# R Street Proposes Federal PQC Validation Pilot

An R Street Institute commentary says the National Institute of Standards and Technology’s Cryptographic Module Validation Program (CMVP) is slowing federal post-quantum cryptography (PQC) adoption, citing a 203-module backlog, an average 348-day validation period as of January 2026, and only 16 FIPS 140-3-certified PQC implementations as of September 2026. It proposes that the Office of Management and Budget (OMB) and NIST pilot insurer-backed third-party validation as an alternative for eligible federal procurements. This is a policy proposal, not an announced solicitation or funded program. Agencies must submit PQC transition plans to OMB by **October 22, 2026 (two days from the current date)**, while high-value systems are targeted for PQC-hardened authentication by 2030.

- Federal buyers and contractors should distinguish the proposed validation alternative from current CMVP certification processes; the commentary does not establish a new procurement route or change existing requirements.
- The backlog and validation timeline may affect contractors’ planning for PQC-capable products and the timing of federal adoption. Agencies’ transition plans are due October 22, 2026, and high-value system authentication is targeted for 2030.
- Underwriters Laboratories is cited as an example of a third-party certification provider, but no provider has been selected for a pilot. Businesses can assess whether their cryptographic products and validation plans support anticipated federal PQC needs.

**Jurisdictions:** federal
**Industries:** Information Technology
**Topics:** Cybersecurity
**Published:** October 19, 2026

### Government Entities
- National Institute of Standards and Technology (NIST)
- Office of Management and Budget (OMB)

### Vendors
- Underwriters Laboratories (Third-party cybersecurity certification provider cited as an example)

### Sources
- [The Certification Bottleneck: How the U.S. Government Is Slowing Its Own Post-Quantum Migration - R Street Institute](https://www.rstreet.org/commentary/the-certification-bottleneck-how-the-u-s-government-is-slowing-its-own-post-quantum-migration) - R Street Institute