A government certification backlog has left federal agencies with only 16 post-quantum cryptography implementations approved for use as of September 2026, forcing agencies to choose from just eight or nine vendors as they race to meet White House deadlines for securing systems against quantum computer attacks. A report published by the R Street Institute in October 2026 warns that the very process designed to ensure cryptographic security has become the main obstacle to migration, putting national security at risk as adversaries collect encrypted government data now to decrypt it later.

The certification pipeline managed by the National Institute of Standards and Technology's Cryptographic Module Validation Program now takes an average of 348 days to approve submitted modules, according to data from January 2026 cited in the report. The program has accumulated a backlog of 203 modules awaiting review, even as it recently stopped accepting new applications for its laboratory accreditation program due to resource constraints. NIST's Cryptographic Technology Group, which handles validation duties, lists only 35 staff members and has experienced a significant staffing decline over the past three years, despite facing increased submission volumes. The problem is more severe for defense and intelligence agencies, which must navigate two separate restricted certification pipelines rather than one. The Trump administration's June 2026 executive order requires agencies to submit transition plans to the Office of Management and Budget by Oct. 22, 2026, with all high-value federal assets and systems required to adopt quantum-resistant authentication by 2030.

The limited pool of certified products could leave contracting officers with only two or three options during procurement, according to report authors Nicholas Thielman, Billy Ludwick, and Mark Dalton. The report finds that this situation puts agencies at risk of vendor lock-in, suppressed competition, or complete failure to migrate due to lack of bids. The recent expiration of all FIPS 140-2 certificates has worsened the situation by collapsing the marketplace of compliant cryptographic products available across the board, not just for quantum-safe tools. The authors write that "the harvest-now-decrypt-later threat is already active, with adversaries collecting encrypted government data expecting it to be decrypted once mature quantum capabilities emerge."

The report recommends that Congress and the Department of Commerce create an alternative validation pathway using insurance companies that independently evaluate and approve laboratory testing. Under this model, insurers would assess cryptographic modules tested by accredited labs and provide coverage-backed certification that government purchasers could accept instead of traditional CMVP approval. Insurers underwriting these modules would have financial incentive to scrutinize testing, monitor vendor behavior, and require ongoing security commitments, with certification revoked if significant issues aren't addressed. The authors argue that this approach would retain government control over technical requirements while shifting financial risk to insurers and eliminating the secondary federal review queue. They call for OMB and NIST to approve a pilot program comparing this alternative method to conventional validation on time savings, cost, laboratory participation, and security outcomes—with the goal of ensuring the government's own certification process doesn't become the main barrier to the migration it's actively trying to speed up.