This post sets out the post-quantum cryptography (PQC) migration dates published by the UK National Cyber Security Centre (NCSC) and by the European Commission. The NCSC guidance, published 20 March 2025, gives target years of 2028, 2031 and 2035. The Commission press release of 23 June 2025 gives the end of 2026 and the end of 2030. It summarizes those pages and is not legal advice.
What are the NCSC’s three migration dates?
The NCSC guidance “Timelines for migration to post-quantum cryptography” says the national migration is a mass technology change that will take a number of years. It sets out key target dates for migration activities. By 2028 the guidance asks organizations to define their migration goals, carry out a full discovery exercise and build an initial plan. By 2031 it asks for early, highest-priority PQC migration activities and a refined plan. By 2035 it asks for migration to PQC of all systems, services and products.
The NCSC adds that a small set of more rarely used technologies may find migration by 2035 more difficult. It says this may affect some sectors more than others, but that all organizations should work towards the key dates.
Who is the NCSC guidance written for?
The guidance says it is primarily aimed at technical decision-makers and risk owners of large organizations, operators of critical national infrastructure systems including industrial control systems, and companies that have bespoke IT. For small and medium-sized enterprises that use mainly commodity IT, the NCSC says migration should happen seamlessly as vendors update their services. Where custom or specialized software is used, it says the same timetable as for larger organizations should be followed.
What does the NCSC say each phase involves?
The NCSC says it expects large organizations, and those who run their own IT infrastructure, to need 2 to 3 years for discovery, assessment, a migration strategy and an initial plan. It expects a further 2 to 3 years for early migration activities and for refining the plan.
For 2028, the guidance asks for the discovery and assessment phase to be complete and an initial plan that identifies the highest-priority, earliest migration activities, dependencies on suppliers and physical infrastructure, any investment needed, and any long-lived hardware roots of trust that must be migrated. It also asks organizations to communicate their needs to suppliers. For 2031 it asks for the highest priority migrations to protect the most critical assets, infrastructure ready for a PQC future, and a plan with a clear route to full migration by 2035.
The NCSC gives its reason for 2035: it believes that 10 years is a sufficient period for standards to appear, for products to be developed and for uptake to become widespread. On standards, it notes that NIST standardized ML-KEM, ML-DSA and SLH-DSA in 2024. It also says that standardization of PQC within TLS is underway at the IETF, and the NCSC expects final standards around 2027.
- 11 April 2024European CommissionPublishes a Recommendation on a Coordinated Implementation Roadmap for the transition to PQC.
- 23 June 2025European CommissionEU Member States, supported by the Commission, issue a roadmap and timeline.
- End of 2026European CommissionAll Member States should start transitioning to PQC.
- 2028NCSCDefine goals, complete discovery, build an initial migration plan.
- End of 2030European CommissionCritical infrastructures transitioned to PQC no later than this date.
- 2031NCSCEarly highest-priority migration activities done; plan refined.
- 2035NCSCComplete migration to PQC of all systems, services and products.
What do the Commission pages say about EU dates?
The Commission page, published 23 June 2025 and last updated 3 September 2026 as of 9 October 2026, says the Commission published a Recommendation on 11 April 2024. It describes the roadmap as the first deliverable of a work stream with the NIS Cooperation Group, a first high-level paper aimed at Member States. The page says the roadmap includes recommendations that Member States need to implement for a synchronized transition to PQC.
The Commission press release of the same date gives the dates. It says all Member States should start transitioning to post-quantum cryptography by the end of 2026. It adds that the protection of critical infrastructures should be transitioned to PQC as soon as possible, no later than by the end of 2030.
The Commission page also lists a consultation result dated 2 September 2026. It says that from 11 August to 29 September 2025 the NIS Cooperation Group ran a survey for feedback on the roadmap. We read only the listing, not the feedback itself.
How do the NCSC and Commission pages compare?
The two sources address different readers and use different wording, as the table shows.
| Topic | NCSC | European Commission |
|---|---|---|
| Source | Guidance on PQC migration timelines, 20 March 2025 | Press release, 23 June 2025 |
| Addressed to | Large organizations, CNI operators, companies with bespoke IT | Member States |
| Early date | By 2028: goals, discovery, initial plan | End of 2026: Member States should start transitioning |
| Later date | By 2031: early highest-priority migration; by 2035: complete | End of 2030: critical infrastructures, no later than |
For the wider picture on standards, see our post on post-quantum cryptography guidance from NIST and CISA. For the NCSC’s other published work, see the NCSC annual review 2025.
What questions can a team take from these dates?
The NCSC says most of the work to prepare for migration involves activities that are central to good cyber security practice, which links to cyber hygiene. The dates suggest some checks for 2027 planning, which our post on planning a 2027 security program with NIST CSF 2.0 also covers.
Is a discovery exercise of services, data and cryptography in use under way, ahead of the NCSC’s 2028 date? The NCSC says many organizations rely on managed service providers for most of their IT, and that those providers should carry out the same assessment. Does the organization know which suppliers it needs to tell about its PQC needs? That is a third-party risk question. The NCSC also says organizations could consider sharing a statement of intent for their migration.
For deadlines from other rules, see the cyber compliance calendar for 2026 and 2027. Check with counsel on how any rule applies to your organization.
Last checked against the official pages on 9 October 2026. Dates and status can change, so confirm on the pages listed under Sources before acting.
For background on how threats are cataloged, see the Brandefense knowledge hub pages on threat groups, malware families, ATT&CK techniques and significant incidents, and the glossary. The cyber threat intelligence page describes the related service.
