DORA and NIS2: European Requirements for Post-Quantum Cryptography

The anticipated arrival of quantum computers in the coming years, systems capable of breaking classical asymmetric cryptography algorithms (RSA, ECC), requires organizations to rethink the security of their communications and data. The very foundations of cybersecurity are being challenged. How have European institutions addressed this issue through the DORA regulation (Digital Operational Resilience Act) and the NIS2 directive (Network and Information Systems Directive 2), both of which recently came into effect?

In this article, we examine how these two regulatory frameworks lay the groundwork for migration toward crypto-agile and quantum-resistant systems. We also review the implications for organizations and the concrete measures required to anticipate risks and achieve compliance with new European requirements.

Why is cryptography central to regulatory priorities?

Cryptography is the cornerstone of digital trust. It ensures the confidentiality, integrity, and authenticity of digital data and communications. But the emergence of quantum computing disrupts this security foundation: quantum computers will eventually be able to break today’s asymmetric cryptography algorithms (RSA, ECC), jeopardizing the entire current digital ecosystem.

It was therefore essential for European institutions to integrate cryptographic requirements directly into regulatory frameworks to preserve trust.

1. DORA: A Mandatory, Proactive Approach to Cryptographic Risk Management

The European DORA regulation, in effect since January 2025, requires the entire European financial sector to strengthen operational resilience against digital risks. It applies to more than 21 entity types, including banks, insurance companies, investment service providers and market infrastructures.

DORA is complemented by a series of Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) which specify and expand on the operational and technical requirements in the regulation. One RTS, entitled “ICT (Information and Communication Technologies) Risk Management Framework”, specifically addresses cryptography and introduces several concrete mandates.

Quantum Computing and Cryptography: An Acknowledged Threat

The introductory statement of the RTS clearly references risks related to advancements in quantum computing:

“Financial institutions must adopt a flexible approach to managing and monitoring cryptographic threats, including those due to quantum-related advances.”

The regulatory framework therefore requires organizations to consider migration to PQC as a strategic component of their cybersecurity posture.

RTS Requirements for Financial Institutions: 

1. Develop a formal policy governing encryption and cryptographic controls
2. Create and maintain a comprehensive cryptographic inventory
3. Rely on standards and best practices from recognized standards bodies (ISO, ETSI, NIST, etc.)
4. Ensure that the cryptographic policy includes the ability to rapidly replace algorithms in the event of a vulnerability: this is the principle of cryptographic agility
5. Document and justify any inability to implement the above measures. In particular, if classical cryptography is still in use, entities must inventory it and justify why they accept the associated risks. Residual risk assessments must be updated at least annually, incorporating changes in the threat landscape, available mitigations and other factors.

DORA’s requirements are not recommendations, they are mandatory.

2. NIS2: Requirements Reinforced through the Implementing Regulation

The NIS2 directive, which replaces the 2016 NIS directive, aims to improve cybersecurity across strategic sectors in the European Union: critical infrastructures, essential service providers, public administrations and more.

Each Member State was required to transpose NIS2 into national law by October 2024. NIS2 mandates that organizations implement:

• risk-management policies
• security governance mechanisms
• business continuity plans
• incident reporting procedures

Cryptography and NIS2: Where do things stand?

Unlike DORA, NIS2 does not explicitly reference quantum-related threats, although it requires that security measures “take into account the state of the art,” including for cryptography.

The real progress, however, comes from Implementing Regulation (EU) 2024/2690, in effect since November 2024, which details technical requirements for certain digital service providers (cloud, DNS, data centers, etc.).

This regulation introduces several cryptography-related obligations:

• A cryptographic policy based on state-of-the-art practices
• Implementation of cryptographic agility mechanisms enabling rapid algorithm replacement
• Alignment with international standards (ISO/IEC 27001, NIST CSF, ETSI, etc.)
• Mandatory documentation and demonstrable compliance.

These requirements are binding and directly applicable to the organizations concerned.

Finally, in June 2025, the EU agency ENISA published an implementing regulation under NIS2 recommending that systems be secured for the long term by adopting quantum-resistant algorithms, particularly to protect sensitive data vulnerable to “harvest now, decrypt later” attacks.

3. Practical Implications for Organizations: Act Now

To comply with these new requirements, organizations must structure their transition toward PQC around three complementary pillars:

1. Inventory all cryptographic assets

The first step is to identify and map all keys, certificates, algorithms, protocols and cryptographic uses across the organization. This is especially critical given that many of these assets are poorly documented and dispersed across heterogeneous infrastructures.

2. Implement a cryptographic-agility strategy

PQC deployment should not be approached as a simple drop-in replacement for classical algorithms. Regulators require a broader crypto-agility strategy:

• Centralized cryptographic governance
• Ability to switch algorithms at any time
• Documentation and management of cryptographic policies throughout the lifecycle

3. Plan migration to standardized PQC algorithms

In August 2024, NIST published the first post-quantum cryptography standards. They provide a solid foundation on which organizations can build a long-term quantum-resistant architecture. But this transition represents a major transformation: effectively a full redesign of key management, certificates, protocols and data flows. It must be approached with strategic vision, appropriate tooling and expert support.

Adopting these standards today enables organizations to:

• Prepare for upcoming compliance deadlines (with 2035 as a major milestone)
• Ensure long-term resilience of sensitive data
• Meet expectations from customers and partners seeking “quantum-safe” counterparts

Conclusion: The Urgent Need to Migrate to Post-Quantum Cryptography

Driven by DORA and NIS2, migration to PQC is now a regulatory requirement, a strategic necessity and a technological opportunity.

Failing to act now exposes organizations to the risk of:

• Future data decryption
• Regulatory non-compliance
• Loss of customer trust

Conversely, anticipating the transition to post-quantum cryptography enables organizations to build a cybersecurity posture that is robust, adaptable and future proof.