NIS2 amendment post-quantum cryptography migration deadlines

The NIS2 amendment post-quantum cryptography migration requirement is a proposed change to Directive (EU) 2022/2555 (NIS2). It would oblige every EU Member State to include a policy for moving to quantum-resistant cryptography in its national cybersecurity strategy. That policy would follow the EU milestones: 2030 for critical use cases and 2035 for medium and low risk use cases.

For operators of energy grids, water utilities and other OT-heavy critical infrastructure, the proposal matters less for what it says directly to them than for what it sets in motion. National authorities will turn the EU milestones into concrete expectations. Encrypted connections between sites, cloud environments and remote users are among the first places those expectations will apply.

Does the proposed NIS2 amendment make post-quantum cryptography mandatory?

Not directly for companies. The proposal makes a PQC migration policy mandatory for Member States. Essential and important entities will then meet PQC expectations through national strategies and through supervision of their existing cryptography obligations.

What the text actually says

The Commission proposed targeted amendments to the NIS2 directive on 20 January 2026, as part of a new cybersecurity package. The Council registered it as document 5627/26. In Article 7(2), which lists what a national cybersecurity strategy must contain, it adds a new point (k): a policy for the transition to post-quantum cryptography, taking into account the transition timelines and relevant requirements set out in applicable Union legal acts and policies. The explanatory memorandum lists this among the targeted amendments as the requirement for Member States to adopt policies for the migration to post-quantum cryptography (PQC) as part of their national cybersecurity strategy.

The recital goes further than the article. It states that those policies should align with the milestones set out in Union legal acts and Union policies as well as documents adopted by the NIS Cooperation Group, in particular the June 2025 roadmap, thus achieving the migration to PQC by 2030 for critical use cases and by 2035 for medium and low level use cases.

Where the obligation reaches operators

NIS2 already requires essential and important entities, under Article 21(2)(h), to have policies and procedures on the use of cryptography and, where appropriate, encryption. Once a national PQC policy exists, supervisors have a clear reference point for judging whether an entity’s cryptography policy is adequate. In practice, the PQC obligation will reach operators through that existing article. They will not need a new, separate duty for it to apply.

Legislative status

The proposal runs under procedure 2026/0012(COD). The European Parliament’s Legislative Observatory listed it as “Awaiting committee decision”. On the Council side, the Presidency planned to start the readthrough on the simplification measures of the NIS 2 Directive at the end of May 2026. Once adopted, Member States will have one year to implement the Directive into national law and communicate the relevant texts to the Commission.

Will EU Member States require essential and important entities to migrate to PQC by 2030?

For high-risk use cases in critical sectors, that is the expected direction. However, the 2030 date comes from the NIS Cooperation Group roadmap and a recital. It does not appear as a binding deadline in the amended article, so the exact national requirements will differ.

The policy line goes back to Commission Recommendation C(2024) 2393, published as Commission Recommendation (EU) 2024/1101 of 11 April 2024 on a Coordinated Implementation Roadmap for the transition to Post-Quantum Cryptography. In response, the NIS Cooperation Group established a work stream on PQC, co-chaired by Germany, France and the Netherlands. The resulting roadmap states that all Member States should start transitioning to PQC by the end of 2026, and the protection of high-risk use cases should be transitioned to PQC as soon as possible, no later than by the end of 2030.

When the roadmap was published, Commission Executive Vice-President Henna Virkkunen said that “post-quantum cryptography is essential to ensure a high level of cybersecurity, fortifying our systems against future threats”.

Countries are already moving. ENISA has hosted sessions on national approaches. Estonia’s National PQC Roadmap consists of three phases: conducting a cryptographic inventory of existing systems, creating detailed transition plans with clear timelines and priorities, and implementing these plans. Operators can expect similar inventory and planning demands elsewhere.

What is the difference between the 2030 deadline for critical use cases and the 2035 deadline for medium and low risk use cases?

The 2030 milestone covers high-risk use cases, explicitly including critical infrastructure such as energy and water. The 2035 milestone is the end date for everything else. The difference is about priority and risk, not about which sector you are in.

A Commission presentation hosted by ENISA sets out the roadmap’s milestones. By the end of 2026, PQC roadmaps are defined in each Member State, and planning for high- and medium-risk use cases is underway. By 2030, high-risk use cases are migrated: critical infrastructure (eg water, energy, health care, finance and transportation) and high-risk domains. In addition, quantum-safe software and firmware upgrades are enabled by default. By the end of 2035, all of the migrations should be completed for every risk category.

The 2035 date matches the international picture. Under the transition timeline in NIST IR 8547, NIST will deprecate and ultimately remove quantum-vulnerable algorithms from its standards by 2035, with high-risk systems transitioning much earlier. Equipment that operators buy today without a PQC path may still be in service when its cryptography is no longer accepted.

How will national PQC migration policies affect encrypted site-to-site and remote access connections in energy and water?

Network connections are likely to be in the first wave. They carry data that can be recorded today and decrypted later. For many energy and water operators, they also form the backbone between control centres, field sites and cloud services.

Why key exchange on network links comes first

NIST explains that today’s encrypted data is already at risk from the “harvest now, decrypt later” threat, where adversaries collect sensitive data now with the intention of decrypting it when quantum technology matures. For that reason, organizations might prioritize migrating to the PQC key establishment standard (FIPS 203) for data that is particularly sensitive or needs to be kept secure for a long time. Grid topology, network designs and operational data from water treatment stay sensitive for years. That makes the key exchange on links between sites a logical first target.

Connection types operators should map

Hybrid key exchange and crypto agility

National policies are likely to accept, or even prefer, hybrid schemes during the transition. In the NIS Cooperation Group’s consultation, respondents indicated that they considered the clear timelines and milestones, actionable steps, risk-based approach, alignment with global best practice and consistency of timelines, hybrid approaches and crypto agility most useful. EU standardisation planning also notes that the recommendations encourage to implement hybrid solutions with both PQC and current asymmetric cryptography. For OT links, the practical question is whether existing VPN and remote access components can run a hybrid key exchange, and whether their algorithms can be swapped later without replacing hardware.

What should OT operators do now to prepare for national PQC requirements under NIS2?

Start with an inventory and a risk classification of every encrypted connection. Then set procurement and architecture rules so that new and renewed links support post-quantum key exchange and can change algorithms later.

Readiness is low across the board. ENISA’s 2024 survey of NIS2 high-criticality sectors found:

• 4% of organisations had already invested in post-quantum cryptography (ENISA, NIS Investments 2024, November 2024).
• 68% said they will not invest in quantum-safe cryptography (ENISA, NIS Investments 2024, November 2024).
• The survey covered 1,350 organisations across all 27 Member States (ENISA, NIS Investments 2024, November 2024).

Separately, the Commission says the wider amendment package will ease compliance for 28,700 companies, including 6,200 micro and small-sized enterprises (European Commission, January 2026). Any relief on administrative burden will not remove the PQC planning work.

Practical steps for the next 12 to 24 months

1. Inventory connections, not just certificates. For each link between sites, to cloud environments and for remote users, record the protocol, the key exchange in use, who owns each endpoint, the firmware status and how long the data it carries must stay confidential.
2. Classify against your national roadmap. Tag links that carry control traffic, privileged remote access or long-lived sensitive data as candidates for 2030, and document why. That record is what a supervisor will ask for under Article 21(2)(h).
3. Separate network-layer from device-layer migration. PLCs and RTUs often cannot be upgraded quickly. Protecting the transport between sites at the network layer lets you move links forward without touching field devices. One example of this design is Quantum Network’s QPN gateway: it is placed at each end of a connection, uses a hybrid key exchange with ML-KEM (FIPS 203), and installs no software on the equipment behind it.
4. Write PQC into procurement now. Require FIPS 203 support or a documented roadmap to it, algorithm agility, a defined path for security updates, and clear behaviour after a line failure (no fallback to unencrypted traffic).
5. Test in OT conditions. Measure latency, failover and recovery on representative links before rollout. Larger post-quantum key material and rekeying must not disturb time-sensitive control traffic.
6. Talk to your competent authority early. Ask how it will interpret the 2030 milestone for your subsector and whether it has a position on hybrid schemes.

Different link types will move at different speeds. NIST’s Dustin Moody, who leads the PQC standardization project, put it this way: “We understand there’s not one strategy that fits all use cases”. For OT operators, this argues for a link-by-link plan with documented priorities, built now while national policies are still being drafted.