(b), directs the issue of guidance requiring federal agencies to transition high-value assets and high-impact systems to post-quantum key establishment by 31 December 2030 and to post-quantum digital signatures by 31 December 2031.

Does the CISA list include networking hardware and VPNs?

Yes, but networking hardware sits in the “transitioning” table, not the “widely available” one. VPNs are not named as a separate category, and OT devices are explicitly excluded.

Table 3 lists Networking Hardware with the example types proxy servers, routers, firewalls, switches, appliances, and Networking Software with software-defined networking, DNS and network operating systems. VPN concentrators and encryption gateways would most plausibly fall under “appliances”, but the document does not say so directly. Because the category is in Table 3, CISA does not yet tell buyers to accept only PQC-capable products there. Instead, Table 3 lists product categories where manufacturer implementation and testing of PQC capabilities are encouraged.

For network equipment, CISA’s note on secondary functions matters. CISA says it is important that the products listed in Table 3 implement PQC for core features and for all secondary functionality, such as for software updates. A router whose tunnels use hybrid key exchange, but whose firmware updates are signed with a quantum-vulnerable algorithm, has only finished part of the transition.

How should critical infrastructure operators use the CISA list in procurement?

Use it as a floor for IT purchases and as a prompt for questions about network purchases. Do not read it as a statement about OT. Buying decisions still require checking each product and each data path.

For Table 2 categories, CISA’s guidance is direct: organizations should acquire only PQC-capable products when planning acquisitions and procuring products in these categories. At the list’s release, CISA’s Acting Director Madhu Gottumukkala said that “organizations must prioritize the procurement of PQC-capable technologies.”

For networking and remote-access purchases, which matter most for site-to-site, edge-to-cloud and remote user connections in OT, these steps follow from the list:

• Ask which functions are post-quantum. Find out whether PQC covers key establishment only, or also authentication and firmware signing. The list separates these functions, and so should your tender.
• Require algorithm agility in writing. NIST notes that the Falcon digital signature algorithm and HQC key encapsulation mechanism were selected for ongoing standardization, so the algorithm set will grow. Check whether algorithms can be swapped on equipment you expect to run for ten years or more.
• Protect the links before the endpoints. Many field devices cannot be upgraded. Encrypting the connections between sites at the network layer reduces the “harvest now, decrypt later” exposure of traffic crossing public or shared networks, without waiting for every controller to support PQC. Overlay gateways, such as the QPN gateway from Quantum Network, follow this pattern: they sit at each end of a link and encrypt at Layer 3 alongside the existing firewalls and routers.
• Check operational fit for OT. Check failure behavior (does the link ever fall back to cleartext?), latency overhead, whether the device depends on cloud services, and whether it works in air-gapped networks.
• Re-check the list on a schedule. CISA says the list will be regularly updated. When a category moves from Table 3 to Table 2, your procurement rules for it should change too.

What do OMB M-23-02 and M-26-15 require for cryptographic inventories?

OMB Memorandum M-23-02 requires federal agencies to inventory their quantum-vulnerable cryptographic systems every year. OMB Memorandum M-26-15 moves from inventory to carrying out the migration, against the deadlines in EO 14412.

M-23-02, issued in November 2022, implements National Security Memorandum 10. The NCCoE explains that M-23-02 provides direction for agencies to comply with NSM-10 and further defines what systems/assets and associated information to include in inventories. Agencies submit a prioritized inventory each year, with cost estimates for the transition. The scope focuses on high-value assets and high-impact systems.

The statutory basis is the Quantum Computing Cybersecurity Preparedness Act, codified at 6 U.S.C. § 1526. Under it, CISA consults with OMB and ONCD, and the guidance requires each federal agency to establish and maintain a current inventory of IT vulnerable to quantum decryption and establishes criteria for agencies to prioritize their inventory efforts.

M-26-15, titled “Execution of the Migration to Post-Quantum Cryptography” and issued in June 2026, is the guidance that EO 14412 called for. One public analysis describes it as placing the move to post-quantum signatures in a 2031 phase, after key establishment. On its PQC Initiative page, CISA describes its own role under M-26-15 and M-23-02 as migration planning, working with cloud service providers, identifying systems most vulnerable to quantum attacks, and assessing cryptographic inventory submissions from civilian agencies. The longer horizon is set by NIST IR 8547: NIST will deprecate and ultimately remove quantum-vulnerable algorithms from its standards by 2035, with high-risk systems transitioning much earlier.

Inventory tools themselves fall outside the product list. CISA states that automated cryptographic discovery and inventory products are out of scope of these lists.

Do these US rules apply to private critical infrastructure owners?

Not directly. The executive orders and OMB memoranda bind federal agencies. Private owners and operators are affected indirectly, through federal contracts, sector agencies and the market.

Three channels matter in practice. First, operators that sell to or work for federal agencies may face PQC clauses once the FAR Council acts under EO 14412. Second, under EO 14412 CISA works with Sector Risk Management Agencies (SRMA) to assist critical infrastructure owners and operators in developing PQC migration planning. Third, vendor roadmaps follow federal demand, so the product categories list affects what operators can buy.

CISA’s earlier analysis of the 55 NCFs (National Critical Functions) showed that electricity generation, transmission and distribution, pipelines, rail, mass transit and wastewater all depend on industrial control systems. These are the same OT environments the product list excludes. As NIST puts it, “Organizations should begin applying these standards now to migrate their systems to quantum-resistant cryptography.”