Quantum risk in cloud and data centres

Yes, by name. Annex I of Directive (EU) 2022/2555 lists cloud computing service providers, data centre service providers and content delivery network providers under digital infrastructure, and managed service providers and managed security service providers under ICT service management. Article 21(2)(h) requires policies and procedures on the use of cryptography and encryption, Article 21(2)(d) covers supply chain security and Article 20 makes the management body approve the measures, oversee them and follow training. The Commission's implementing regulation of 17 October 2024 turns those measures into technical and methodological requirements for exactly these providers, and applies directly in every Member State.

The Commission Recommendation of 11 April 2024 asks each Member State to adopt a national PQC strategy and deploy PQC, hybrid where needed, across public administration and critical infrastructure. The Coordinated Implementation Roadmap of 23 June 2025 sets the dates: national roadmaps and first steps by the end of 2026, high-risk use cases migrated by the end of 2030, as many systems as feasible by the end of 2035. Neither document names cloud providers, but a provider hosting critical infrastructure customers will be asked to show how its platform supports their 2030 deadline, and the NIS2 cryptography policy is where the authority will look for the answer.

The symmetric layer is fine; AWS says the same on its own KMS documentation. The exposure is the asymmetric cryptography around it: the RSA or ECDH operation that wrapped the data key, the TLS handshake that carried it, the ECDSA signature on the token that authorised the request. Record those today and a future quantum computer unwraps the data key, and with it the AES ciphertext. In a cloud key hierarchy the damage compounds, because one key-encrypting key protects thousands of data keys across many tenants. That is why the hierarchy, not the storage, is the first thing to map.

Yes, at the public edge and on management APIs. RFC 10024, published in August 2026, standardises hybrid key agreement for TLS 1.3 and registers X25519MLKEM768 as the recommended group. Browsers already prefer it, Cloudflare reported more than 65 per cent of human traffic post-quantum encrypted in April 2026, and Google Cloud load balancers enable it by default from October 2026. The handshake grows by about a kilobyte, so test through any middlebox that inspects ClientHello messages, and log the negotiated group so you can report the share. It protects data in transit only; the key hierarchy still needs its own plan.

More than they used to. Executive Order 14412 of 22 June 2026 requires PQC key establishment on high value assets and high impact systems by 31 December 2030 and PQC signatures by 31 December 2031, and orders a proposed FAR rule requiring covered contractors to meet PQC-compliant FIPS by the end of 2030. OMB M-26-15 of 24 June 2026 tells agencies to engage their FedRAMP-authorised cloud providers to delineate PQC responsibilities under the shared responsibility model, names CISA and the Department of War with GSA to lead migration for FedRAMP providers and multi-agency SaaS, PaaS and IaaS, requires TLS 1.3 by 2 January 2030 and points agencies at CISA's product categories list when they buy. Expect a questionnaire, a request for your roadmap and a line in the contract.

The NSA's CNSA 2.0 FAQ expected web browsers, servers and cloud services to support and prefer quantum-resistant algorithms by 2025 and to use them exclusively by 2033. Traditional networking equipment follows 2026 and 2030. It binds US national security systems directly, but any cloud or hosting provider with a national security customer, or a defence prime as a tenant, will be asked to meet those dates for the services that customer uses. CISA's product categories list of January 2026 is the civilian echo: cloud IaaS and PaaS are already categories where agencies should buy PQC-capable products only.

Checked against the providers' own documentation on 30 October 2026. AWS KMS supports hybrid post-quantum TLS with ML-KEM on every endpoint, including FIPS endpoints, and added ML-DSA-44, 65 and 87 key specs in FIPS 140-3 Level 3 HSMs in June 2025. Google Cloud KMS reached general availability for ML-KEM-768, ML-KEM-1024, the X-Wing hybrid KEM, ML-DSA and SLH-DSA-SHA2-128s in 2026, with encapsulation done client-side and a quantum-safe Cloud HSM targeted for 2028. Azure Key Vault's key types page lists RSA, EC and AES keys and points to 256-bit AES as the quantum-resistant option, with no ML-KEM or ML-DSA key type listed. Our comparison article tracks the detail.

This is the slowest layer and the one your roadmap depends on. CISA's January 2026 list places HSMs, PKI and certificate authorities in the transitioning column, not the widely available one. Executive Order 14412 orders NIST to revise Cryptographic Module Validation Program processes within 180 days to speed validations, which tells you the queue is the problem. Ask each HSM vendor which firmware version implements FIPS 203 and 204, whether that firmware sits inside a completed FIPS 140-3 validation or a pending one, and what PKCS#11 v3.1 and KMIP support looks like. Write the answers into the hierarchy map and the next tender.

The Cybersecurity Act (Regulation (EU) 2019/881) created the framework. The first scheme, EUCC for ICT products, became applicable on 27 February 2025. The cloud services scheme the Commission requested from ENISA is still listed as a candidate scheme on the Commission's framework page, last updated 9 September 2026, with no adoption date. In January 2026 the Commission proposed a revised Cybersecurity Act under which schemes would be developed within twelve months by default. Until a cloud scheme is adopted, NIS2 and its implementing regulation are the binding EU requirements on your cryptography.

With four things. A cryptographic inventory that starts at the KMS and HSM roots and the public CA chain. A map of which tenant data must stay confidential beyond 2030, and under which key-encrypting keys it sits. Hybrid key exchange switched on at the edge, with the negotiated group logged. And a PQC questionnaire to every HSM, KMS, CDN, CA and hardware vendor. Those four give the board the evidence to set priorities and give customers a dated statement they can cite.

Everything on this page. The two-minute readiness check scores your platform and routes you to the right next step. The free tools, including the Third-Party Cryptographic Exposure Model and the HNDL Risk Calculator, run in your browser with no registration. The weekly peer call runs every Tuesday at 15:00 CET and is open to anyone. Sample lectures from the 170-plus expert library are linked above, and the page is reviewed as the mandates change; the date beside the key facts is the last check.

It depends on the role. Boards, management bodies and executives start with the Certified Quantum Business Professional bootcamp, about 22 hours self-paced across ten modules. Platform security, SRE and IT teams take Introduction to Quantum Cyber Security, four to five hours online with a QSECDEF certificate. Cloud security architects and key management engineers take PQC Migration for Cloud KMS and HSM Infrastructure, the sector course for key hierarchies, HSMs and FIPS 140-3 revalidation. Whoever will run the migration takes CPQCPM, the Certified Post Quantum Cryptography Programme Manager course: ten hours live online over five weeks, with the next public cohort in January 2027.

Yes. QSECDEF runs private CPQCPM cohorts for a single organisation, live online or in person, and private deliveries of the sector courses listed under Equip your people for your key management, platform and network teams. Board and leadership workshops are built on your own exposure and obligations and end with an agreed position on quantum risk. Use the contact button in the For your organisation section and tell us your timeline.

Through the QSECDEF Expert Members directory. Every listed member has been vetted, has signed the Members' Charter and has presented to the community. You can filter by consulting and services, technology vendor or enablement and investment, and send a request for further information from the member's own page. QSECDEF is vendor-neutral and sells training, not migration products, so the shortlist stays yours.

Two routes. QSECDEF membership gives your team the self-paced courses, the full lecture archive, the weekly call and 25 per cent off CPQCPM and partner training. Expert Membership is for the builders, consultancies and technology vendors serving cloud and data centres who want to be found by the people reading this page; it includes a showcase listing with an enquiry form, the Industry Conversations and speaking slots at the annual QSECDEF symposium.

No. QSECDEF is a vendor-neutral membership network. We train people and connect them with peers and peer-reviewed experts; we do not sell migration software or services.

CPQCPM is ten hours of live instruction over five weeks, two hours a week. The Quantum Cyber Security course is 4 to 5 hours, self-paced. The business bootcamp is self-paced at your own speed. The cloud and data centre courses are listed with their formats on the training pages.