NIST's Final IR 8547 of 27 October 2026 Deprecates P-256, RSA-3072 and Ed25519 After 2030, Where the 2024 Draft Left 128-Bit Keys Untouched Until 2035
What NIST changed in the final IR 8547 on 27 October 2026
NIST published the final version of NIST IR 8547, Transition to Post-Quantum Cryptography Standards, on 27 October 2026, replacing the initial public draft of 12 November 2024. The central change sits in the transition tables. The draft deprecated only quantum-vulnerable algorithms at 112 bits of security after 2030 and let stronger keys run until they were disallowed after 2035. The final deprecates every quantum-vulnerable public-key algorithm at 112 bits or more after 2030, so ECDSA on P-256, RSA-3072 and Ed25519 now enter the deprecated category at the same point as RSA-2048. Disallowance after 2035 stays where it was.
How the final ties NIST standards to EO 14412 and OMB M-26-15
The report now cites Executive Order 14412 of 22 June 2026 and OMB Memorandum M-26-15 of 24 June 2026. Under them, federal high value assets and high impact systems must use post-quantum key establishment by 31 December 2030 and post-quantum signatures by 31 December 2031, and agencies must support TLS 1.3 by 2 January 2030. NIST says the 2030 to 2035 window exists for lower-risk and legacy systems and does not relax those deadlines. The final also names ML-KEM-768 as the default parameter set, confirms HQC as the second key-establishment scheme and states that an approved composite, or hybrid, key-establishment technique can be FIPS 140 validated when at least one of its inputs comes from an approved scheme.
GAO's 2024-2025 Post-Quantum Audit of 24 Federal Agencies, Released 6 October 2026, Finds None Met All Inventory, Funding and Testing Practices Ahead of OMB's 22 October Migration Plans
What GAO-27-108740 found at 24 federal agencies in 2024 and 2025
On 6 October 2026 the U.S. Government Accountability Office released the public version of its audit, conducted from February 2024 to September 2025, of how the 24 Chief Financial Officers Act agencies are preparing to move vulnerable systems to post-quantum cryptography. GAO measured three practices drawn from OMB's November 2022 memo M-23-02: a prioritized inventory of systems with vulnerable cryptography, the funding needed to migrate them, and testing in agency environments. None of the 24 agencies fully addressed all three. One agency had a complete inventory of priority systems, 19 used no automated discovery tools, and no agency had tested post-quantum algorithms in its own environment. Agencies may have moved since; the public report does not say.
Why the $7.1 billion figure needs a second look
OMB gave Congress an estimate of about $7.1 billion to migrate priority federal systems or replace legacy systems that cannot support the new algorithms. GAO reports that 21 agencies acknowledged their funding assessments were not fully accurate and that only one assessment rested on a complete inventory.
Why the timing matters in October 2026
The audit work ended in September 2025, and the public version does not discuss OMB's June 2026 memo M-26-15, whose agency migration plans fall due on 22 October 2026. Unless agencies have closed the gaps since 2025, those plans will rest on inventories GAO found incomplete.