diff --git a/quantum-top-10/QSxx_Compliance-Obligations.md b/quantum-top-10/QSxx_Compliance-Obligations.md new file mode 100644 index 0000000..239cd47 --- /dev/null +++ b/quantum-top-10/QSxx_Compliance-Obligations.md @@ -0,0 +1,25 @@ +## Compliance Obligations + +**Description:** + +Regulatory, legislative and standards requirements mandate the migration to quantum-resistant cryptography. Organisations must meet such requirements regardless of the creation of a cryptographically-relevant quantum computer (CRQC) that can actually break classical crypto schemes. + +**Common Examples of Vulnerability:** + +1. NSM-10 requires US federal entities to migrate to quantum-resistant cryptography, with a target of "achieving as much migration as possible by 2035". +2. NIST has established timelines for depreciating and disallowing RSA, ECC and Diffie-Hellman. NIST standards are considered de-facto industry standards; in parallel, contractual and insurance terms often include a provision to adopt industry standards. Ergo failing to follow NIST standards could leave an organisation in breach of contractual or insurance terms. +3. Several EU laws reference the need to consider "state-of-the-art" security controls; quantum-resistant crypto meets that definition. + +**How to Prevent:** + +1. Understand the consequences of not migrating, or delaying migrating, by identifying any relevant legislation, regulatory requirements and contractual terms relating to cryptography. +2. Develop and execute a cryptographic migration that fulfils the requirements identified in #1. + +**Example Attack Scenarios:** + +Scenario #1: An organisation defers PQC-related activities in the belief that a CRQC is still many decades away, whilst failing to recognise the evolving compliance landscape. They discover during an audit several years later that their failure to migrate leaves them out-of-step with industry standards, and therefore in breach of contract with their clients. Clients are forced to move their business elsewhere due to their own 33rd-party commitments to their clients. + +**Reference Links:** + +1. [National Security Memorandum 10](https://www.presidency.ucsb.edu/documents/memorandum-promoting-united-states-leadership-quantum-computing-while-mitigating-risks): NSM-10 - Federal requirements for migrating to quantum-resistant cryptography +2. [NIST IR 8547](https://nvlpubs.nist.gov/nistpubs/ir/2024/NIST.IR.8547.ipd.pdf): NIST proposals to depreciate & disallow RSA/ECC/DH