The EU’s Commission Recommendation 2024/1101 encourages all systems handling sensitive data to switch to post-quantum cryptography by 2030. And the Digital Operational Resilience Act (DORA), which started in January 2025, already requires quantum-safe data protection as part of operational resilience frameworks.
Here’s how the recommended timeline is structured:
- Complete cryptographic inventory by 2025: Identify and document all cryptographic assets, protocols, and systems currently in use, especially those protecting sensitive information.
- Begin testing hybrid approaches by 2026: Start testing and piloting hybrid cryptographic solutions (which combine classical and post-quantum algorithms) to ensure compatibility and security during the transition period.
- Complete full migration by 2030: Achieve a full migration to post-quantum cryptography, particularly for critical infrastructure and public sector systems.
The Network and Information Systems Cooperation Group (NIS) is expected to publish the final Europe-wide roadmap for the migration to post-quantum cryptography by April 2026. This will provide clearer technical requirements and guidance for public administrations and critical infrastructure operators like payment networks. The timelines are designed to ensure a smooth transition and compliance, similar to how PSD2 compliance became standard practice across the financial sector.
Fortunately, many institutions aren’t waiting for that regulatory pressure to begin. Santander chairs Europol’s Quantum Safe Financial Forum (QSFF), bringing together over 35 institutions, including Barclays, BNP Paribas, and Mastercard, to coordinate the transition.
In June 2023, the Bank for International Settlements’ (BIS) Project Leap successfully tested quantum-safe communication channels between Banque de France and Deutsche Bundesbank by transmitting simulated payment messages over a quantum-resistant network. Although actual financial data wasn’t used in the tests, BIS was able to demonstrate the feasibility of protecting financial messaging against future quantum threats.
And Worldline (the only payment company participating in NIST’s post-quantum cryptography standardisation process), is demonstrating that digital banking innovation accelerates when regulatory and competitive pressures align.