QUANTUM-SAFECOMPLIANCE AUDIT

Compliance frameworks are catching up with post-quantum cryptography. The National Institute of Standards and Technology finalized the first three post-quantum standards in August 2024. The National Security Agency Commercial National Security Algorithm Suite 2.0 sets a 2035 transition deadline for National Security Systems. Federal agencies have been directed under National Security Memorandum 10 to inventory cryptographic systems and plan migration. Every compliance framework that references NIST algorithms, and most of them do, will eventually require post-quantum cryptography for controlled data. The specific language has not yet landed in every framework, but the direction is unambiguous and prudent organizations are planning now.

Petronella Technology Group audits your existing compliance posture against the emerging post-quantum requirements so that you know exactly where you stand before the framework updates force your hand. Our audit produces a finding-by-finding report mapped to your controlling framework, a gap list that identifies every control that will need evidence updates, a remediation roadmap with budget envelopes, and an evidence package that your assessor can consume directly. The goal is to turn an abstract future regulatory pressure into a concrete work list your team can plan against.

The audit runs as a distinct engagement from a quantum readiness assessment. Where the readiness assessment focuses on the technical cryptographic inventory, the compliance audit maps that inventory into the specific clauses of your framework and produces auditor-facing evidence. Most clients engage us for the readiness assessment first and then for the compliance audit as the next step, but we scope either engagement standalone where that fits the client need.

Step 1: Framework Alignment

We begin by confirming which frameworks are in scope and which specific controls within each framework implicate cryptography. For clients with overlapping obligations we build a single combined control catalog that deduplicates where controls overlap and preserves the stricter standard where they diverge. The output is a working document that the audit team and the client security leadership both sign off on before any technical work begins.

Step 2: Cryptographic Inventory

We inventory every in-scope cryptographic implementation. That includes TLS configurations, SSH, VPN, hardware security modules, cloud key management services, code signing, document signing, application-layer encryption, database encryption, and object storage encryption. For each instance we document the algorithm, the parameter set, the module used, the validation status under CMVP, the data classification it protects, and the business owner. This inventory doubles as SC-12 and SC-13 evidence for the controlling framework.

Step 3: Gap Analysis Against Post-Quantum Standards

We run the inventory against FIPS 203, 204, 205, the draft FIPS 206, NIST SP 800-131A transition guidance, and the specific flowdown language from your controlling framework. The gap analysis produces a finding per control per in-scope system with enough specificity that your engineering team can plan remediation without further interpretation.

Step 4: Remediation Roadmap

We sequence remediation by risk, by compliance urgency, and by operational practicality. The roadmap phases remediation into three to five tranches timed against your annual assessment cycle, so that each tranche lands in time to be reflected in the next assessment package. Each tranche carries a budget envelope, owner, and dependency list.

Step 5: Auditor Evidence Package

The final deliverable is packaged for consumption by your assessor. For CMMC the package is formatted to C3PAO expectations. For HIPAA it is formatted to OCR expectations. For PCI DSS it is formatted to QSA expectations. For FedRAMP it is formatted for 3PAO continuous monitoring review. We include draft SSP updates, draft POAM entries, and a finding-by-finding crosswalk to the control catalog.

The Cybersecurity Maturity Model Certification program requires FIPS-validated cryptography for Controlled Unclassified Information. As NIST transitions classical algorithms into deprecation status and validates post-quantum algorithms through the Cryptographic Module Validation Program, CMMC assessors will evaluate your cryptographic posture against the current NIST guidance. The NSA Commercial National Security Algorithm Suite 2.0 deadline of 2035 is the most explicit driver for defense-adjacent organizations, and the flowdown language from prime contractors is likely to tighten faster than the formal CMMC practice guidance updates.

Our CMMC-focused audit maps every practice that implicates cryptography, including access control, audit and accountability, configuration management, identification and authentication, media protection, and system and communications protection, against the post-quantum standards. We call out specific practices where the evidence you hand an assessor will need to change over time, such as the description of the encryption module used, the algorithm selection documented in your System Security Plan, and the key management procedures described in your policies. We produce the language you need for your SSP and Plan of Action and Milestones artifacts.

Petronella Technology Group is a CMMC-AB Registered Provider Organization under RPO-1449. Our team holds CMMC Registered Practitioner credentials and we work with defense contractors across Level 1, Level 2, and emerging Level 3 scope. See CMMC compliance for the broader program overview.

The HIPAA Security Rule requires covered entities and business associates to maintain reasonable and appropriate safeguards for electronic protected health information. The Rule is framed in risk-based language rather than specific algorithm mandates, which means the definition of reasonable safeguards tightens over time as the threat environment shifts. Post-quantum cryptography matters for healthcare because electronic protected health information often has a confidentiality lifetime measured in decades. Radiology archives, pediatric records, mental health records, and genomic data all remain sensitive long after initial creation. Harvest-now-decrypt-later attacks against long-lived healthcare data are the highest-consequence version of the threat model for most covered entities.

Our HIPAA-focused compliance audit maps your risk analysis against the quantum threat, reviews your encryption for data at rest and in transit, evaluates key management and vendor management under Business Associate Agreements, and documents a path to post-quantum readiness that fits your clinical operations timeline. We explicitly do not recommend rushed changes that would impair patient care. We document the migration sequencing that makes sense for your environment and the interim safeguards that provide quantum risk reduction before the full migration completes. See HIPAA compliance for the broader program context.

Payment Card Industry Data Security Standard version 4.0 defines strong cryptography by reference to industry-accepted standards and explicitly mentions NIST publications. As NIST transitions its published standards to include post-quantum algorithms and deprecates classical algorithms, the PCI DSS definition of strong cryptography will follow. The payment card industry also has long-lived certificate authority infrastructure where the root signing algorithms are expected to operate for decades, which makes PKI modernization a particular concern for acquirers, issuers, and payment processors.

Our PCI DSS compliance audit maps requirements 3 and 4 against post-quantum cryptography, reviews your cryptographic key lifecycle under requirement 3.6, and produces findings that your Qualified Security Assessor can evaluate. We also review the technology inventory for point-of-interaction devices, payment application components, and back-end processors so that the roadmap reflects the very different cadences at which each layer of the payment stack can change.

Cloud service providers pursuing FedRAMP Moderate or High authorization must implement cryptographic protections aligned with the NIST SP 800-53 controls that apply to the target baseline. Those controls reference NIST standards for algorithm selection and will track the post-quantum transition as it progresses through the Cryptographic Module Validation Program. Federal customers are increasingly asking cloud service providers about their post-quantum roadmaps during continuous monitoring reviews and during new authorization packages.

Our FedRAMP-focused audit reviews your System Security Plan cryptographic implementations, your Plan of Action and Milestones entries related to cryptography, and the specific FIPS validation status of the modules you use. We produce the evidence updates your 3PAO will expect during the next continuous monitoring period and the roadmap language that can drop into your SSP for the next annual assessment.

NIST Special Publication 800-53 is the root control catalog that most federal and quasi-federal frameworks inherit from. The cryptographic controls that drive post-quantum compliance work live in the System and Communications Protection family, particularly SC-8 for transmission confidentiality and integrity, SC-12 for cryptographic key establishment and management, SC-13 for use of cryptographic protection, SC-17 for public key infrastructure certificates, and SC-28 for protection of information at rest. Each of these control statements is written algorithm-independent, which means that satisfying the control today in classical algorithms and satisfying it tomorrow with post-quantum algorithms both need to be demonstrable in your evidence.

Our audit walks each of the cryptographic controls in your baseline, documents the current algorithms, identifies the specific enhancement statements that will tighten over time as post-quantum cryptography matures, and calls out the enhancement language that should be added to your SSP in the next revision. We also identify controls outside the SC family that implicate cryptography indirectly, such as AC-17 for remote access, IA-5 for authenticator management, and AU-10 for non-repudiation. These lateral dependencies are often missed in informal reviews and they are where assessors find gaps.

For clients pursuing NIST SP 800-171 compliance under CMMC Level 2, we map to the 110 Level 2 practices with specific attention to the 14 practices that touch cryptographic controls. For clients operating under NIST SP 800-172 for advanced persistent threat protection, we include the enhanced practices and the specific cryptographic modulations that matter for Level 3 scope.

Auditors do not accept statements that the environment uses strong cryptography. They accept evidence. Our audit produces the specific artifacts your assessor will request during review. That includes a documented cryptographic inventory with algorithm, parameter, module, and validation status for every in-scope system, a module validation trace that ties each module back to its FIPS 140-2 or FIPS 140-3 certificate on the Cryptographic Module Validation Program website, a key management procedures document that describes lifecycle in enough detail to satisfy SC-12 enhancement statements, certificate authority practice statements that document algorithm choices and rotation schedules, and a set of configuration samples drawn from production that demonstrate the documented algorithms actually are the ones in use.

For forward-looking evidence, we produce a transition plan that can be referenced in the SSP and the POAM. The plan documents the current state, the target state, the phased milestones, the responsible owners, and the specific control enhancement language that will apply after migration. This is the language that lets your assessor see that the organization is actively managing the transition rather than waiting for regulatory pressure to force emergency changes.

Each sector has its own overlay that shapes the audit. Healthcare clients have the long-lived electronic protected health information problem, which means harvest-now-decrypt-later is the most material quantum risk and data-at-rest cryptography gets weighted higher than in other sectors. Financial services clients have the combined pressure of payment card PKI, interbank messaging, and long-term record retention, which drives a more PKI-centric audit with particular attention to certificate authority practice statements. Defense clients have the NSA CNSA 2.0 deadline and the contract flowdown language from prime contractors, which makes the audit more time-sensitive and more explicit about transition milestones.

State and local government, utilities, and critical infrastructure operators get a tailored audit that maps to the CISA Post-Quantum Cryptography Initiative guidance for their sector. Education and research organizations get attention to federally funded data handling obligations under grant-specific data management plans. Legal services and professional firms get a focus on attorney-client privileged material with indefinite retention. In every case the audit methodology is the same, but the weighting, the specific clauses cited, and the evidence format change to match what the examining authority will expect.

Quantum-safe compliance audits are led by senior consultants with compliance and applied cryptography experience. Craig Petronella holds CMMC Registered Practitioner, Certified Forensic Examiner (DFE 604180), CCNA, and CWNE credentials. Petronella Technology Group is a CMMC-AB Registered Provider Organization (RPO-1449), holds Better Business Bureau A+ accreditation in good standing since 2003, and has been serving regulated clients in the Raleigh and Research Triangle area since 2002. Our team pairs compliance expertise with cryptographic depth so that every finding lands correctly on both axes.

Audits often run in coordination with adjacent engagements. Clients who want the technical inventory as a standalone deliverable engage a quantum readiness assessment first. Clients who know they will migrate and want the audit to feed directly into execution engage a combined audit and migration program. Clients who need the architectural foundation before either engagement engage crypto agility consulting up front so the migration they eventually execute produces artifacts that clean up the agility problem at the same time. Clients who want broader program coverage combine the audit with our cybersecurity program offerings. For a walkthrough of fit, call 919-348-4912 or submit the contact form.

The Cryptographic Module Validation Program is the joint effort of NIST and the Canadian Centre for Cyber Security that validates cryptographic modules against FIPS 140-2 and FIPS 140-3. Post-quantum algorithm support is being added to the CMVP queue as vendors submit modules that implement ML-KEM, ML-DSA, and SLH-DSA. Our audit verifies the current validation status of each module your environment relies on, flags any module whose validation does not yet cover the post-quantum algorithms you will need, and calls out the expected vendor timeline for validation updates. For clients on the FIPS 140-3 track we review the specific implementation guidance that applies to hybrid key encapsulation and to the larger key formats used by post-quantum algorithms, and we document any implementation choices your vendor has made that could affect future validation submissions. The validation status is the most auditor-visible piece of evidence for cryptographic posture, and we treat it with the attention that implies.