Five PQC Migration Frameworks, Compared: What NIST, CISA, ETSI, and MITRE Actually Agree On

Ask five different standards bodies how to migrate to post-quantum cryptography, and you'd expect five different answers. What's striking about the frameworks actually in circulation is how little they disagree about the first move: build a cryptographic inventory before you do anything else. The disagreement, where it exists, is about who's actually required to do that.

The five frameworks

NIST IR 8547 is the United States' federal strategy document for the transition itself -- identifying which current quantum-vulnerable standards (RSA, ECDH, ECDSA) need replacing and which NIST-finalized post-quantum standards should replace them. It's foundational in scope but still provisional in status: released as an Initial Public Draft on 12 November 2024, with its comment period closed 10 January 2025 and no finalized version published as of this review. Citing it as settled federal policy overstates where it actually sits.

NIST SP 1800-38, from NIST's National Cybersecurity Center of Excellence (NCCoE), is the most technically detailed of the five. It's a practice guide -- an actual architecture for how to build cryptographic discovery tooling, not just a policy statement -- that frames inventory-building as step 2 of a four-step readiness process. It carries real engineering substance and zero legal force: no statutory mandate, no deadline, no defined regulatory scope, no enforcement mechanism. It answers "how," not "whether you have to."

The CISA/NSA/NIST joint factsheet, "Quantum-Readiness: Migration to Post-Quantum Cryptography," published 21 August 2023, is the most widely cited of the five and the easiest to misrepresent. It's marked TLP:CLEAR, meaning it's meant to be shared without restriction -- genuinely public guidance, not a restricted internal document, despite some secondary summaries implying otherwise. Its core ask: form a project team, build a cryptographic inventory across IT and OT systems (including network protocols, end-user systems, and CI/CD pipelines), then run risk assessment and vendor engagement. It explicitly "encourages" and "urges" -- verbs chosen for a document with no compliance mechanism behind them.

ETSI TR 103 619, "Migration strategies and recommendations to Quantum Safe schemes," is the oldest of the five, published by ETSI's Cyber Security Technical Committee in July 2020 -- three years before the CISA factsheet and four years before NIST IR 8547's draft. ETSI Technical Reports are explicitly non-normative by design: they document strategy and recommendations, not requirements, which makes this simultaneously one of the earliest substantive PQC migration documents in the world and one of the least capable of binding anyone, by its own institutional design.

The PQCC roadmap is the outlier in origin: not a government body at all, but an industry coalition, the Post-Quantum Cryptography Coalition, founded by MITRE, which published its migration roadmap in May 2025. Its four stages -- Preparation, Baseline Understanding, Planning and Execution, and Monitoring and Evaluation -- map closely onto the same inventory-first logic the government documents use, dressed in more conventional program-management language. It's explicitly voluntary industry guidance, framed around empowering CIOs and CISOs to act decisively, not a compliance checklist anyone is required to follow.

What they actually agree on

Strip away the institutional differences and the sequencing is nearly identical across all five: find out what cryptography you're actually running before you decide what to prioritize or replace. NIST SP 1800-38 makes that step 2 of 4. The CISA factsheet makes it the first concrete action after forming a project team. PQCC calls it "Baseline Understanding," stage 2 of 4. ETSI's 2020 report and NIST IR 8547's draft both treat cryptographic visibility as a precondition for everything that follows, even though neither uses the word "inventory" as a formal defined term the way the CISA factsheet does.

This convergence matters practically: an organization building toward any one of these frameworks' recommended first step is, in practice, building toward all of them. There isn't a meaningful fork in the road between "NIST-style" and "ETSI-style" inventory work at this stage -- the actual divergence between jurisdictions happens later, in which specific algorithms get mandated and on what legal timeline, not in whether a cryptographic inventory comes first.

What none of them actually requires

This is the detail that gets lost when any one of these frameworks gets cited as "the US mandate" or "the EU standard": none of the five creates a legal obligation by itself. They're frameworks, practice guides, and coalition roadmaps -- methodology, not law. The actual binding deadlines that exist on this tracker come from separate instruments that build on top of this inventory-first logic rather than replacing it: OMB Memorandum M-26-15 requires federal civilian agencies to build their PQC migration plans on a continuously-updated automated cryptographic inventory feeding a Cryptographic Bill of Materials, with plans due 22 October 2026. Executive Order 14412 sets harder dates -- 31 December 2030 for key establishment, 31 December 2031 for digital signatures -- but only for designated federal high-value assets and high-impact systems. Several national regulators elsewhere on this tracker (Germany's BSI, Canada's TBS) have issued their own binding instruments that likewise sit on top of the same inventory-first foundation these five frameworks describe.

What to do with this

If you're choosing which framework to build your organization's migration program around, the honest answer is that it mostly doesn't matter which one you pick first, because they all point at the same starting move. NIST SP 1800-38 is the right choice if you want engineering-level detail on how to actually build cryptographic discovery tooling. The CISA/NSA/NIST factsheet is the right one-page reference for briefing leadership, since it's public, short, and jointly authored by the three most relevant US agencies. PQCC's roadmap is useful if your organization responds better to conventional program-management staging than to government-document structure. None of them should be cited as a reason you're required to do anything on a specific date -- for that, you need the separate binding instrument that applies to your jurisdiction and sector, which this tracker catalogues per country.

See the methodology page for how this tracker scores binding mandates against frameworks like these, and the rankings page for which countries have actually converted inventory-first guidance into an enforceable deadline.