European Union
ExecutingCommission Recommendation (EU) 2024/1101 of 11 April 2024 invited Member States to build a coordinated roadmap. The NIS Cooperation Group's 'Coordinated Implementation Roadmap for the Transition to Post-Quantum Cryptography' was adopted on 23 June 2025: Member States should start the transition by the end of 2026, protect high-risk use cases as soon as possible and no later than the end of 2030, and complete the transition of remaining systems as far as possible by 2035.
Recommendations and roadmaps are not directly binding. The binding layer is NIS2 as transposed by each Member State, so the real obligation depends on the country and the sector supervisor.
Member State public administrations, and — through NIS2 risk-management obligations — essential and important entities in the covered sectors
Band rationaleA coordinated roadmap rather than a single PQC regulation; enforcement comes from national law and NIS2.
- 2024-04-11
Commission Recommendation (EU) 2024/1101
Calls for a coordinated implementation roadmap across Member States.
Bindingness · policy roadmap - 2025-06-23
Coordinated Implementation Roadmap published
NIS Cooperation Group PQC workstream roadmap (Part 1) published by the Commission.
Bindingness · policy roadmap - 2026-12
Transition starts
Member States should have started the national transition to post-quantum cryptography.
Bindingness · policy roadmap - 2030-12
High-risk use cases migrated
High-risk cryptographic use cases protected at the latest by end-2030.
Bindingness · policy roadmap - 2035-12
Remaining transition
Transition of the remaining systems as far as possible by 2035.
Bindingness · policy roadmap
The EU milestone set is the reference point most European sector regulators — financial, energy, telecom — will align their own expectations to.
- ·Check the Member State transposition and sector supervisor, not only the EU roadmap
- ·High-risk classification drives sequencing and is defined nationally
- ·Expect supervisors to ask for a cryptographic inventory first
- A1adopted(EU) 2024/1101Commission Recommendation on a Coordinated Implementation Roadmap for the transition to Post-Quantum CryptographyEuropean CommissionPublished 2024-04-11Reviewed 2026-09-06
- A2adoptedA Coordinated Implementation Roadmap for the Transition to Post-Quantum Cryptography (Part 1)NIS Cooperation GroupPublished 2025-06-23Reviewed 2026-09-06
- A2finalPost-Quantum Cryptography — integration studyENISAPublished 2022-10Reviewed 2026-09-06