What Are the Contracting Implications of New Quantum-Resistant Security Requirements?

According to the White House, the stated federal policy is to strengthen cryptographic protections and execute the transition of federal information systems to NIST-approved FIPS for post-quantum cryptography, while also assisting critical infrastructure owners and operators with their transitions. NIST describes post-quantum cryptography as cryptographic algorithms or methods designed to resist attack by both a quantum computer and a classical computer, and NIST’s transition paper says the move is from quantum-vulnerable algorithms to post-quantum digital signature algorithms and key-establishment schemes. FedRAMP’s 2026 rules add contracting relevance because providers must document the cryptographic modules used to protect federal customer data, including whether they are validated under the NIST Cryptographic Module Validation Program or are update streams of such modules. FedRAMP also says providers with Class D certifications must use validated cryptographic modules for that purpose, while Class C providers should, and Class A and B providers may. FedRAMP SC-13 further requires organizations to determine cryptographic uses and implement the required types of cryptography. The practical implication is that cryptographic design, module validation status, and migration alignment are part of the federal security work itself.